### UNITED S TATES OF AMERICA ENVIRONMENTAL PROTEC TIO N AGENCY DE PARTMENT OF TRAN S PORTATION
Greenho u se Gas Emi ss ion s and Fu el E ffi ciency Standards fo r M edium- a nd Heavy-Duty Eng in es and Vehicles

- Pha se 2 ) ) ) ) 

### D oc ket No .: E PA-HQ-O A R

- 2014-0827 NHTS A-20 14 -0132 Public Hearin gs: Augu s t 6 and 18, 2015
ORAL STATEM ENT OF THE TRUCK AND ENGI NE MANUFACTURER S ASSOCIATION

I am Jed Mandel, Pr es ident of the T ru ck and Engine Manufacturers Assoc iat ion (EMA). EMA ' s members manufacture the medium- and heavy-duty engines and vehicles that are the subject oftoday ' s rule. As you know, EMA ' s members we r e instrumental in working with EPA, NHTSA, our customers, and other stakeholders on EPA's and NHTSA's historic Phase 1 Rule. That rul e was a s uccess , for among other reasons, because th e final rule was s tru c tured around certain key principles: (i) adopting a sing le , nationwide GHG /FE program; ( ii ) increasing the utili z ation of existing technologies to achieve substantial time gains; (iii) recognizing the commercial needs of the marketplace and the complexity of product offerin gs; and, (iv) avoiding unintende d consequences
. / EMA and its members have advocated that similar principles guide the development and implementation of Phase 2. Given E PA's and N HTSA ' s sta t ed intent is to adopt a significantly m o re stringe nt program, one that forces th e deve lopment of techno logy, th e app ropriate and necessary principles are somew hat modified. Howeve r, it rem ai n s abso lu te ly criti cal th a t we maintain a single , nationwide program. That not on ly means that the EPA and N HTS A rul es must align, but that California must fully harmonize w ith them as well. l n that r ega rd , we are aware th at Ca lifornia ha s advocated that EPA consider adopting a more aggressive timeline for the Phase 2 standards, a long w ith lower NOx limits contemporaneous wi th the proposed Phase 2 standards. More important, California has indicated that they wi ll consider adopting more stringent GHG/ FE and NOx limits on their own if E PA does not act. We have an a lmo st thirt y-yea r hi sto ry of alignment between CA RB and E PA heavy-duty em ission standards. T hat a li gnment is a fundamenta l cornerstone to th e costeffectiveness and implementability of the wo rld 's most stringent criteria emission control program. F ull r egulatory alignment was s imil arl y c ri tical to the s u ccess of Pha se 1. 50-state h armon ization lik ew ise will be absolutely critical to th e f easibili ty of Phas e 2. Given the we llknown, well-documented physics associated with the trade-off between NOx emissions and GllGf FE limits , it is not enough that California a l ign itself with EPA's GHG limits

- - including on the same time li ne recomm ende d and estab lished by E PA. CARB also must continue to fully align w ith EPA o n NOx emissions as well. To do otherwise wou ld ser iou s ly jeopardi ze th e success of both the GHGfFE rule and EPA's criteria emission control program.We remai n open to hearing from both CARB and EPA on their interest in explorin g 

# ' I pos s ibl e futur e lower NOx re ductions , and how and when th ey could b e ach ieved. But , in th e meantime, a nationwid e, full y harmoni zed G H G/criteria e mi ss i o n program mu s t b e maintained. 

### It a l so i s essential th a t th e final rul e recog nizes th e commercial needs of the marketpl ace and th e complexity of product offerings, and avo i ds uninte nd e d consequen ces. To that end , th e final ru le must ( i ) p rov ide adequate le a dtim e and stabi li ty; ( ii ) bal a nce s tringency , cos t and implem e nta tion elates; ( iii ) look to improve m e nt opportuniti es b ey ond ju s t tho se that a r e in the contro l o f truck and e n g in e manufacture rs; ( i v) accoun t for th e impacts of trail er desig n o n tract or ae r ody n amic s; and (v) ass ure uniform, accurate, cost

- effective and reliab le s i mulation modelin g and measurement m ethod s . Th e proposed rule , a nd accompany in g draft Re g ul a to ry Impact Analy s i s, are inc red ibl y complex. They envision a s tro n g, ag g r essive program of Pha se 2 GHG re duct ions and FE improvements. The proposa l a lso d e mon s trates that the agencies ha ve co n si de red multipl e options , are ope n to potential c h a nges b efore th e rul e i s finished , and are committed to work with
a ll s ta ke h o ld e rs to fin a li ze a rul e that s ub sta ntiall y redu ces GHG emissions and impro ves fuel effic ie nc y in a way th at ( i) is cost-effective an d impl e m e ntable ; ( ii ) w ill be accepted by custome rs; a nd ( iii ) will p rov id e real-world imp rovements.
Whil e those goals are e nv isioned in th e proposal , they are not yet fu ll y integ rated into th e proposed regu lations. In a ll candor, we s till are studying the deta il s oftoday"s m ass ive pro p osal. We are f oc u se d on m ak in g s ure that th e final rul e "gets it ri g ht. ' ' To achieve that goa l, we a re comm itted to continuin g to work w ith EPA a nd N HTSA to ass ure that a s tro n g, effective a nd impl e m e nt a b l e rul e is fin a li ze d

- one that m ee ts th e prin c ipl es that we l o n g h ave articulated and that we b e li eve E PA and N H TSA s upport. Today is not th e tim e and place for u s to de li neate wit h s p ec ifity a ll of o ur area s of
concern. But , I wi ll take a mome nt to bri eny identify a few key concerns.
W e note that today 's rule includ es a numb er of prop osa ls that wou ld change the Ph ase 1 rul e . M a nufacturers a lready have full y cmnmitte d to th e i r p r o duct d eve lopme nt plans for Ph ase 1 comp li ance. E PA and N HTSA mu s t no t e ith e r create uncertainty, or eliminate essentia l regulatory s tability , by attempt ing to make r e troact i ve c h a n ges to the Ph ase I rul e.
As yo u know , und e r the D epartme nt of Energy's "Su p e rTruck" initiati ve, EMA memb e rs have d eve loped prototyp e e n g ine , tractor a nd tra i ler combination s that ac hi eve inn ovat ive, gamechan g in g improve m e nt s in freig ht ef fi c i e ncy. Yet, based on o ur prelim in a ry assess m e nt s, eve n tho se SuperTrucks, whic h includ e technol og ies and des i g n e le m e nts that exceed what wou ld b e c ommercially viab le in 2027 , wo uldn ' t be capable of ach iev in g th e best perform i n g veh ic l e re quire m en t s conte m p lated by th e prop osed rul e. We don ' t bel ieve th at E PA's and lJ-IT SA · s intent is to adopt rule s th at wou ld requ ire the developme nt of new techn o log ies, be yo nd the SuperTru ck prototypes ju s t now b e in g d eve loped, as th e re fer e nce for compliance with Ph ase 2. Acco rdin g ly , we believ e th at it i s necessa ry to refin e the r e f

e r

e nce assumptio n s, and co rrec t man y o f th e underlyin g assumpt ions about technolo gy p e ne tration rates fo r certain m a rket segm e nt s, in o rder to finalize a t ec hno logica ll y fe asi bl e a nd impl eme ntabl e rul e.



### 2EPA and NHTSA also are proposing significantly more robust and complex s imul ation models. With those new models comes significant test variab ili ty associated with measurement accuracy, varying ambient conditions, test truck differences, tractor variability, and multiple trai le r gap and tr a il e r configurations. We believe the agencies can, a nd must , minimi ze the many component s that contribute to that variability. Where they cannot fully do so, it is incumbent on the agencies to provide some degree of testing margin to account for that variability. Otherwise , to a s sure technical comp liance, manufacturers will be forced to downgrade the actual, real-world GHG / FE perf orma nce of their tractors. H owever , th e net r es ult of being forc ed to do so will be their inability to achieve th e certification le vels co ntempl ated by the proposed rule. Consequently, the agencies' allowance of sufficient test and audit margins are key to the implementation of feasible technology-forcing Ph ase 2 standards.
We know that EPA and N HTS A a re a ttemptin g to find a bal a nce between separate e ngi ne and comp le te vehic le standards. Our members have strong views on that subject. You have heard f rom them , a nd will continue to hear from them. However. as an indu s try, we all agree that it is critical that the agencies "get right" the intersect between those two views

- - spec ifi cally, the manner in which the e n g in e i s accounted for in th e Greenhouse Gas Emissions Mode l ( GEM). As it s tand s now , th e agencies have n ot yet got 

### it ri g ht. Among other things, in attempting to connect the engine and vehicle standards , EPA and NHTSA have yet to account for the known variability associated with measuring the fuel consumption of an engine to simulate that engine in GEM

. A compliance margin is absolutely necessary , especially in the context of an age ncy audit , to account for inherent variab ili ty in c haracterizi ng e ngin e fuel consumption. Without a compliance margin , the proposed rule w ill not be feasible. As with Phase 1 , EMA and its members are committed to workin g with EPA and NHTSA to resolve the many important ope n issues , in cl udin g th ose 1 have touched on today. We w ill be provid ing our best technical assessment of the proposed rule, a nd our recommendations for necessary improvements, all supported by data. Our customers have long demanded fuel effic iency. We have worked to continuously improve it

- - even while making incredible improvements in th e reduction of cri t e ri a pollutants. We intend to continue to provide improved fuel effic ie ncy , and th e corr espo nding improve m e nts in GHG emissions. To that end, it is essential that the final rule pro vide an appropriat e, fa ir , cost-effective, and implementablc regulatory framework for those fut ure improvements; one that does not d i srupt the market or cau s e serious unintended consequences. We are ready to assist in that effort. If yo u h ave a ny qu es t io n s, I am happy to an swe r th e m.



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