UNITED STATES OF AMERICA 

ENVIRONMENTAL PROTECTION AGENCY 

DEPARTMENT OF TRANSPORTATION 

Greenhouse Gas Emissions 

and Fuel Efficiency Standards 

for Medium- and Heavy-Duty 

Engines and Vehicles - Phase 2 

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Docket No.: EPA-HQ-OAR-2014-0827 

NHTSA-2014-0132 

Public Hearings: August 6 and 18, 2015 

ORAL STATEMENT OF THE 

TRUCK AND ENGINE MANUFACTURERS ASSOCIATION 

I am Jed Mandel, President of the Truck and Engine Manufacturers Assoc iation (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 were instrumental in working with EPA, 

NHTSA, our customers, and other stakeholders on EPA's and NHTSA's historic Phase 1 Rule. 

That rule was a success, for among other reasons, because the final rule was structured around 

certain key principles: (i) adopting a single, nationwide GHG/FE program; (ii) increasing the 

utilization of existing technologies to achieve substantial time gains; (iii) recognizing the 

commercial needs of the marketplace and the complexity of product offerings; and, (iv) avoiding 

unintended consequences. / 

EMA and its members have advocated that similar principles guide the development and 

implementation of Phase 2. Given EPA's and NHTSA's stated intent is to adopt a significantly 

more stringent program, one that forces the development of technology, the appropriate and 

necessary principles are somewhat modified. However, it remai ns absolute ly critical that we 

maintain a single, nationwide program. That not only means that the EPA and NHTSA rul es 

must align, but that California must fully harmonize with them as well. 

ln that regard, we are aware that California has advocated that EPA consider adopting a 

more aggressive timeline for the Phase 2 standards, along with lower NOx limits 

contemporaneous with the proposed Phase 2 standards. More important, California has indicated 

that they will consider adopting more stringent GHG/FE and NOx limits on their own if EPA 

does not act. We have an almost thirty-year history of alignment between CARB and EPA 

heavy-duty emission standards. That alignment is a fundamental cornerstone to the costeffectiveness and implementability of the world's most stringent criteria emission control 

program. 

Full regulatory alignment was similarly critical to the success of Phase 1. 50-state 

harmonization likewise will be absolutely critical to the feasibility of Phase 2. Given the wellknown, well-documented physics associated with the trade-off between NOx emissions and 

GllGfFE limits, it is not enough that California align itself with EPA's GHG limits - - including 

on the same time li ne recommended and established by EPA. CARB also must continue to fully 

align with EPA on NOx emissions as well. To do otherwise would seriously jeopardize the 

success of both the GHGfFE rule and EPA's criteria emission control program. 

We remain open to hearing from both CARB and EPA on their interest in exploring 

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possible future lower NOx reductions, and how and when they could be achieved. But, in the 

meantime, a nationwide, fully harmonized GHG/criteria emission program must be maintained. 

It also is essential that the final rule recognizes the commercial needs of the marketplace 

and the complexity of product offerings, and avoids unintended consequences. To that end, the 

final rule must (i) provide adequate leadtime and stabili ty; (ii) balance stringency, cost and 

implementation elates; (iii) look to improvement opportunities beyond just those that are in the 

control of truck and engine manufacturers; (iv) account for the impacts of trailer design on 

tractor aerodynamics; and (v) assure uniform, accurate, cost-effective and reliable simulation 

modeling and measurement methods. 

The proposed rule, and accompanying draft Regulatory Impact Analysis, are incredibly 

complex. They envision a strong, aggressive program of Phase 2 GHG reductions and FE 

improvements. The proposal also demonstrates that the agencies have considered multiple 

options, are open to potential changes before the rule is finished, and are committed to work with 

all stakeholders to finalize a rule that substantially reduces GHG emissions and improves fuel 

efficiency in a way that (i) is cost-effective and implementable; (ii) will be accepted by 

customers; and (iii) will provide real-world improvements. 

While those goals are envisioned in the proposal, they are not yet fu lly integrated into the 

proposed regulations. In all candor, we still are studying the details oftoday"s massive proposal. 

We are focused on making sure that the final rule "gets it right.'' To achieve that goal, we are 

committed to continuing to work with EPA and NHTSA to assure that a strong, effective and 

implementable rule is finali zed - one that meets the principles that we long have articulated and 

that we believe EPA and NHTSA support. 

Today is not the time and place for us to delineate with specifity all of our areas of 

concern. But, I will take a moment to brieny identify a few key concerns. 

We note that today's rule includes a number of proposals that would change the Phase 1 

rule. Manufacturers already have fully cmnmitted to their product development plans for Phase 

1 compliance. EPA and NHTSA must not either create uncertainty, or eliminate essential 

regulatory stability, by attempting to make retroactive changes to the Phase I rule. 

As you know, under the Department of Energy's "SuperTruck" initiative, EMA members 

have developed prototype engine, tractor and trailer combinations that achi eve innovative, gamechanging improvements in freight effic iency. Yet, based on our preliminary assessments, even 

those SuperTrucks, which include technologies and design elements that exceed what would be 

commercially viable in 2027, wouldn't be capable of achieving the best performing vehic le 

requirements contemplated by the proposed rule. We don't believe that EPA's and lJ-ITSA · s 

intent is to adopt rules that would require the development of new technologies, beyond the 

SuperTruck prototypes just now being developed, as the re ference for compliance with Phase 2. 

Accordingly, we believe that it is necessary to refine the refe rence assumptions, and correct 

many of the underlying assumptions about technology penetration rates for certain market 

segments, in order to finalize a technologically feasi ble and implementable rule. 

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EPA and NHTSA also are proposing significantly more robust and complex simulation 

models. With those new models comes significant test variability associated with measurement 

accuracy, varying ambient conditions, test truck differences, tractor variability, and multiple 

trailer gap and trail er configurations. We believe the agencies can, and must, minimize the many 

components 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 assure technical compliance, manufacturers will be forced to downgrade the actual, real-world 

GHG/ FE performance of their tractors. However, the net result of being forced to do so will be 

their inability to achieve the certification levels contemplated by the proposed rule. 

Consequently, the agencies' allowance of sufficient test and audit margins are key to the 

implementation of feasible technology-forcing Phase 2 standards. 

We know that EPA and NHTSA are attempting to find a balance between separate engine 

and complete vehic le standards. Our members have strong views on that subject. You have 

heard from them, and will continue to hear from them. However. as an industry, we all agree 

that it is critical that the agencies "get right" the intersect between those two views - -

specifically, the manner in which the engine is accounted for in the Greenhouse Gas Emissions 

Mode l (GEM). As it stands now, the agencies have not yet got it ri ght. 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 agency audit, to account for inherent variability in characterizing engine fuel consumption. 

Without a compliance margin, the proposed rule will not be feasible. 

As with Phase 1, EMA and its members are committed to working with EPA and 

NHTSA to resolve the many important open issues, including those 1 have touched on today. 

We will be providing our best technical assessment of the proposed rule, and our 

recommendations for necessary improvements, all supported by data. Our customers have long 

demanded fuel efficiency. We have worked to continuously improve it - - even while making 

incredible improvements in the reduction of criteria pollutants. We intend to continue to provide 

improved fuel efficiency, and the corresponding improvements in GHG emissions. To that end, 

it is essential that the final rule provide an appropriate, fair, cost-effective, and implementablc 

regulatory framework for those future improvements; one that does not disrupt the market or 

cause serious unintended consequences. We are ready to assist in that effort. 

If you have any questions, I am happy to answer them. 

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