ENVIRONMENTAL 

EDF~ $ 

DEFENSE FUND ' 

Finding the ways that work 

ENVIRONMENTAL DEFENSE FUND 

STATEMENT ON 

U.S. ENVIRONMENTAL PROTECTION AGENCY AND 

NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION 

"GREENHOUSE GAS EMISSIONS AND FUEL EFFICIENCY STANDARDS FOR MEDIUMAND HEAVY-DUTY ENGINES AND VEHICLES- PHASE 2" 

EPA-HQ- OAR-2014-Q827; NHTSA-2014- 0132 

* * * 

JASON MATHERS 

* * * 

Public Hearing 

Chicago, Ill inois 

August 6, 201S 
On behalf of Environmental Defense Fund and our more than one million members nationwide, I 

sincerely thank you for the opportunity to testify today. 

Freight trucks are one of the single fastest growing sources of climate disrupting emissions. leaders in 

business and the environmental community alike recognize that rigorous well designed standards can 

save fleets and families in fuel costs, can reduce dangerous pollutants and can strengthen our global 

competitiveness by spurring the deployment of existing technologies. 

In fact, in a recent Wall Street Journal op-ed, Fred Krupp president of EDF, joined with lndra Nooyi, 

chairman and CEO of PepsiCo, in a call for "strong federal standards" to reduce fuel consumption and 

greenhouse gas emissions from heavy trucks. 

As proposed, the heavy truck fuel efficiency and greenhouse gas standards are an important step 

forward, but they fall short of being the strong standards our nation needs. 

We need final phase two standards that are built to enable innovators to advance further in their efforts 

spurring technologies that can achieve deeper emissions reductions and greater efficiency 

improvements. Standards that lock in currently available technology would be a terrible misread of 

market demand and would fail to carry out the technology-spurring statutory requirements of the 

nation's clean air laws. 

We respectfully make the following recommendations to realize the environmental and economic 

opportunity of protective standards. 

#1 Strengthen the engine standard 

An engine standard is essential for several reasons, including the ability to deliver permanent, real-world 

results; and allowing EPA and manufacturers to simultaneously evaluate NOx and C02 emissions, 

ensuring that efficiency improvements do not result in higher NOx emissions. 

Existing technologies have the potential to cost-effectively reduce engine fuel consumption by more 

than 15% beyond the 2017 levels. Through the impressive results of the DOE SuperTruck program, 

advanced technologies are demonstrating the ability to achieve even greater reductions 

Engine improvements on the order of 15% will deliver significant cost savings for the end-users. Analysis 

by M.J. Bradley and Associates found that a final standard consistent with a 15% engine standard would 

reduce the lifecycle operation cost of a new sleeper combination truck by $0.22 per mile in 2030-

saving fleet owners and their customers tens of billions annually. 

#2 Accelerate the timing of the most stringent standards to 2024 

The compliance timeline in alternative four is consistent with our assessment of the appropriate 

timeframe for implementing the most stringent standards. Nearly a decade away, it provides sufficient 
lead time for the manufacturers to cost-effectively scale fuel saving solutions. It also better reflects the 

urgent need to reduce climate disrupting emissions. 

#3 Ensure emission reductions regardless of fuel choices 

Diesel is the current dominate fuel for heavy trucks. While it is likely to remain the most widely used fuel 

throughout the phase two proposal, gasoline and natural gas are each making inroads in different 

market segments. The agencies need to safeguard projected savings from being eroded by lower 

standards for other fuels or perverse incentives in the rule. 

EDF is particularly concerned about the ability of natural gas trucks to deliver real-world greenhouse gas 

reductions. Given the significant impact of upstream methane emissions, a recent ICCT study found that 

"inadequate attention to technologies designed to limit methane leakage ... would diminish the program 

benefits by as much as 38 percent." This is simply not acceptable. 

The proposal takes important steps forward in respect to its treatment of methane emissions from 

natural gas trucks. The requirements that natural gas engines have closed crankcases and the 

establishment, for the first time ever, of hold-time requirements for LNG fuel tanks, are important. 

While it is critical for EPA to carry out the President's January 2015 commitment to secure a 40-45 

percent methane reduction by addressing the leak, discharges and venting associated with oil and gas 

development, there are several additional steps the agency can take under this rulemaking to further 

address the impact of methane emissions. 

First, the EPA should use the current Global Warming Potential values put forward by the IPCC. 

Second, the agency should recognize the full impact of methane by accounting for its impact at multiple 

time periods. 

Third, the agency should adopt a full fuel cycle accounting approach for alternative fuels, which the \l 

agencies chose to pursue in the historic light-duty standards. 

The agencies need to act on gasoline too. It is inconsistent with mandate of these agencies to continue 

to hold diesel and gasoline engines to different standards. We urge you to decrease the gap between 

the diesel and gasoline standards over the phase two program in order to completely phase out 

separate standards. 

In sum, there are cost-effective, workable steps the agencies can take to finalize strong standards that 

will: 

• Save tens-of-billions annually for the U.S. economy 

• Support American innovation 

• Reduce greenhouse gas emissions- on an absolute basis- and put us on a path for future 

gains. 
To close, though, I want to note that as important as strong final rules are to me professionally, it is 

essential to me personally. 

Two months ago, I was blessed with the birth of a second child. Climate change will be a consistent 

challenge for his generation. He will turn 35 in 2050- by when our best science tells us that we must 

have emissions down 80% to avoid the worst impacts of a warming world. As much faith as I have in his 

abil ity and that of his generation, it is irresponsible for us to burden him and others with the immense 

challenges of a warming world. While this effort is but one of the many needed, the responsible course 

of action is to maximize the adoption of the cost-effective fuel-savings existing technologies. 

Thank you