Testimony 

Presented to the National Highway Traffic Safety Administration and 

U.S. Environmental Protection Agency 

By Vice Admiral (Retired) Ann Rondeau 

In support of 

Gr eenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and HeavyDuty Engines and Vehicles- Phase II 

August 6, 2015 

Chicago, Illinois 

Docket: EPA- HQ-OAR- 2014-0827 

Thank you for the opportunity to present testimony in support of the proposed 

Phase II Greenhouse Gas Emissions and Fuel Effic iency Standards for Medium- and 

Heavy-Duty Engines and Vehicles. I am Vice Admiral Ann Rondeau. and I retired from 

the U.S. Navy in 20 12 after 38 years of service. On one of my last commands, I had the 

honor to serve as Deputy Commander for U.S. Transportation Command 

(USTRANSCOM) a unified, functional combatant command which provides support to 

the eight other U.S. combatant commands, the military services, defense agencies and 

other government organizations. In other words, a truck or convoy didn't move without 

my unit knowing about it. 

It is through the lens of my experiences at USTRANSCOM and serving nearly 

four decades as a naval officer in the armed services that I view the critical issue of fuel 

economy. I experienced firsthand the importance of getting vehicles and equipment to 

travel farther - by the road, air or sea - on less fuel. This battlefield perspective drives 

my support for Phase II of the National Highway Traffic Safety Administration's heavyduty truck rule. Why? When it comes to fuel usage, the military didn't always get it right, 

and we have learned the hard way that boosting gas mileage improves national security. 

Since the advent of the U.S. military's evolution into a motorized. machine-driven 

force in the wake of World War I, the abi liry to adeptl y move troops, supplies, 

ammunition, and other daily needs has become core to the effecti ve execution of our 

missions. Over the last century, the need for agility and mobility has only increased with 

each wartime engagement. And it's been technological ingenuity that helped us evolve 

into the military we are today. We've come a long way since stranding our tanks in the 

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desert in World War lJ after running out of fue l, but yet 70 years later, our nation - and 

armed forces - is still hamstrung by our overreliance on fossil fuels. In fact, our 

overdependence on oil makes it more likely that our men and women in uniform will be 

sent into harm's way. 

Reducing fuel use by improving efficiency enhances the military's operational 

effectiveness. decreases the size of convoys and saves lives. The men and women of our 

armed forces, who tirelessly protect our nation at home and overseas, are placed at an 

increased risk due to our oil addiction. The sad truth is that fuel convoys have become a 

primary target in the battlefield. In 2007, one in every 24 convoys in Afghanistan resulted 

in the death or serious wounding of one of our fighting forces, according to an Army 

study. These brave men and women deserve bener odds when they take the wheel. Every 

gallon of gas we can save by increasing the efficiency of trucks helps reduce the threat to 

those serving in uniform. Reducing our fuel use also decreases the cost of defense 

operations. The fitlly burdened cost of f uel is a calculation the Department or Defense 

(DOD) makes that is equal to the commodity cost plus the totallifecycle cost of all 

people and assets required to move and protect fuel from the point of sale to the end user. 

I can speak from experience; the fully burdened cost of fuel makes oil a budget buster. 

By making the trucks running on US highways more efficient. we can transfer 

that technology to ensure the heavy machinery used by the military is more efficient -

from trucks, to ships, to generators- reducing the stress of fulfilling everyday tasks that 

are core to military logistics. When we are able to mobilize our vehicles on less fuel, 

DOD saves money. but more importantly, we reduce logistics, reduce exposure, reduce 

convoys and save American lives. 

/\way from the front lines, the nation's overreliance on oil also impacts our 

national. economic and energy security. This addiction leaves us vulnerable to a volatile 

international market and the unfriendly nations who control the spigots. Last year, due to 

increased efficiency and production, the United States significantly cut oil imports. I 

applaud this effort, but the hard work remains. As a nation, we still import nearly 30 

percent of the oil we consume, and whil e the majority of that oil is now from Canada and 

Mexico and other friendly nations, the price of oil is not in our total control. regardless of 

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how much we conserve or even produce. Just look at Libya as an example. In 2011 , we 

imported no oil from Libya. But when Libya broke into civil war, the price of oil 

worldwide increased to over $ 1 00/barrel, and rose to over $3.00 gallon at the pump in the 

U.S. The prices in the U.S. rose because oil is a global commodity. While we had a brief 

reprieve over the winter back in Washington, DC, we are back to more than $3 .00 at the 

pump. But make no mistake these prices are not floating on pure supply and demand; 

they are being controlled to a great extent by how much the Saudis choose to produce. 

Oil prices can be forced up as quickly as they can be brought down, wreaking 

havoc on the American economy and undermining our nation's strength domestically and 

internationally. Our economic engine is heavily reliant on transportation, and 94 percent 

of our nation's transportation relies on oil. It's easy to see how oil price shocks can be 

used as weapons to attack our stability as a nation. We can' t drill ourselves to energy 

independence when we are reliant on a finite, global commodity. The only option is to 

use less. 

CNA Military Advisory Board (MAB), a panel of top-ranking retired military 

leaders on which I have the pleasure to serve, has reported extensively on how our 

overreliance on oil is a national vulnerability. In short, the MAB's findings are simple: 

efficiency makes us more resilient, and increased fuel economy standards underpin a 

suite of conservation and energy diversification steps this nation can take - should take -

to get on the road toward energy independence. 

It's mission critical: the U.S. must use its ingenuity to lead global efforts to 

deploy advanced technologies that lower the demand for oil. Based on my own 

experience, fuel economy standards for cars and trucks have proved to be powerful tools 

that speed innovation, decrease our dependence on oil and improve our nation's overall 

economy and security. In closing, 1 reiterate my support for the proposed Phase IJ 

Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and lleavy-Duty 

Engines and Vehicles, and I hope to see NHTSA and EPA finalize this rule without 

delay. 

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