ENVIRONMENTAL DEFENSE FUND 

STATEMENT ON 

U.S. ENVIRONMENTAL PROTECTION AGENCY AND NATIONAL 

HIGHWAY TRAFFIC HIGH\IVAY SAFETY ADMINISTRATION 

"PROPOSED RULE- GREENHOUSE GAS EMISSIONS AND FUEL 

EFFICIENCY STANDARDS FOR MEDIUM- AND HEAVY-DUTY 

ENGINES AND VEHICLES-PHASE 2" 

EPA-HQ- OAR- 2014-0827 

NHTSA- 2014- 0132 

* * * 

HILARY SINNAMON 

* * * 

Public Hearing 

Los Angeles, California 

August 18, 2015 

On behalf of Environmental Defense Fund and our more than 1 million members 

nationwide and the nearly 200,000 here in California, I sincerely thank you for the 

opportunity to te tify today in support of a timely and rigorous Phase 2 program to reduce 

climate pollution and fuel consumption from our nation's fleet of heavy-duty trucks and 
buses - the most swiftly growing transportation source of greenJwuse gas emissions in 

the United States. i 

The proposed standards build on the histori c first ever fuel economy and grcenJ10use gas 

standards for the heavy-duty sector. The success of the first phase of the program is 

already being demonstrated by the demand for more efficient trucks- model year 2014 

heavy-duty trucks saw the highest sales since 2005ii and Class 8 sales this summer arc up 

an impressive 23% over the same time last year. iii 

This second phase of the program provides a critical opportunity to deli ver even greater 

emissions and oil reductions while spurring teclmological innovation and saving 

businesses and consumers money. 

II cavy trucks transport the products we buy every day and pcrfom1 thousands of other 

vital services. However, these vehicles also consume more than 135 million gallons of 

fuel every day and emit more than 450 million metric tons of climate poll ution annually.iv 

In California, heavy trucks contribute significantly to the state's carbon pollution and air 

qua lity problems. Southern California has the worst air qua lity in the country and, in Los 

Angeles County alone, nearly 400,000 children suffer from asthma while li vi ng in an area 

that fa ils the health-based standards for ozone and particulate pollution.v The county is 

also home to the largest port complex in the nation, which relies on heavy-duly vehicles 

to sustain its operations - vehicles that can be cleaner and more efficient. 

California has already demonstrated critical leadership, recognizing the importance of 

achieving emission reductions from the state's large trucks and buses- actions that have 

spurred critical progress both statewide and nationally. For example, California's trailer 

efficiency standards have yielded strong benefits and arc now an important feature of the 

agencies' proposed rule. And just recently, Governor Brown atmounccd an initiative to 

further strengthen the environmental and economic performance of California's 

transportation sector. The Phase 2 heavy-duty greenl1ousc gas and fuel economy 
standards arc one of the single most important opportunities to protect human health and 

the environment in Californ ia and across the nation. 

While the proposals by EPA and DOT arc an important step forward, there arc many key 

opportunities to strengthen the standards in a way that secures the emission reductions 

that arc needed to protect our fami lies and communities and that drives American 

ingenuity to ensure we are innovating to strengthen our economy and protect our 

environment. 

In addition to other opportunities, we respectfu lly make the following central 

recommendations. 

# I: Strengthen the engine standard 

A separate, rigorous engine standard is essenti al to deliver permanent, real-world 

emissions reductions. It also allows EPA and manufacturers to simultaneously evaluate 

NOx and C02 emissions, ensuring that efficiency improvements do not result in higher 

NOx emissions. However, the proposed 4.2 percent engine efficiency improvement over 

ten years falls woefully short of what manufacturers and leading analyses have indicated 

is viable. Existing technologies have the potential to cost-effective ly increase the engine 

efficiency by 15% beyond the 20 17 levels. A weak engine standard undcm1ines the 

overall tractor trail er standard and fai ls to drive a wide array of important engine 

technologies that can deliver real world reduction. The Agencies must finalize a 

protective engine standard that reflects the innovati ve path oftoday's technologies and 

carries out its legal responsibilities under our nation's clean air laws. 

#2: Accelerate the timing of the standards to 2024 

To ensure the Phase 2 program drives needed emission reductions and technological 

innovation in the ncar term, it is essential that standards be ful ly implemented by 2024. 

The agencies' own ana lysis - proposed as Altemative 4- indicates this is eminently 

feasible and cost-effecti ve. Speeding the transition to cleaner trucks would save an 

additional 200,000 barrels of oil per day in 2035, and avoid an additional 40 million 
metric tons of global wanning emissions annually.'·i A faster timelinc would also hasten 

the important NOx reductions- 2.4 million tons reduced over the life of the program - an 

improvement California would ce1iainly benefit from. 

#3: Promulgate protective emissions standards for the particulate pollution from APUs 

Auxiliary power units (A PUs) arc among the technologies available to reduce fuel use 

from sleeper cab tractors due to idling. However, the particulate standards for diesel 

APUs, established under the nonroad n ile, arc not nearly as protecti ve as the truck engine 

standards for MY 2007 and later trucks, which require the use of diesel particulate filters 

(DPFs) or comparable altemative. This disparity allows diesel A PUs to emit more than 

five times as much harmful diesel particulate as the trucks they arc relieving.' ii This 

increase in particulate emissions will be especially significant at idling "hotspots" like 

truck stops, distribution centers and port areas like here in Long Beach. California has 

already established more protective standards for APUs and has concluded the 

technologies arc available and highly cost-effective. We request that EPA fol low 

Cali fomia 's lead and put in place protective particulate emissions standards for these 

units to protect public health and the environment from the harmful impacts of diesel 

particulates. 

The Phase 2 standards represent an important opportunity to protect America's health, 

strengthen its economy, and improve energy security all while saving truckers money in 

fuel costs. I appreciate the opportunity to testify, and respectfully request the Agencies 

finalize rigorous protective standards for California and our nation. 

Thank you. 

'.Energy lnfonuation Agency. Annual Energy Outlook (20 15) Tables A-7 and A-19. 

" http://www.truck i ngi n lQ..com/channellflcct-managcmcnl/newslslorv/20 14/ 1 0/hcalthy-demand-ovcrall-fortrucks-in-scptcmber.aspx?rcf=rcl-recommended (las! accessed November 5, 2014) 

,;, hllp://trai la-bodybui ldcrs.com/chassislmedium-and-hca\ y-truck -sales-7 -july 

" Energy lnfom1a1ion Agency, Annual Energy Outlook (20 15) Tables A-7 and A-1 9. 
" American Lung Association, State of the Air 2015 website, report card for Los Angeles County. A vailablc 

at: http://www .sta teoftheair.org/20 15/states/ca l ifornia/los-angcles.htnl! (last accessed August 13, 20 15). 

,; UCS f<tctsheet, "Newly Proposed Heavy-duty Truck Efficiency Standards for 20 18-2029," July 2015. 

http://www .ucsusa .org/si tes/clefault/fi les/attach/20 15/07 /proposcd-hcavy-duty-veh icles-standards.pd r 

,;; CARI3, Staff Report: Initial Statement o.f Reasons Notice of Public Hearing to Consider Requirements to 

Reduce Idling Emissions from NeiV and In-Use Tmcks, Beginning in 2008 (2005). Table 3 and Table 5, 

page 44. 

http://www .arb.ca. gov/regacUhd vidlc/isor. pd I'