STATEMENT OF THE 

ADVANCED ENGINE SYSTEMS INSTITUTE 

ON THE PROPOSAL BY THE U.S. ENVIRONMENTAL PROTECTION 

AGENCY AND THE NATIONAL HIGHWAY TRAFFIC SAFETY 

ADMINISTRATION TO SET PERFORMANCE STANDARDS FOR 

GREENHOUSE GAS EMISSIONS FROM MEDIUM- AND HEAVY -DUT 

VEHICLES - PHASE 2 

DOCKET ID NO. EPA-HQ-OAR-2014-0827; NHTSA-2014-0132 

AUGUST 18, 2015 

My name is Mona Sheth, I am here on behalf of the Advanced Engine Systems Insti 

(AESI) to provide comments on the agencies' proposal to set more stringent greenhouse gas 

standards for medium- and heavy-duty vehicles. 

AESI represents several emissions control and efficiency technology manufacturers i an 

industry employing more than 65,000 people in the U.S. For more than 40 years, our indust has 

been working with vehicle manufacturers - our primary customers - and the regulators to deve op 

technologies to reduce harmful pollution in the most cost-effective ways possible. 

The industry's many innovations developed and deployed in the U.S., in response to 

science-driven air quality regulations, have reduced pollution from cars and trucks by more th n 

75% since 1975. This has occurred even while vehicle miles traveled increased 300%, drivin 

economic growth forward and significantly enhancing mobility. 

We commend the Agency and the President for going beyond the public health and 

environmental impacts of criteria pollutants like particulate matter (PM) and nitrogen oxides 

(NOx) to tackle the grave risks associated with greenhouse gas and black carbon emissions. 

Carbon pollution from the U.S. transportation sector, especially medium- and heavy-duty 

vehicles, is a very significant contributor to global atmospheric concentrations and will rise 

through 2040 without Phase 2 or similar limits. 

AESI is pleased that the Agency has proposed to retain the basic regulatory structure sed 

in Phase 1, including a separate engine standard and similar testing and certification procedur . s. 

Our industry has invested heavily in research and systems to deliver cost-effective greenhous 

gas reductions to meet the Phase 1 schedule while meeting the 2010 standards for NOx and P . 

Retaining a separate engine standard and enhancing compliance enforcement will help ensure he 

long term environmental integrity of the program. 

AESI supports setting final Phase 2 greenhouse gas standards that will strongly 

encourage innovative companies to develop new technologies and systems that can help vehi le 

and engine makers to quickly, cost-effectively, and reliably reduce or eliminate carbon polluf n 

and still overperform on criteria pollutants. We appreciate the delicate balance that the agenc es 

must consider between setting an engine standard that appears feasible now versus setting a 

slightly more stringent technology-driving standard that will prompt faster evolution, more 

reductions and greater consumer savings in the long run. 

There appears to be ample evidence to indicate that Alternative 4's timeline comes cl sest 

to striking the right balance, though it does seem that greater reductions than the 4.2% target i 

the proposal could well be technically feasible and still quite cost-effective. There are now a 
multitude of technologies, including waste heat recovery, turbo-compounding, advanced 

downspeeding, hybridization, etc. that can be ready to deploy in that timeframe or sooner at s ll 

reasonable cost, provided the right policy or market signal or some combination of incentives r 

credits. The agencies may want to consider incentives or credits, particularly in an era of low fuel 

prices, to expedite the commercialization of these technologies and earlier and more costeffective achievement of the program goals. 

Our members have been working with the Department of Energy's Super Truck progr m 

to demonstrate the magnitude of carbon dioxide reductions that engine and vehicle technologi s 

can deliver while improving criteria pollution control systems. Through that program and the 

investment our companies are making with EPA and the California Air Resources Board at th 

Southwest Research Institute project, we are increasingly confident that there is a fuel 

economy/greenhouse gas optimization "bonus" that can be realized by integrating rapidly 

emerging and cost-effective NOx control strategies into heavy-duty manufacturers' engines a 

powertrain designs. There no longer needs to be the once evident tradeoff between engine 

efficiency and tailpipe NOx emissions. However, without clear policy signals, those NOx 

controls may languish and leave significant fuel economy gains on the table. 

California is seriously considering an additional 90% reduction in NOx emissions beYi nd 

the 2010 standards for medium and heavy duty vehicles. Should California, the Ozone Trans ort 

Commission states or EPA choose to adopt such a standard, AESI members will work with ou 

customers to ensure that that standard can be achieved and to realize the optimization "bonus" 

and make fuel economy/greenhouse gas targets easier to achieve. 

AESI supports the Agency's efforts to tighten the nitrous oxide (N20) cap to ensure th t 

efficiency enhancements made by engine manufacturers to reduce carbon dioxide pollution d not 

lead to unintended increases of this potent greenhouse gas. Meeting the proposed cap will be 

challenging, but our members are already working on the cutting edge materials necessary to 

limit N20 formation. 

Finally, though the agencies' proposal does not seek to place limits on the large vol~ 

of black carbon emissions from heavy-duty engines, it is worth noting that the global warrni~

potential of this pollutant is very significant, as high as 4,470 times that of carbon dioxide. T 

Agency may want to consider incentives in this rule or another for the rapid installation of 

particulate filters on any vehicles/engines not already using them, as the filters can remove 99 % 

of black carbon from exhaust streams. 

Thank you for the opportunity to provide comments today. We will supplement these 

remarks with additional written material before the end of the comment period.