Comments of 

The BlueGreen Alliance on 

www. blueg ree n a IIi an ce. org 

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Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and 

Heavy-Duty Engines and Vehicles- Phase 2- Proposed Rules 

EPA- HQ-OAR- 2014-0827; NHTSA- 2014- 0132; FRL- 9931-48-0AR 

Long Beach, August 18, 2015 

Good afternoon, l' m Jorge H Rodriguez, Los Angeles Program Coordinator for the BlueGreen 

Alliance. Thank you for the opportunity to make comments on behalf of the BlueGreen Alliance on 

the U.S. Environmental Protection Agency (EPA) and the National Highway Traffic Safety 

Administration's (NHTSA) proposed phase 2 standards for medium- and heavy-duty vehicles. These 

standards will increase fuel efficiency and cut greenhouse gas emissions from long-haul trucksalong with full size pick-ups, other trucks, buses, and vocational vehicles. These standards can also 

continue America's auto and manufacturing resurgence. 

The BlueGreen Alliance is a national partnership of America's largest labor unions and 

environmental organizations. We work together to turn today's biggest environmental challenges 

into our biggest economic and job-creating opportunities. Together with 15 million members and 

supporters, we are a powerful, unified voice calling for good, family-sustaining jobs, a clean 

environment and a thriving and fair American economy. 

The BlueGreen Alliance and its 15 labor and environmental partners recognize the importance of the 

proposed medium- and heavy-duty truck fuel eaiciency and greenhouse gas emissions reduction 

rule. America's economy depends on leadership in building the next generation of clean globally 

competitive energy and vehicle technology. These new standards can provide a critical opportunity 

to sustain jobs, further reduce the pollution driving climate change and foreign oil dependence while 

enhancing the competitiveness ofU.S.-manufactured trucks in global markets. 
For the past decade, the auto industry (in the light, medium and heavy duty sectors), and American 

workers-represented by the United Auto Workers, the United Steelworkers and others-have been 

on the front lines when it comes to rebuilding manufacturing jobs and building the world-leading 

technology needed to achieve deep cuts in carbon pollution and save consumers billions at the pump. 

Soon to be released research carried out by several of our partners finds more than 380 plants that 

are manufacturing fuel efficient medium- or heavy-duty vehicles or their components today in states 

all across the country. These include more than 55 companies in California alone, and range from 

major assemblers, to companies making key subsystems to large and small manufacturers of 

components, trailers, tires, and the steel and aluminum that goes into them. Done right, this standard 

can spur investment, secure and grow jobs, and enhance U.S. competitiveness across these 

businesses and technologies- and the industry as a whole. 

U.S. Manufacturers of Fuel Efficient Medium- and 

Heavy-Duty Vehicles and Components 

Key 

- * Medium- and Hea-.y-Duty Vehicle Assemblers 

Data and mapping by Natural Resources Defense Council and the BlueGreen All/ana> • Major Component Manufacturers 

• Specialized Component Manufacturers 

We greatly appreciate the thorough and systematic process EPA and NHTSA have undertaken in 

developing this proposal. It is critical that an effective final rule works for the environment, for the 

economy, and for the thousands of hard-working American women and men in the heavy truck, 

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component and related industries. The auto industry and autoworkers have been at the forefront in 

proving that America can lead globally in combating climate change while rebuilding our 

manufacturing sector and creating and sustaining quality jobs. We urge the agencies to continue their 

thorough and deliberate process to ensure that the final truck rule will continue this trajectory. 

Together, the previous rounds of car and light-duty truck and medium- and heavy-duty truck 

standards achieve the largest greenhouse gas reductions ever undertaken in the U.S. and one of the 

largest globally. We thank EPA and NHTSA for their work to date and look forward to working with 

the agencies and all our partners to ensure that we keep on combating climate change by building 

great trucks. 

Thank you. 

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