### Public Hearing for Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles-Phase 2 Long Beach, California August 18, 2015 TESTIMONY OF CUMMINS INC. Thank you for the opportunity to testify on the proposal to establish the second phase of greenhouse gas (GHG) and fuel efficiency standards for medium- and heavy-duty engines and vehicles. My name is Brian Mormino, and I am the Executive Director of Worldwide Environmenta l Strategy & Compliance for Cummins Inc. Cummins thanks EPA and NHTSA for leading an open and collaborative process to develop the Phase 

### 2 proposal. As the world's largest independent engine manufacturer, we have a long history of working together with the Agencies, our customers and other stakeholders with the aim of bringing cleaner, more efficient, reliable products to the market. We appreciate the opportunity over the past 3.5 years to provide extensive policy and technical input to the Agencies and to work closely with a wide range of stakeholders including the Heavy-Duty Fuel Efficiency Leadership Group- which is comprised ofCon -Way, Eaton, FedEx, PepsiCo, Wabash National and Waste Management - to inform the rulemaking process across our broad range of common interests. It is in that spirit of collaboration that I speak today on key aspects of the proposed rule. Cummins supports the goals of the Phase 

### 2 proposal to reduce GHG emissions and fuel consumption. We recognize the threat of climate change and the need for all sectors of the economy to play a role. This is also an area where our customer interests are directly aligned since lower carbon dioxide (C02 ) emissions from heavy-duty engines and vehicles means fuel savings for them. The proposed regulatory structure of separate engine and vehicle standa rds delivers on these important economic and environmental benefits. As outlined in the Preamble of the proposal, a sepa rate engine standard offers a robust, clearly defined compliance program, requires manufacturers to optimize C02 and criteria pollutants together and provides the only measure of engine fuel consumption and C02 emissions under transient conditions. Also in the Preamble, the Agencies declare these and other advantages of separate engine standards as "fundamental to the success of the program." Cummins wholeheartedly agrees, and as you heard in Chicago and will hear today, so do many others. Although the Phase 1 regulatory structure of separate engine and vehicle s tandards is retained for Phase 

### 2, a change in how the engine ischaracterized in the Greenhouse Gas Emissions Model (GEM) drives more interaction between the engine and vehicle programs. The Phase 

### 2 proposal requires engine manufacturers to both certify a steady-state engine fu el map and provide the fuel map to vehicle manufacturers for use in the GEM vehicle certification process. This approach is very concern ing because it requires Cummins to release proprietary and confidential business information into the public domain. Additionally, the steady-state fuel map is unable to accurately represent engine performance today, and it is likely to be even less accurate in the future. Cummins urges the Agencies to pursue the alternative "cycle average map" approach as described in the Draft Regulatory Impact Analysis. The cycle average map process is being eva luated by EPA and our industry, and it is demonstrating prom ising results for accurately representing engine performance in GEM, especially in t ransient operation. Additional testing and ana lysis is planned, and Cummins is comm itted to continued support of

### these efforts. We urge the Agencies to finalize the cycle average map approach not only for generating a powertrain map as proposed but also as the method of characterizing the engine in GEM. Another area of concern related to interactions between the engine and vehicle standards has to do with "implied" engine stringency. It appears additional engine C02 reduction beyond the explicit engine standards is assumed in the vehicle standards, for example, associated with engine downspeeding. Cummins cautions the Agencies against this approach

. First, implicit engine s tringency in the vehicl e program decouples engine C02 

### improvements from compliance with standards for oxides of nitrogen {NOx). This threatens the regulatory integrity of the rule by creating a structure in which in-use NOx emissions can be increased by operation outside expected NOx regulatory limits while in-use C02 emissions are reduced. Second, it allows trading of directly measurable and enforceable improvements at the engine level for less certain and unenforceable improvements at the vehicle level. Third, implied standards lack the regulatory clarity required for focused and sustained innovation in engine technology. For these reasons, required engine C02 reductions should be explicit in the engine standard, and engine procedures should continue to link C02 with criteria pollutants. As we consider the explicit levels of the proposed engine standards, our ability to comply is informed by our experience with SuperTruck, a Cummins-Peterbilt project in partnership with the Department of Energy. In 2014, SuperTruck averaged a 75 percent increase in fuel economy, a 43 percent reduction in GHG emissions and an 86 percent gain in freight efficiency in 24-hour, head-to-head testing against a 2009 baseline truck. 40 percent of this fuel economy improvement derives from engine advancements and innovations which will be making their way into production engines over the timeframe of this rule. As a result of SuperTruck and our own internal technology development programs, Cummins is confident we have the engine technologies necessary to meet or exceed improvements required by the Phase 2 engine standards. In fact, we expect our customers will demand even more improvement than the standards, and we are prepared to meet their demands with cost-effective and reliable products. Lead time and stability are also critical to achieving the goals of the proposal. EPA and NHTSA have proposed three steps of standards for engines and vehicles- in 2021, 2024 and 2027. Cummins supports retaining this timeline for the Final Rule. The long-term certa inty of knowing the required reductions through 2027 benefits component suppliers and manufacturers who need to invest and develop and validate reliable fuel -saving technologies and the end users who will ultimately depend on them in the market. Finally, Cummins supports a consistent, national program. One deviation from this area in the proposed rule is different standards for diesel and gasoline engines. The Agencies should move to C0 2 

### standards that are the same for all fuels, or "fuel neutral," because it is necessary to ensure reductions are achieved regardless of the fuel or technology used. It is also critical that EPA, NHTSA and the California Air Resources Board (ARB) are al l aligned in addressing fuel efficiency and C02as well as NOx. ARB has stated their need for further NOx reductions in California to meet federal ambient air standards and their desire for lower heavy-duty NOx requirements nationally as part of the State's plan to meet this challenge

. EPA and ARB should work collaboratively with the goal of maintaining a national, heavy-duty NOx and GHG program. Cummins is committed to working with both Agencies to determine the best path for achieving real -world reductions.As many have noted, the Phase 2 proposal is complex, including new aspects related to the engine and its interactions with the rest of the vehicle. We sti ll have more work to do to fully understand it all, and we intend to submit detailed written comments based on our continuing review of th e proposal. Through the com ment period and beyond, Cummins will work with th e Agencies and other sta k eholders to make sure both the environment and our custome rs ben efit from th e Final Rule

. Thank you again for th e opportun ity to provide these comments and for leading such an open and collaborative process. I look forward to addressing any questions that you might have. lUlU