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 Environmental 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 of Con-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 standards delivers on these important economic and environmental benefits. 

As outlined in the Preamble of the proposal, a separate 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 standards is retained for Phase 

2, a change in how the engine is characterized 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 fuel map and provide the fuel map to vehicle 

manufacturers for use in the GEM vehicle certification process. This approach is very concerning 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 evaluated by EPA and our industry, and it is demonstrating 

promising results for accurately representing engine performance in GEM, especially in transient 

operation. Additional testing and analysis is planned, and Cummins is committed 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 stringency in the vehicle 

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 certainty 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 C02 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 C02 as 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 the proposal. Through the 

comment period and beyond, Cummins will work with the Agencies and other stakeholders to make sure 

both the environment and our customers benefit from the Final Rule. 

Thank you again for the opportunity 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