EPA/DOT Hearing 

Phase 2 Greenhouse Gas Emissions Standards and Fuel Efficiency Standards for 

Medium- and Heavy-Duty Engines and Vehicles 

Chicago 

August 6 2015 

Thank you for the opportunity to comment on the proposed Phase 2 regulations. 

My name is Richard Stuckey. I am a retired partner with Accenture and a 

volunteer member of the Sierra Club, UCS and other environmental organizations, 

but I am speaking today on behalf of family, my friends and myself. 

First, I'd like to commend the EPA for the outstanding work you have done to 

implement regulations on the most important sources of climate changing 

pollution. They will improve the environment, the economy, our health, and help 

reduce our addiction to fossil fuels. It is particularly important that the US shows 

this leadership in addressing climate change in advance of the upcoming talks in 

Paris. 

I testified at the hearing on Phase 1 of the Heavy Vehicle regulations proposals in 

November 2010 and I want to endorse the rules contained in Phase 2 proposals. 

I live fairly close to major expressways. My daughter experienced breathing 

problems while living in Chicago. Particulate pollution from heavy duty trucks is a 
major contributor to our polluted air and the regulation you have proposed will let 

my daughter and others who suffer from air pollution breath better and live 

healthier lives. 

According to the ICCT1 heavy-duty trucks in the US make up just over So/o of 

vehicles on the road but generate more than 30°/o of carbon dioxide emissions 

from vehicles and are responsible for 36°/o of vehicle particulate emissions. 

The Phase 2 proposed rules will save 550,000 barrels of oil per day and 120 

Million Metric Tons of global warming pollution by 2035. Over the lifetime of the 

trucks covered by the rules over 1 Billion metric tons of global warming emissions 

will be avoided, equivalent to the emissions from all US homes for a year. 2 

Although the benefits from these regulations are great so are the problems they 

are intended to address, so it is essential to question whether the changes go far 

enough or are being implemented fast enough. 

Unfortunately, even with the proposed Phase 2 regulations, fuel usage from 

heavy-duty trucks is expected to increase and will exceed 2013 levels due to 

1 International Council on Clean Transportation. Policies to Reduce Fuel Consumption, Air 

Pollution , and Carbon Emissions from Vehicles in G20 Nations, May 2015. Fa<;anha, C., 

Blumberg, K. , Miller, J. (2012). Global transportation energy and climate roadmap. 

2 Union of Concerned Scientists. www.ucsusa.org/truck efficiency 
increasing numbers of vehicles on the road. Studies3 show that the technologies 

that are needed to achieve a 40°/o reduction in fuel consumption can be 

incorporated into new trucks by 2025 rather than 2027 and this will save an 

additional 200,00 barrels of oil per day in 2035 and avoid 40 MMT of global 

warming pollution annually. This is the equivalent of shutting down 12 coal-fired 

power plants. 

4 

I have a concern with the regulations relating to vocational vehicles. Unlike long 

distance haulers, vehicles like garbage trucks and buses spend large amounts of 

time standing with engines running. Often this is the only way that air conditioning 

can be provided for the drivers. Standards for miles per gallon are not effective in 

dealing with consumption and pollutions caused when the vehicles are stationary. 

Technologies such as auto start engines that cut off when vehicles are stationary, 

operation of air conditioners and hydraulic pumps without reliance on the main 

traction engines etc. could result in very large savings for these types of vehicles. 

I hope you will consider them in addition to miles per gallon targets to more 

accurately address the manner in which these vehicles are used. 

As the EPA did when it issued its final Clean Power Regulations recently, which 

made significant improvements over the original draft, I urge you to improve the 

3 ACEEE et al 2014 

4 EPA n.d. 
proposed draft to both accelerate the achievement of the savings and increase the 

saving goals. 

Thank you. 

Richard Stuckey 

1931 N. Fremont St 

Chicago, IL 60614