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 ofthe Sierra Club, UCS and other environmental organizations, but I am speaking today on behalf offamily, 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 ofthe upcoming talks in Paris. I testified at the hearing on Phase 1 ofthe 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 amajor 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 ofvehicle 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 ofthe trucks covered by the rules over 1 Bill ion 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 regu lations, 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 efficiencyincreasing numbers ofvehicles 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 ofglobal 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 ofvehicles. 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 ofthe savings and increase the saving goals. Thank you .

Richard Stuckey 1931 N . Fremont St Chicago, IL 60614