August 2015 

Before the 

U.S. Environmental Protection Agency 

and 

National Highway Traffic Safety Administration 

on the matter of 

Phase 2 Proposed GHG Rules for Medium and Heavy-Duty Trucks 

Dockets: EPA-HQ-OAR-2014-0827 and NHTSA-2014-0132 

The Diesel Technology Forum represents the leaders in clean diesel technology including engine, vehicle and 

equipment manufacturers and affiliated organizations. We appreciate the opportunity to provide these 

comments on the proposed rules for reducing greenhouse gas emissions from medium and heavy-duty trucks. 

(More information about the Diesel Technology Forum is available at www.dieselforum.org.) 

Today, manufacturers of commercial trucks, engines and their components produce the cleanest, safest and 

most fuel efficient technology in the world. For all parties, the challenge of further increasing fuel efficiency 

while maintaining or improving environmental, safety and productivity of commercial vehicles is as important 

as it is complex. 

Diesel engines are the prime mover of the global economy and the primary power plant for the wide range of 

commercial trucks. We hope that the outcome of these proceedings sets the stage to build on the success 

already accomplished in achieving near-zero emissions with today's new clean diesel technology, with 

continued innovation in technology and products that are highly desired by customers. 

When finalized these rules will join the Clean Power Plan, light -duty vehicle and efficiency standards as the 

third key component of the Administration's climate change plan and contribute a substantial amount toward 

the greenhouse gas emissions reduction commitments to the international climate convention. 

The Diesel Technology Forum will not be taking a formal position on the specific aspects of the proposed rule. 

We believe that individual manufacturers and suppliers are best suited to provide these perspectives. We 

would like to focus our comments on three areas: 

• The role of diesel engines in commercial vehicles, the transformation to clean diesel 

technology; 

• The clean air, fuel saving and other benefits accruing from new technology clean diesel 

engines; and 

• A framework for continued success. 

1. NEW CLEAN DIESEL TECHNOLOGY Will CONTRIBUTE TO FURTHER EFFICIENCY GAINS AND CONTINUE TO 

BE THE PRIMARY POWERTRAIN FOR COMMERCIAL VEHICLES. 

More than 95 percent of all heavy-duty trucks on the road today are diesel-powered as are a majority of 

medium-duty trucks. Advances in diesel engine technology will continue to contribute to the overall efficiency 

gains of vehicles under the proposed rule, and as a result we expect diesel technology to remain the primary 

power-plant for commercial trucks into the foreseeable future. Diesel will continue to be the technology of 
Statement of the Diesel Technology Forum August 2015 Page 2 

choice because it offers an unmatched combination of power, increasing energy efficiency, work capability, 

reliability and now near-zero emissions environmental performance, along with an ability to utilize a variety of 

low-carbon renewable diesel fuels. 

Since 2000, the leaders in clean diesel technology and the EPA worked together in establishing a regulatory 

pathway that brought about the introduction of an entire new generation of clean diesel engines for both onand off-road applications. Manufacturers have met the challenge to virtually eliminate both NOx and 

particulate emissions from diesel engines, reducing emissions by as much as 98 percent from previous levels. 

These new technology clean diesel engines are being widely embraced by customers as evidenced by the 

increasing penetration into the vehicle population. According to state vehicle registration data for 2014, of the 

More dian 37% an~ 

near zero for 

particalltt -ions 

120117-lor• 

fJ!tJdll-1 

2:2% are near zero for 

both particulllt tDittel 

antlnilnlgen oxtdts 

enissi12!J70Mid~.tterl'fltldll.-t 

1rs no SUfl)lise the "''1011's trud<ing 

Heet Is mowtng to the ftiXI 

geomt>oa of cit .. tllwtl 

60® '- -

,JIP~§~!: www.dieselforurn.org/CieanDieseiTrucking 
Statement of the Diesel Technology Forum August 2015 Page 3 

roughly 9.2 million Class 3-8 heavy-duty vehicles on the road nationwide, about 38 percent, or 3.4 million 

vehicles are deployed with a 2007 or newer model year engine. Of these, 20 percent or roughly 1.9 million 

vehicles on the road meet the 2010 emissions milestone that requires near zero levels of both particulate 

matter and nitrogen oxide emissions. 1 

Last year (2014) was a very strong year for new truck sales across the industry, with over 186,000 new mediumduty trucks sold (Class 4-7) along with over 230,000 heavy-duty (Class 8) trucks sold. The overwhelming 

majority of these vehicles are powered by clean diesel technology with just a few thousand units powered by 

other fuels. 

According to the Fuels Institute, as of 2013, diesel represents about 98 percent of the engines founds in 

medium and heavy-duty vehicles including those that are covered by the proposed rule. By 2023, the Fuels 

Institute estimates that diesel engines will power between 95 and 97 percent of these vehicles despite the 

introduction of alternative fuels and powertrains including all-electric, fuel cell and continued introduction of 

natural gas powered vehicles. 

2. CLIMATE, FUEL SAVINGS AND CLEAN AIR BENEFITS FROM NEW TECHNOLOGY DIESEL ENGINES IN 

COMMERCIAL TRUCKS IN OPERATION TODAY ARE SIGNIFICANT AND GROWING 

New diesel technology on the road today is delivering real world benefits in the form of fuel savings and 

reducing carbon emissions. According to research commissioned by the Diesel Technology Forum, between 

2010 and 2014, technologies developed to meet strict emissions standards beginning for model year 2010 

engines have generated substantial fuel savings and emission reductions. 

• 9 million tons of C02 

• 880 million gallons of diesel 

• 21.0 million barrels of crude oil 

• 1.45 million tons of NOx 

• 

• 

The carbon emissions generated 

annually from 2.4 coal-fired power 

plants 

The NOx emissions generated 

annually from 158 coal-fired power 

plants 

Now 18 months into the first ever fuel economy and greenhouse gas reduction rules for these medium and 

heavy-duty vehicles- the so called Phase 1 rules- are expected to save 530 million barrels of crude oil and 

eliminate 270 million tons of carbon emissions between 2014 and 2018 according to EPA and NHTSA. In this 

population of vehicles, diesel is the predominant powertrain found in about 98 percent of trucks. Industry 

estimates have diesel maintaining over 90 percent of this market over the lifetime of the rule. 

a. Vehicle Technologies Will Be Critical to Meet Proposed Phase 2 Benefits 

Class 7 and 8 vehicles that today consume about 70 percent of all the fuel used in the medium and heavy-duty 

fleet, are expected to achieve a 24 percent improvement in fuel economy and reduction in carbon emissions 

through the lifet ime of the proposed rule relative to the existing Phase 1 standard. Consideration of the Phase 

1 http://www .dieselforum.org/index.cfm ?objectld=090207DS-Q 1F9-ll E4-91 B7000C296BA163 
Statement of the Diesel Technology Forum August 2015 Page 4 

2 proposal will include a suite of technologies from advanced engine designs to lightweight and more 

aerodynamic materials, innovative and adaptive cruise controls, next generation transmission designs and 

safety features and many more. All of these technologies build on the continued gains in diesel engine 

efficiency to consume even less fuel and help to quickly achieve greater fuel savings and greenhouse gas 

reductions. 

Technologies envisioned to meet these proposed Phase 2 standards may deliver significant additional fuel 

economy benefits and greenhouse gas emission reductions on the order of 1.8 billion barrels of crude oil saved 

and 1 billion tons of carbon emissions eliminated. Unlike Phase 1, where many technologies were already 

commercially available and proven, in order to achieve the ambitious goals outlined in Phase 2, EPA and NHTSA 

should proceed with caution in that they have incorporated reliance on adoption of technologies that may not 

currently be widely tested, proven or commercially available. 

b. Advanced Renewable Biofuels Offer Significant Reductions in Greenhouse Gas Emissions 

While this proposed rule focuses on vehicle and engine standards, in the context of efficiency and reducing 

greenhouse gas emissions, we believe that it is important to also note the benefits from changes to fuels. The 

diesel platform is most unique in its ability to operate on a wide range of renewable low-carbon biofuels. 

Today, most heavy-duty diesel engines are approved to operate on blends of biodiesel up to 20 percent. 

Renewable diesel fuels made from renewable bio-feedstocks are now also commercially available. These 

"drop-in" replacement fuels couple even greater carbon reduction with further emission reduction. Studies by 

the California Air Resources Board indicate that such fuels can reduce by 70 percent the greenhouse gas 

emissions over conventional diesel fuel. 

Recently, the City of San Francisco announced that renewable diesel fuel will power all city owned diesel 

vehicles and equipment by years' end.2 Still yet, UPS, the world's largest package delivery service, recently 

announced that it plans to consume 46 million gallons of renewable diesel fuel over the next three years.3 

c. Expand Efficiency Consideration Beyond New Engine and Vehicle Standards 

There are also significant opportunities for efficiency improvements through adoption of other policies that 

impact vehicle operations and in turn fuel use and emissions, and these should be an increasing part of policy 

consideration. For example, heavy-duty trucks and passenger vehicles are estimated to have wasted 2.9 billion 

gallons of fuel due to traffic congestion. Efforts to better maintain and modernize freight-related 

transportation infrastructure will also contribute to fuel savings alongside the latest truck technologies. 

d. California Clean Diesel Adoption and Benefits 

With one of the largest medium and heavy-duty fleets in the country, California stands to benefit the most 

from these proposed Phase 2 rules. Already, model year 2010 and newer engines that are found in Class 3-8 

2 http://www.sfmayor.org/index.aspx?page=846&recordid=919&returnURL=%2findex.aspx 3 http://www.nynmes.com/2015/07 / 30/ business/ups·agrees-to-buy-46-milllon-gallons-of-renewabledlesel.html? r=l 
Statement of the Diesel Technology Forum August 2015 Page 5 

vehicles in the state have eliminated 120,000 tons of NOx and 580,000 tons of carbon dioxide and saved 1.4 

billion barrels of crude oil between 2010 and 2014, according to our most recent research. 

According to the Air Resources Board, the further adoption of new and newer diesel engines in heavy-duty 

applications in California is expected to reduce emissions of oxides of nitrogen by fifty percent between 2012 

and 2020. 

3. FRAMEWORK FOR CONTINUED SUCCESS SHOULD INCLUDE APPROPRIATE TIMEFRAMES, UNIFORMITY 

AND HARMONIZATION 

Based on the industry experience over the last decade-plus in meeting the clean diesel milestones as well as 

that for Phase 1 greenhouse gas rules, there are a number of key contributors to the success enjoyed so far. 

We believe these are also important considerations for EPA in developing a final Phase 2 rules, as follows : 

o This must be a national program uniform to all SO states including California: National uniformity 

is essential for many reasons relative to the overall feasibility, implementation, cost and 

acceptance of the program and vehicles produced as a result of the proposed changes. 

o The program must be fuel neutral in nature: Through the adoption of emissions standards, testing 

procedures and other provisions, the proposed rule must ensure that one fuel or technology is not 

directly or indirectly favored over others, for any of the categories of vehicles covered. 

Manufacturers and their customers are best suited to select the technology that makes the most 

sense for their specific needs. 

o That ample lead time and stability are provided: This is important because the number of 

commercial trucks made and sold each year (several hundred thousand) is a tiny fraction of the 11-

17 million cars made. The significant diversity in the marketplace will require many hundreds if not 

thousands of different approaches depending on the type of vehicle. Manufacturers must have 

adequate lead time to make changes in technology for this diverse vehicle population along with 

regulatory stabi lity so that they can recoup their investments over the longer sales and turnover 

cycles common in this segment. 

o That this rule is compatible with the needs and complexities of the diverse marketplace: 

Commercial trucks encompass a wide range of types, shape and sizes with primary and secondary 

manufacturers of commercial vehicles, along with many vehicles customized to meet the needs of 

a broad range of specific work tasks. Efforts to impose fuel economy standards should not affect 

vehicle choice or such efforts could have unintended consequences of causing shifts in the 

marketplace to less productive and more vehicles on the road. 

o That it is mindful of the other requirements placed on industry relative to environmental and 

safety requirements of commercial vehicles: Unlike passenger cars, commercial trucks must 

adhere to a number of additional federal and state safety and operational requirements. 

Provisions that impact fuel economy must not compromise safety or utility of the vehicle. 
Statement of the Diesel Technology Forum August 2015 Page 6 

o The standards must be harmonized to the greatest extent possible: Both the EPA, NHTSA and the 

California Air Resources Board have various components in this final rule creating multiple 

obligations for manufacturers. Harmonizing between the three agencies would simplify and 

streamline and likely contribute to a chance for greater success. 

o The program must consider the longstanding trade-off between NOx and C02: The rule should 

avoid driving technologies that realize gains in fuel efficiency at the expense of NOx, reversing the 

huge achievements of clean diesel technology in recent years and limiting the potential for further 

reductions in the future 

4. SUMMARY 

These proposed rules -if successfully enacted- will be an important building block of the Administration's 

Climate Action Plan that seeks to reduce overall greenhouse gas emissions between 26 and 28 percent by 2025 

relative to 2005 and also forms the basis of the climate. commitment the Administration announced as part of 

the United Nations' Framework Convention on Climate Change. 

The proposed Phase 2 rules would join the Phase 1 rule, existing fuel economy standards for light-duty vehicles 

and the recently announced final carbon emission rules for electricity generation through the Clean Power 

Rule, as major contributors to achieve these substantial carbon emission reductions. 

Regulations for TransE!ortation Sector ~nticioated Carbon Reduction Benefit 

Final Fuel Economy Rules for Passenger Vehicles (2012-2025) 6,000 million tons 

Final Phase 1 Rules for Heavy-Duty Vehicles (2014-2018) 270 million tons 

Proposed Phase 2 Rules for Heavy-Duty Vehicles (2014-2018) 1,000 million tons 

Advanced truck and engine designs that reduce emissions provide significant fuel savings for their owners and 

clean air benefits for everyone. 

Now achieving near zero emissions, clean diesel technology powers the overwhelming majority of medium and 

commercial trucks today and thanks to these improvements, is poised to continue as the prime powertrain 

technology for commercial vehicles in the future. 

The engine may look and perform somewhat differently, and may be burning different kinds of low carbon 

fuels, but in the end it will still be a diesel engine and an integral component of meeting the needs of a growing 

economy and a cleaner and more sustainable future. 

Contact Information: 

Allen Schaeffer- Executive Director, aschaeffer@dieselforum.org 

Ezra Finkin, Director of Policy, efinkin@dieselforum.org 

301-668-7230 
_..I DIESEL TECHNOLOGY FORUM 

(View t his press release online here.) 

August 6, 2015 

Contact: 

Steve Hansen 

shansen@dieselforum.org 

301-668-7230 (o) 

202-355-3664 (c) 

Clean Diesel Power Key Part of Achieving Future Truck Efficiency Gains, 

EPA Officials Told 

Chicago, ll-The success in reaching the first phase of greenhouse gas and fuel efficiency standards for 

heavy-duty vehicles and the new complex challenges facing truck and engine manufacturers in achieving the 

proposed second phase of regulations were outlined today during a rulemaking hearing conducted by 

Environmental Protection Agency {EPA) and National Highway Traffic Safety Administration {NHTSA) officials. 

Allen Schaeffer, the Executive Director of the Diesel Technology Forum, testified at the Chicago hearing on 

behalf of the diesel industry. Witnesses included environmental, health, industry and science representatives 

during the first of two national hearings on the Proposed Rulemaking to adopt Phase 2 of national greenhouse gas 

emission reduction and fuel efficiency requirements for medium and heavy duty trucks. The second hearing is 

scheduled for August 181

h in los Angeles. 

"Today, manufacturers of commercial trucks, engines and their components produce the cleanest, safest 

and most fuel efficient technology in the world, and over 95 percent of those vehicles are powered by diesel 

engines. Advances in diesel engine technology will continue to contribute to the overall efficiency gains of 

vehicles under this proposed rule. As a result we expect diesel technology to remain the primary power-plant for 

commercial trucks into the foreseeable future," Schaeffer said. 

"For all parties, the challenge of further increasing fuel efficiency while maintaining or improving 

environmental, safety and productivity of commercial vehicles is as important as it is complex. To be successful, 

the final outcome here must build on the success already accomplished in achieving near-zero emissions with 

today's new clean diesel technology, and drive continued innovation while ensuring that the end products are 

highly desired by customers." 

"When finalized these rules will join the Clean Power Plan, light-duty vehicle efficiency standards as the 

third key component of the Administration's climate change plan and are expected to contribute substantial 

greenhouse gas emission reductions while helping to advance commitments to the international climate 

convention." 

New Diesel Technology Greenhouse Gas Benefits Already Accruing 

"In light of the Clean Power Plan announcement earlier this week, we thought it was important to note 

that new technology clean diesel trucks on the road between 2010-2014 have already reduced annual carbon 

emissions by about the same amount as 2.4 coal-fired power plants, and NOx emissions equivalent to the 

equivalent of 158 coal-fired power plants," Schaeffer said. 

Over 95% of All Heavy Duty Trucks in U.S. Are Diesel-Powered 

Schaeffer explained that diesel will continue to be the technology of choice because it offers an 

unmatched combination of power, increasing energy efficiency, work capability, reliability and now near-zero 

emissions environmental performance, along wit h an ability to utilize a variety of low-carbon renewable diesel 

fuels. 

Schaeffer said that since 2000, the leaders in clean diesel technology and the EPA have worked 

cooperatively in establishing a regulatory pathway that brought about the introduction of an entire new 

generation of clean diesel engines for both on- and off-road applications. 

"Manufacturers have met the challenge to virtually eliminate both NOx and particulate emissions from 

diesel engines, reducing emissions by as much as 98 percent from previous levels," Schaeffer said. "These new 

technology clean diesel engines are being widely embraced by customers as evidenced by the increasing 

penetration into the vehicle population." 

According to state vehicle registration data for 2014, of the roughly 9.2 million Class 3-8 heavy-duty 

vehicles on the road nat ionwide, about 38 percent, or 3.4 million vehicles are deployed with a 2007 or newer 

model year engine. Of t hese, 20 percent or roughly 1.9 million vehicles on the road meet the 2010 emissions 

milestone that requires near zero levels of both particulate matter and nitrogen oxide emissions, Schaeffer said. 

According to the Fuels Institute, by 2023 diesel engines wi ll power between 95 and 97 percent of all 

medium and heavy duty vehicles despite the introduction of alternative fuels and powertrains, including allelectric, fuel cell and continued introduction of natural gas powered vehicles. 

Important Factors Must Be Considered In Final Phase 2 Rules 

As EPA works to develop the final Phase 2 rules, Schaeffer said it is important that the rule must be a 

national program uniform to all 50 states including California; remain fuel neutral in nature; provide ample lead 

time and stability; be compatible with the needs and complexities of the diverse marketplace; be mindful of the 

other requirements placed on industry relative to environmental and safety requirements of commercial vehicles; 

harmonize standards to the greatest extent possible, and carefully consider the longstanding trade-off between 

NOx and C02. 

"Now achieving near zero emissions, clean diesel technology powers the overwhelming majority of 

medium and commercial trucks today and thanks to these improvements is poised to continue as t he prime 

powertrain technology for commercial vehicles in the future," Schaeffer said. "The engine may look and perform 

somewhat differently, and may be burning different kinds of low carbon fuels. But in the end, it will still be a 

diesel engine and an integral component of meeting the needs of a growing economy and a cleaner and more 

sustainable future." 

Connect with DTF For the latest insights and information from the leaders in clean diesel technology, 

join us on Facebook, follow us on Twitter @DieseiTechForum, or YouTube @DieseiTechForum and 

connect with us on linkedln. 

ABOUT THE DIESEL TECHNOLOGY FORUM 

The Diesel Technology Forum is a non-profit organization dedicated to raising awareness about 

the importance of diesel engines, fuel and technology. Forum members are leaders in clean diesel 

technology and represent the three key elements of the modern clean-diesel system: advanced 

engines, vehicles and equipment, cleaner diesel fuel and emissions-control systems. For more 

information visit www.dieselforum.org. 

# # #