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 Med i um and Heavy-Duty Trucks Dockets: EPA-HQ-OAR-2014-0827 an d NHTSA-2014-0132 The Diesel Technology Forum represents the leaders in clean diesel te chno logy 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 m edium 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 i ncreasing fuel efficiency whi le maintaining or improving environmental, safety and productivity of comme rcial vehicles is as important as it is complex. Diesel engines are the prime mover of the gl obal economy and the primary power plant for the wide range of commercial trucks. We hope that the outcome of these proceedings set s the stage to build on the success already accomplished in achieving near-ze ro emissions with today's new clean diese l technology, with con tinued innovation in technology and products that are highly desired by customers. When f ina lized these rules will jo in the C lean Power Plan, light -duty vehicle and efficiency standards as the third key component of the Administration's climate change pl an and contribute a substantial amount toward the greenhouse gas emissions reduction commitments to the i nternational climate conven t ion. The Diesel Technology Forum will not be taking a formal position on the specific aspects of the proposed rule. We believe th at ind ividual manufacturers and supp liers are best suit ed to provide the se perspectives
. We would like to focus o ur commen t s on three areas : • The role of diesel eng ines in commerci al vehicles, the transformation to clean diesel technology; • The clean air, fuel saving and oth e r benefits accruing from new technology clean die se l 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 d iesel- powered as are a majority of medium-duty trucks. Advances in diesel engine techno logy will continue to contribute to the overall efficie ncy gains of vehicles under the proposed rule, and as a result we expect d iesel technology to remain the primary power-plant for commercial trucks into the foreseeable fu tu re. Diesel will continue to be the technology ofStatement 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 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. These new technology clean diesel engines are being widely embraced by customers as evidence d by the increasing penetration into the vehicle population. According to state vehicle registration data for 2014, of the

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**,JI P~§~!:**  www.di esel f orurn .org/CieanDieseiTruck ingStatemen t of the Di esel Techno l ogy Fo ru m August 2015 Page 3 roughly 9.2 million Class 3-8 heavy-d uty vehicles on the road nationwide, about 38 percent, or 3.4 mill ion 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 l evels of both particu l ate matter and nitrogen oxide emission s. 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 ove r 230,000 heavy-duty (Class 8) trucks sold
. The overwhelming majority of these vehicles are powered by clean d iesel 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 Fuel s 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
. CLIMA TE, FUEL SAVINGS AND CLEAN AIR BENEFI T

S FROM NEW TECHNOLO GY DIESEL ENGINES IN COMMERCIAL TRUCKS IN OPERATION TODAYARE SIGNIFICANT AND GROWING New diesel technology on the road today is delivering rea l world benefits in the form of fuel savings and reducing carbon emissions. Accord ing to research commissioned by the Di esel Technology Forum, between 2010 and 2014, technolog i es 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 mi ll ion tons of NOx 

## •


# • The carbon emissions generated annually from 2
.4 c oal -fi red pow e r p l ants The NOx emissions generated annually from 1 58 coa l -fired powe r pl ants 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 r ules- are expected to save 530 mi ll ion 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. Ve h i cl e Technol og i es Will Be Criti ca l to M eet 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 exi sting Phase 1 standard. Consideration of the Phase
1 http://www.dieselforum.org/index.cfm ?objectld=090207DS-Q 1F9-llE4-91 B7000C296BA163Statement 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, innovat ive and ad apt ive cruise controls, next generation transmission designs and safety features and many more. All of these technologies build on the continued gai ns in di esel eng ine efficiency to consume even less fuel and help to quickly achieve greater fuel savings and greenhouse gas reductions. Technologies envisioned to meet these pro posed Ph ase 2 standards may deliver signif ica nt additiona l f uel 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 P hase 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 ca ut ion in that th ey have inco rporated reliance on adoption of technologies that may not currently be widely tested, proven or commercially ava i lable. b
. Advanced R e newa bl e Biofue l s Offer Significant Reduction s i n Greenhou se Gas Emi ssio ns Whil e th is proposed rule focu ses on vehicle and engine standards, in the context of efficiency and reducing greenhouse gas emissions, we believe that it is im portant 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 pe rce nt. Ren ewabl e diese l fuels made f rom renewa b le bio-feedstocks are now also commerci a lly available. These "drop-in" replacement fuels couple even greater carbon reduction with further emission reduction. Stud ies 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 announ ced that renewable diesel fuel will power all city owned d iesel vehicles and equipment by years' end. 2 Sti ll yet, UPS, the world's largest package delivery service, recently announced that it plans to consume 46 million ga llons 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 operat ions and in turn fuel use and emissions, and these should be an increasing part of policy consideration. For example, heavy-d uty trucks and passenger vehicles are estimated to have wasted 2.9 billion gallon s of fuel due to traffic congestion
. Efforts to better maintain and modernize freight- related tran sportation infrastructure will also contribute to fuel savings alongside the latest truck technologies. d
. California Clean Di ese l Adoption and Benefits W ith one of the largest medi um 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=lStatement of the Diesel Technology Forum August 2015 Page 5 vehicles in the state have elimi nated 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 di esel engines in heavy-duty applications i n California i s 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 succes s enjoyed so far. We believe these are also important considerations for EPA in developing a final Phase 2 rules, as follows : o Thi s mu s t be a national prog ram uniform to a ll SO s tates incl uding C alifo rnia : National uniformity is essentia l 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 Th e program must be fu e l neutral i n nature: Through the adoption of emissions stan dards, 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 cat egories of vehicles covered. Manufacturers and the ir customers are best suited to select the technology that makes the most sense for th eir specific needs. o That a mpl e lead time and s tability are provided : This is important because th e 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 techno logy 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 thi s rul e is compatible with the needs and co mplexities 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 in du s try relative to environmental and safety require me nts of co mmercia l 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 Th e sta ndard s must b e h armonized to the greatest extent possible: Both the EPA, NHTSA and the California Air Resources Board have various components in th is 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 Th e program must consider the longs tand i ng 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 techno l ogy in recent years and limiting the potentia l 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 ru le, 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. R

eg ulations for TransE!ortation Sector

**~nticioated** Carbon Reduction Benefit Final Fuel Economy Rules for Passenger Vehicles 

### (2012-2025) 6,000 million tons Final Pha se 

### 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 tru ck and engin e 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 tru cks today and thanks to these improvements, is poised to con t inue 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 In formation: Allen Schaeffer- Executive Director, aschaeffer@dieselforum.org Ezra Finkin, Director of Policy, efinkin@dieselforum.org 

### 301-668

-7230

# DIESEL _..I TECHNOLOGY FORUM

(V iew t h is press re l ease o nlin e here .) A u g u st 6, 2015 Contact : 

### Steve Han se n 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 n ew complex challenges facing t ru ck 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. All en Schaeffer, the Executive Director of the Diesel Technology Forum , testified at the Chicago hearing on behalf of the diesel industry. Witnesses includ ed envi ronm enta l, health , industry and science rep re sentatives 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 181h 

### in los Angeles. "Today, manufacturers of comme rcial 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 rul e. As a result we expect diesel technology to remain the primary power-plant fo r commerc i al trucks into the foreseeable future," Schaeffer said.

" For all parties, the challenge of further increasing fuel efficien cy while maintaining or improving environmental, safety and productivity of commercial vehicles is as important as it is complex. To be successful, the fin al outcome here must build on t h e success already accomplished in achievi ng 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 comp onen t of the Admini stratio n's climate change plan and are exp ected to contrib ute substantial greenhouse gas emission reductions while helping to advance commitments to the international climate convention. " N ew Di ese l Techn ology Greenhou se Gas Benefits Alrea dy Accrui ng "In light of the Clean Power Plan anno un ceme nt earlier t hi s week, we thought it was importan t 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. Ove r 95% of All Heavy Duty Tru cks i n U .S. A re Diesel-Pow e red 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 perfo rmance, along wit h an ability to utilize a variety o f l ow-ca rbo n 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," Schaeffe r said. "These new technology clean d iesel engines are being wid e ly emb raced by customers as evide n ced by the increasing penetration into the vehic le popu l at ion." Accordi ng to state ve hi cle regist ratio n data fo r 2014, of t h e rough ly 9.2 m ill io n Cl ass 3-8 heavy-duty veh icles on th e road nat io nwid e, abou t 38 percen t, or 3 .4 m i ll io n vehic l es are depl oyed with a 2007 or new e r mode l year e ng in e. Of t hese, 20 pe rce nt o r rou g hly 1.9 m ill io n vehi cl es o n th e roa d meet th e 2010 emi ssio n s m il estone that requires near zero l evel s of both parti cula te matter and ni trogen oxi d e emiss i ons, S ch aeffer said. Acco rding to the Fuels I nstit ute , by 2023 diesel engines wi ll power between 95 and 97 pe rcent of all medium and heavy duty vehicles despite t h e introductio n of alternative fue ls and powertrains, includi ng allelectric, fuel cell and continued introduction of natural gas powe red vehicles. Important Factors Must Be Considered In Final Pha se 2 

### Rules As EPA works to develop the final Phase 2 rules, Schaeffer said it is important that the rul e must be a national program unifo rm to all 50 states including Cal ifornia; remain fuel neutral in nature; provide ample lead time and stability; be compatible with the needs and complexities of the diverse marketplace; be mindfu l of the other requirements placed on industry relative to environmenta l 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 emissio ns, clean diesel techno l ogy powe rs t h e ove rwhelming majority of medium and commercia l trucks today and th anks to t h ese imp rovements i s poised to co ntin ue as t he prime powertrain techno l ogy for comme rci al ve hicle s i n the fut ure," Sc haeffer sa i d. "Th e eng in e m ay look an d perfo rm somewhat diffe rent ly, and may be burn i ng different kin ds of low ca rb on fue ls. But in th e end , it w ill sti ll be a d i ese l engine and an in teg ral compo nent of meetin g t he nee ds of a grow ing eco nom y and a cl eaner and more sustainable future." 

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. 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 ofthe modern clean-diesel system: advanced engines , vehicles and equipment, cleaner dieselfuel and emissions-control systems. For more information visit www. dieselforum
. org. # # #