EPA I f\} HTS A 

Good morning. My name is Matthew Rudni ck and I am the Manager for Global Fuel 

Economy and Greenhouse Gas Policy at General Motors. 

I am pleased to speak with you today regarding the EPA and NHTSA Notice of Proposed 

Rulemaking to address greenhouse gas and fuel efficiency for medium and heavy-duty 

trucks. 

General Motors is a major manufacturer of these vehicles, and we want to thank NHTSA 

and EPA for providing the opportunity to comment on this regulation. We have been 

working closely with both agencies, and will continue to do so in order to establish 

standards for this integral part of the American economy. GM supports the adoption of a 

national standard covering these vehicles, and it is paramount that it be consistent with 

some critical and foundational principles: 

First, it is imperative for NHTSA and EPA to develop a harmonized approach that does 

not penalize both consumers and manufacturers in providing products that continue to 

serve the purposes, functions and utility that are needed. General Motors is supportive of 

the approach used during Phase 1 of this initiative, and encourages the continued 

harmonization of CAFE and GHG regulations. By creating one national standard, we can 

best maximize resources to produce clean and efficient vehicles which better align with 

the emission reduction standards put in place. 
Second, the program must continue to recognize the unique functionality and utility 

needs of the trucking industry, and that we provide vehicles that preserve the 

performance integrity of these work trucks. Consumers value the payload and towing 

capabilities these working vehicles offe r. and the '·work factor based" standards set by 

EPA and NHTSA should continue to align with the industry and business needs of this 

demographic. 

Third, we have been gaining valuable experience concerning the importance of flexibility 

mechanisms contained in the light duty vehicle greenhouse gas and fuel economy 

regulations - and these lessons can be applied to the medium and heavy duty fleets. For 

example, the pre-defined and pre-approved list of mobile air conditioner greenhouse gas 

credits has incentivized rapid improvements in the efficiency and leak integrity of light 

duty vehicle air conditioners. These incentives are now paving the way for an early 

transition to lower global warming air conditioner refrigerants, as mi ll ions of new 

vehicles are being produced with the new refrigerants - many years in advance of any 

mandate to make the switch. The success of these air conditioner provisions led to an 

expansion of this approach in 20 14 for the light duty fleet, with the introduction of an 

extended "off cycle" list of pre-defined and pre-approved credits for other technologies 

that reduce fuel usage in conditions not comprehended in the standard fuel economy tests, 

such as colder weather, higher speeds, or extended idl e times. All of these flexibility 

mechanisms that have been successful for the light duty trucks can be applied equall y to 

the Class 2b and Class 3 pickups and vans covered by this proposed regulation. 

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We have also had favorable experience with the extended carry-forward time allowed in 

the light duty regulation, which has resulted in manufacturers achieving greater 

improvements sooner, based on the understanding that they will not waste thro ugh 

expiration the surplus credits that they have earned through their early actions. This 

concept could also be applied to the medium and heavy duty segments. 

The agencies' proposed Class 2b/3 standards, which are based on alternative 3 in the 

Notice of Proposed Rulemaking, will continue to drive innovation and will dri ve GM to 

invest in and refine new teclmologies that are both appreciated and optimized by 

American consumers. We cautiously support this path based on alternative 3 for future 

emission reduction standards. This path will challenge our product plan and drive 

considerable technology into our heavy-duty trucks and vans. 

Finally, the program must attempt to minimize the potential for unintended 

consequences, especially for the consumer. The heavy duty Oeet does not benefit from 

the years of data that have been collected and analyzed for the light duty fleet. Indeed, 

comprehensive data for this product segment is only now being accumulated and 

analyzed for the 20 I4 model year, whi ch is the first year of Phase I of the medi urn and 

heavy duty truck regulations. Year-end reports for 2014 were due to EPA by the end of 

March 20 IS, so this first year of comprehensive industry-wide data is still fairly new. 

This new data should be carefully evaluated and compared to the estimates and 

assumptions that formed the basis for both Phase I and the proposed Phase 2 of the heavy 

duty regulations. 

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We will be providing more extensive written comments to address the key details that 

fundamentally crop up with the implementation of any new program. We look forward 

to working with NHTSA and EPA to assure that the program created is national in scope 

and consistent with these principles. Thank you. 

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