1000 N. ALAMEDA ST 11240 

LOS ANGELES. CA 90012 

213.?93.4929 

August 18, 20 15 

Re: Heavy Duty Phase 2 Greenhouse Gas Emission and Fuel Consumption 

Standards 

Good afternoon. Thank you for the opportunity to give comment today. My 

name is David Fink and I'm the Director of Campaigns for Climate Resolve. We 

are LA's climate advocacy organization based in downtown Los Angeles and we 

are dedicated to creating real, practical solutions to meet the climate challenge 

while creating a better region for all Southern Californians today and in the 

future. 

First of all, we applaud the Obama administration and EPA for proposing 

standards that will make our freight trucks cleaner and more efficient for several 

years going forward. While the proposed standards are an important step in the 

right direction, we urge you to strengthen these standards to ensure the greatest 

reductions in oil use and global warming emissions. 

Climate Resolve believes it is vital that as a nation and as a state we take 

necessary measures that both prevent future climate change and help us prepare 

for the expected impacts. For this reason we strongly recommend the strongest 

possible standards that would require heavy-duty trucks to go further on a gallon 

of fuel. 

Not only will more fuel-efficient heavy-duty trucks directly reduce greenhouse 

gas emissions leading to a reduction in long term atmospheric warming but there 

are numerous benefits that will also help us prepare for expected climate impacts, 

make us more resilient and stave off the worst case scenarios. 

The best science we have tells us that Southern California will warm 4-5° Fin 

the middle part of this century and the number of extreme heat days will double 

and in some parts of the region triple. If we continue with business as usual 

temperatures are expected to rise an average of 9° F by the end of the century. 

However with strong mitigation measures we will see a leveling off of warming 

and a reduction of average temperatures in the latter half of this century. 

Higher average temperatures and stronger heat waves will have many negative 

impacts maybe none more so than on public health. In a typical year there are a 

greater number of mortalities attributed to heat than all other weather events 

combined. There is also a strong correlation between heat and ground level 

ozone formation, meaning poorer air quality, a trigger for asthma and other 

chronic respiratory ailments. 

Lastly, our cities already suffer from higher average temperatures than 

surrounding rural areas due to a phenomenon called the Urban Heat Island Effect 

which typically pushes temperatures up 4-6°. There are three main drivers of the 

Urban Heat Island Effect, paved surface area (roads, rooftops, etc.), lack of 

vegetation and exhaust from automobiles, trucks and manufacturing. Therefore 

the standards being discussed today, which will drive down heavy-duty truck 

emissions, can play a significant role in helping us cool our cities and make us 

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Once again, we commend the administration for proposing standards to make our 

trucks more efficient, and we urge you to finalize stronger standards that reduce 

trucks' fuel use by 40% by 2025. Thank you for the opportunity to testify. 

Sincerely, 

David Fink 

Director of Campaigns 

Climate Resolve 

dfink@climateresolve.org