# CRLSTRRT Comments ofBill Van Amburg; CALSTART Before the National Highway Transportation SafetyAdministration And the U.S. Environmental ProtectionAgency Phase II HD Fuel Economy Wor bop Long Beach, CA August 1,8, 201,5 CALSTART appreciates the opportunityto provide comments today on the dra Heavy-duty Phase II fuel economy rules. EPA and NHTSA staffhave been high collaborative with industry in developing these importantrules to this stage. look forward to continuingto work with both staffs to finalize the regulations next spring. By way ofbackground, CALSTART is a California-based, national non..profit de n transportation technologies coalition ofmore than 150 companies and agencie . Our mission is to grow the clean transportation industry segment. We supportthe development ofstrong, effective fuel economy regulations as a key component reducinggreenhouse gas emissions on the timeline needed to move toward mi
- centuryclimate stabilitygoals. With our base in California, we are especially sensitive to the climate change imperative. Butwe also support strongefficiency regulations as a driver of American technology and economic opportunities. Many ofthe advanced, efficient technologies needed will bebuilt and commercialized first in the U.S. because these rules. We will offer more complete comments to you on rule specifics for the docket. we wanted to share with you the results ofa justcompleted fleet fuel economy benefits study, and some preliminaryhigh level observations on the rule stru Our new report, titled Higher Fuel Efficiency: Working for Fleets, was builtaro d assessing the business case for fleets ofhigher fuel efficiency trucks that might e driven by a new fuel economy rule.We worked with a cross section offleets representingvarious applications and truck types nationwide to validate thekey components ofa fleet business case asses ent model
- collaboratingwith the NAFA FleetManagementAssociation and its fleets. In developing the model, we surveyed fleets on their supportfor
- and concern about
- increased fuel efficiency.
• Interestingly, we found 87-persent offleet managers responding suppo rules driving higher fuel efficiency. • Their primary concern was cost; though 89-percent said they would be "lling to pay more up front for fuel efficienttrucks iftheyknew theywould pa over their life. • They also expressed concern about reliability and maintenance costs. Using the life cycle cost model we validated in the survey we assessed business ses in seven specific truck use profiles: • Class 8 Over the Road; • Class 8 Regional Haul; • three medium duty use profiles: Urban, rural/intra-cityand work site support; and • Class 28 pickups and vans. While structured beforeyour draftrules were released, these categories are ve similar to the vocational segmentsyou are proposing
- and which we generally support. We then looked at different technology packages that were most applicable to use profile, with a goal ofassemblingpackages that could achieve up to a 40 pe cent reduction offuel use over 2010 baseline trucks. Many ofthese packages, and projected costs, came from National Research Council and Transportation Rese reb Board studies, around which we modeled high and low cost scenarios and calcu ated payback.I will provide copies ofthe report, but in a nutshell ourtop level findings were ese: • We found there is a reasonable business case payback, based on fleetvalidated cost assessment tools, for higher fuel economytrucks atlevels proposed in the rules. • Indeed, the stringency levels we modeled inthe report were, in most cas s, actually higher than those proposed in the Alternative 3 language. • While all fleets are different, we found a positive business case in almost II scenarios we modeled. • We saw the potential for higher fuel economytargets than those proposed in several use profiles
- particularly urban trucks, regional trucks and thos vehicles with high work site idle time. • The

**b~ggest** variables for payback were utilization
- the mileage and fuel used

- and the upfront cost ofthe technology. • Higher mileage or fuel use applications had strongand fast paybacks - s ch as Class 8 Over the Road in as short as nine months. • One ofthe items we could not include in our model was projected maintenance costs - there are no good data points for this. Fleets have suggested that modelingpayback sensitivityto maintenance costwould e helpful. In shapingthe final rule, we see a solid payback from efficiency. Indeed, we see a strongcase for higher efficiency targets than those currently for in severalvocational segments. However, some ofthe technology that could provide this efficiency- such ash and electric systems - might notbe needed atlower stringencytargets, butthe are critical to goals in California and some other regions. Given fleet reliability and maintenance concerns, a long rule horizon with stair tep increases may smooth technologyphase in. But itshould be bolstered with gre ter stringencyand accompanyingrule flexibility- such as an advanced technology redit

### ·market. and a streamlined offcycle creditprocess - to make sure achievable a d affordable efficiency gains do not getleft offthe table. We look forward to working with the agencies to explore these issues.