CRLSTRRT Comments of Bill Van Am burg; CALSTART 

Before the National Highway Transportation Safety Administration 

And the U.S. Environmental Protection Agency Phase II HD Fuel Economy Wor bop 

Long Beach, CA August 1,8, 201,5 

CALSTART appreciates the opportunity to provide comments today on the dra 

Heavy-duty Phase II fuel economy rules. EPA and NHTSA staff have been high 

collaborative with industry in developing these important rules to this stage. 

look forward to continuing to work with both staffs to finalize the regulations 

next spring. 

By way of background, CALSTART is a California-based, national non .. profit de n 

transportation technologies coalition of more than 150 companies and agencie . Our 

mission is to grow the clean transportation industry segment. We support the 

development of strong, effective fuel economy regulations as a key component 

reducing greenhouse gas emissions on the timeline needed to move toward mi -

century climate stability goals. 

With our base in California, we are especially sensitive to the climate change 

imperative. But we also support strong efficiency regulations as a driver of 

American technology and economic opportunities. Many of the advanced, efficient 

technologies needed will be built 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 of a just completed fleet fuel economy 

benefits study, and some preliminary high level observations on the rule stru 

Our new report, titled Higher Fuel Efficiency: Working for Fleets, was built aro d 

assessing the business case for fleets of higher fuel efficiency trucks that might e 

driven by a new fuel economy rule. 
We worked with a cross section of fleets representing various applications and truck 

types nationwide to validate the key components of a fleet business case asses ent 

model - collaborating with the NAFA Fleet Management Association and its fleets. 

In developing the model, we surveyed fleets on their support for - and concern 

about - increased fuel efficiency. 

• Interestingly, we found 87 -persent of fleet 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 efficient trucks if they knew they would 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-city and work site 

support; and 

• Class 28 pickups and vans. 

While structured before your draft rules were released, these categories are ve 

similar to the vocational segments you are proposing - and which we generally 

support. 

We then looked at different technology packages that were most applicable to 

use profile, with a goal of assembling packages that could achieve up to a 40 pe cent 

reduction of fuel use over 2010 baseline trucks. Many of these 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 of the report, but in a nutshell our top level findings were ese: 

• We found there is a reasonable business case payback, based on fleetvalidated cost assessment tools, for higher fuel economy trucks at levels 

proposed in the rules. 

• Indeed, the stringency levels we modeled in the 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 economy targets 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 up front cost of the technology. 

• Higher mileage or fuel use applications had strong and fast paybacks - s ch as 

Class 8 Over the Road in as short as nine months. 

• One of the items we could not include in our model was projected 

maintenance costs - there are no good data points for this. Fleets have 

suggested that modeling payback sensitivity to maintenance cost would e 

helpful. 

In shaping the final rule, we see a solid payback from efficiency. 

Indeed, we see a strong case for higher efficiency targets than those currently 

for in several vocational segments. 

However, some of the technology that could provide this efficiency- such ash 

and electric systems - might not be needed at lower stringency targets, but the 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 technology phase in. But it should be bolstered with gre ter 

stringency and accompanying rule flexibility- such as an advanced technology redit 
·market. and a streamlined off cycle credit process - to make sure achievable a d 

affordable efficiency gains do not get left off the table. 

We look forward to working with the agencies to explore these issues.