INTERNATIONAL UNION, UNITED AUTOMOBILE, AEROSPACE & AGRICULTURAL IMPLEMENT WORKERS OF AMERICA – UAW

DENNIS WILLIAMS, President GARY CASTEEL, Secretary-Treasurer

VICE PRESIDENTS: CINDY ESTRADA • JIMMY SETTLES • NORWOOD JEWELL

IN REPLY REFER TO

August 18, 2015

1757 N STREET, N.W.

WASHINGTON, D.C. 20036

TELEPHONE: (202) 828-8500

FAX (202) 293-3457

Environmental Protection Agency

Department of Transportation--National Highway Traffic Safety Administration

EPA–HQ–OAR–2014–0827; NHTSA–2014–

0132; FRL–9931–77–OAR

RIN 2060–AS16; RIN 2127–AL52

Greenhouse Gas Emissions and Fuel

Efficiency Standards for Medium- and

Heavy-Duty Engines and Vehicles—

Phase 2

Comments submitted by President 

Dennis Williams, President, International Union, UAW

The International Union, United Automobile, Aerospace and Agricultural Implement Workers of America, 

(UAW) appreciates the opportunity to share our views on the proposed Greenhouse Gas Emissions and Fuel 

Efficiency Standards for Medium and Heavy-Duty Engines and Vehicles-Phase 2 National Program. 

The UAW represents over one million active and retired members, many of whom have a considerable stake in 

the continued success of the motor vehicle manufacturing industry. We represent over 34,000 workers who 

could be directly impacted by this proposal. Our members assemble Navistar, Freightliner, Volvo and Mack 

medium and heavy trucks; heavy-duty pick-up trucks; vocational vehicles; school buses and vans. Our 

members also work in plants making engines, axles, transmissions and other parts for those vehicles.

The UAW supports President Obama’s goal of addressing climate change, increasing fuel efficiency and 

reducing greenhouse gas emissions in the combination tractor, heavy-duty pick-up truck, van, and vocational 

vehicle fleets. Regulations, properly crafted, can be good for the environment and the broader economy. This 

can and should be a win-win. For example, increasing the efficiency of light-duty vehicles has led directly to the 

creation of jobs in the auto industry.

We commend the U.S. Environmental Protection Agency (EPA) and Department of Transportation’s National 

Highway Traffic Safety Administration (NHTSA) for their diligent work in crafting this proposal and for their 

willingness to engage on this important matter. We are carefully studying the various options presented in this 

proposal and are not making final recommendations at this time. Even under the most optimal circumstances,

industry participants will be required to make changes to their product design and adapt to comply. With this in 

mind, we urge you to proceed carefully. We are concerned about the potential economic disruption caused by 

any standards that are not achievable or are developed without giving proper consideration to market reaction 

and other possible ramifications. Here are some of our guiding principles and overarching recommendations in 

no particular order.

As you know, the medium and heavy duty sector is already working to comply with the first-ever fuel economy 

and emission standards for model years 2014-2018. This is a challenging task and the existing standards will 

reduce greenhouse gas emissions by approximately 270 million metric tons and save 530 million barrels of oil. 

Your main proposal recognizes this reality and the challenges it presents. We support the phasing-in of 

stringency standards as most of the new requirements will not start until model year 2021. This will enable the 
industry to improve efficiency without causing major market disruption and accounts for product cycle. We 

would have significant concerns about the feasibility and impact from moving the 2021 requirements to an 

earlier date.

It is essential to maintain flexibility by allowing companies to achieve stringency targets in a manner that best 

suits their competitive and market position. The regulation should not be overly prescriptive or technology 

forcing. Specifically, the Averaging, Banking and Trading (ABT) and advanced technology credit system is 

essential for achieving this end. We urge you to give consideration to proposals that would further improve the 

credit system and allow increased flexibility around product cycles. 

Without sufficient flexibility, the tough standards included in this proposal would likely lead to layoffs and other 

negative economic consequences. The “Phase 2” requirements cannot result in a boom and bust cycle for 

American working men and women and their families who work hard to manufacture the vehicles our nation 

depends on. Prescriptive, technology forcing requirements in this industry have been problematic in the past 

and may very well be again. 

Many of our members experienced economic hardship and uncertainty when new truck purchasers rushed to 

pre-buy trucks in anticipation of increased costs due to regulatory requirements outlined in earlier heavy-duty 

engine emission standards. This was especially a problem for complying with 2007 standards. This pre-buy 

was a contributing factor resulting in the lay-off of thousands of UAW members and other workers. Sadly, it 

took as long as five or six years before some workers were recalled. This was a time filled with financial 

hardship and stress as many workers struggled to make ends meet. 

The pre-buy/no buy cycle is not only bad for workers. It is also bad for the environment and undermines the 

entire goal of regulations. Customers in the heavy duty sector are especially sensitive to the bottom line and 

will resist buying vehicles that are viewed as prohibitively expensive or include unproven technologies. We

want to encourage innovation and purchases of more efficient vehicles. Regulations designed the wrong way 

achieve the opposite results. A separate engine standard that is overly stringent has the potential to lead to 

this outcome. We are still examining the engine standard but encourage you to ensure the final rule does not 

create an engine standard that would lead to a pre buy/no buy cycle. Companies that choose to rely on engine 

efficiency to help meet the standard can do so under the overall combination tractor standard.

We encourage the agencies to continue to refine the standard’s compliance testing procedures to not only 

accurately reflect real world driving and work conditions, but to also avoid increasing stringency via technical 

requirements.

Finally, the standard has to be harmonized and applicable throughout the country. To do otherwise would be 

entirely inconsistent to the realities of commerce. 

UAW wants this proposed regulation to succeed and is willing to work with all stakeholders and interested 

parties to reach this achievement. Thank you.

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