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Statement of 

The Union of Concerned Scientists 

IN RESPONSE TO 

NHTSA and EPA Proposed Phase 2 Greenhouse Gas Emissions and Fuel Efficiency 

Standards for Medium- and Heavy-Duty Engines and Vehicles 

August 18, 2015 

Long Beach, CA 

Thank you for the opportunity to testify today. My name is Don Anair and I am the research and deputy 

director of the Clean Vehicles Program at the Union of Concerned Scientists. UCS is a leading sciencebased non-profit with more than 450,000 supporters and a network of nearly 17,000 scientists, engineers, 

and public health professionals. Reducing oil consumption and pollution from heavy-duty vehicles has 

been a focus of our work for more than 15 years. So it is with great interest that I am here today to 

provide comments on the Phase 2 greenhouse gas and fuel efficiency proposal that your agencies have 

developed. 

Tackling pollution and fuel consumption from heavy-duty trucks is a critical task. Left unchecked, global 

warming emissions and oil use from these vehicles will continue to grow despite the successful, on-going 

implementation of the Phase 1 standards. Fortunately, technical analyses by UCS and others, including 

the national academies, show that much greater improvements are not only possible, but will result in net 

economic savings. 

Union of Concerned Scientists applauds EPA and NHTSA for seeking to address growing fuel use and 

emissions by proposing new standards for these vehicles. The proposal represents a significant step 

forward from Phase 1, particularly with the inclusion of trailers. 

However, there are additional opportunities to increase the emission reductions and oil savings from 

heavy-duty trucks, while continuing to provide strong overall economic benefits from the program and we 

urge the agencies to strengthen the rule. 

First and foremost. the agencies should accelerate the implementation of the standards. Our analysis 

shows that by 2025, new truck fuel consumption can be reduced 40 percent below 2010 levels. The 

timing and stringency of Alternative 4, which moves the final implementation date from 2027 to 2024, is 

much more consistent with the analyses of UCS and other independent organizations. as well as the 

technical capabilities of the industry. 

In addition, the stringency of the engine standard is much lower than our assessment of the potential 

cost-effective improvements available over the next decade. As proposed, the standards require a very 
modest 4.2% reduction in fuel consumption between 2018 and 2027. This falls far short of the potential 

improvements over this time frame. 

Third, we applaud the agencies for including hybrid technology when setting the overall stringency. 

Hybrid technology is commercially available and should be expected to continue to advance over the 

timeframe of this regulation. However, in the current proposal, the agencies have underestimated the 

effectiveness of hybrid technology-both in their reliance only on the GEM, and not-real world, duty cycle 

and also by excluding the benefits of using electric power take-off in some of the applications most likely 

to utilize hybrid technology, such as utility bucket trucks. These exclusions downplay both the costeffectiveness of this critical technology and its penetration , thus underestimating the total potential for 

reductions from the vocational vehicle sector. The agencies should fully consider the benefits of hybrid 

technology, including the advancement of technology development and growth in cost-effective 

applications over the timeframe of the rule, and increase the stringency of the vocational vehicle 

standards to reflect this. 

The standards should also support the development and deployment of technologies that are needed to 

meet air quality standards, protect the health of communities near freight hubs, and achieve deep 

reductions in climate emissions in the future. These include technologies like battery electric, plug-in 

hybrid electric, and fuel cell trucks, as well as strong hybrids in Class 7 and 8 tractors, all of which are in 

earlier stages of development and deployment. 

States like California, as well as early adopter fleets, are investing millions of dollars to move advanced 

truck technology toward full commercialization and deployment and hundreds of advanced electric trucks 

are already operating on the road today.

1 With Governor Brown's recent executive order calling for 

deployment of zero-emission technologies in the freight sector as well as the on-going commitment of 

investments from California's Greenhouse Gas Reduction Fund, these technology developments are 

expected to not only continue, but to accelerate over the time frame of the regulation.

2 

EPA and NHTSA can support advanced technology truck development by both increasing the stringency 

of requirements for vocational vehicles and by restoring the advanced technology credits, or similar 

mechanism, to incentivize the most advanced technologies. 

In conclusion, we strongly urge EPA and NHTSA to finalize Phase 2 heavy-duty standards that fully 

capture the technical capabilities and ingenuity of the truck manufacturing sector and set a path to 

even greater emission reductions and fuel savings in the future. Strong standards will help to keep 

America's truck manufacturing sector competitive, spur economic growth, and improve the nation's 

energy security and our environment while saving the nation's truck fleets and their customers 

billions of dollars in fuel costs. 

Don Anair 

Research and Deputy Director 

Clean Vehicles Program 

1 Over 390 zero-emission trucks have been funded through California incentive programs since 2010. Reference 

available online at: http:/ /INWw .arb.ca.gov I msprog/ aqip/fundplan/proposed _ fylS-16 _funding_plan.pdf 2 Governor's Executive Order available online at: http://gov.ca.gov/ news.php?id=19046