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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 Effici ency Standards for Medium- and Heavy-Duty Engines and Vehi c les 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 science based 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 tha t I am here today to provide comments on the Phase 2 greenhouse gas and fuel effic iency proposal that your agencie s have developed . Tackling pollution and fuel consumption from heavy-duty trucks is a critical task . Left unchecked , g l obal warming emissions and oil use from these vehicles will continue to grow despite the successfu l , on -go ing 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 i n net economic savings . Union of Concerned Scientists applauds EPA and NHTSA for seeking to address growing fuel use an d emissions by proposing new standards for these vehicles . The proposal represents a signifi cant step forward from Phase 1 , particularly with the inclusion of trailers . However, there are additional opportunities to increase the emission reductions and oil saving s from heavy-duty trucks , while continuing to provide strong overall economic benefits from the prog ra m an d we urge the agencies to strengthen the rule . First and foremost . the agencies should accelerate the implementation of the standards . O ur a nalys is shows that by 2025 , new truck fuel consumption can be reduced 40 percent below 2010 levels . T he 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 i ndependent organizations . as we ll as the technical capabilities of the industry . In addition , the stringency of the engine standard is much lower than our assessm e nt of the p ote nti a l cost-effective improvements available over the next decade . As prop osed , the standard s requ ire a verymodest 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 techno l ogy-both in their reliance only on the GEM , and not-real world , duty cycle and also by excluding the benefits of using el ectric power take-off in some of the applications most likely to utilize hybrid technology , such as util ity 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 tech nol ogy 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 techno logies 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 i nvesting 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 on ly continue , but to accel erate over the time frame of the regulation .2 EPA and NHTSA can support advanced technology t ruck 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 nat ion ' 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-emissio n trucks have been f u nded through California i ncentive programs si nce 2010. R eference avai lab le online at: http :/ /INWw .arb.ca.gov

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_plan.pdf 2 Governor' s E xecutive Order available online at: http ://gov .ca.gov / news.p h p?id=1904 6