## NRDC

Testimony of Luke Tonachel Director, Clean Ve hicles and Fuels Proj ect Natural Reso urces Defense Cou n ci l EPA and NHTSA Hea rin g o n the Proposed Phase 2 Greenhouse Gas Emission s and Fu el Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles August 6, 2015 Chicago, IL My name is luke Tonachel and I direct the Cl ean Ve hicles and Fuels Project at the Natural Resources Defense Council, or NRDC. On behalf of NRDC's more than 2 million members and online activists , I appreciate the opportunity to testify today
. As you know better th an most people, the ph ase 2 med ium - and heavy-d uty truck proposa l is the result of a tremendous amount of work. NRDC greatly appreciates the fair and inclusive rule development process conducted by the agencies. I understand that the agenci es have conducted hundreds of meetings with stakeholders including those meetings with us in the NGO community speaking on behalf of the public's environmental concerns. A healthy environment and our clean energy future depend on strong greenhouse gas and fuel efficiency standards fo r heavy trucks
. The latest projection from the Energy I nformation Admi nistration shows that medium - and heavy-duty t ru cks wi ll be a fast-growing source of oil demand and carbon pollution in the transportation sector if new tru ck standards are not implemented
. NRDC bel ieves these standards are an integral and critical part of President Obama's Climate Action Plan. The proposed standards include some very important steps forward. For example, adding trailers to the truck rules can deliver signifi cant efficiency benefits. Also, the agencies made improvements to regulatory compliance tools, such as the GEM model and the vocational segmentation and duty cycles. At a high level, NRDC bel ieves that there are two areas where the agencies should modify the proposal. First, the compliance t imeline should be moved up. The environmental community conducted conservative analysis showing that new fleet fuel consumption and greenhouse gas emissions can be reduced by at least 40 percent from 2010 levels by 2025. Within the proposal, Alternative 4, which achieves full compliance in 2024, is the closest to meeting our target. When it comes to cutting carbon and reducing our dangerous dependence on oil, every year counts. The agencies' own analysis shows that Alternative 4 is technically feasible and cost-effective. NRDC believes that the 2024 compliance
1timeline is also appropriate. Compared to the proposal, Alternative 4 reduces oil consumption and carbon pollution by an additional13 percent and increases net benefits by over $24 billion. NRDC urges the agencies to accelerate the compliance timeline. Second , NRDC believes that the engine standard should be significantly strengthened. As proposed, the engine standard is weak because it achieves only a 4.2 percent emissions reduction over ten years . In reality, the standard is even weaker-and close to 3 percent-because the proposed re -weighting the Supplemental Emission Test (SET) toward lower engine speeds results in better performance on the test without any new technology addition. NRDC supports the structure of a separate engine standard because we think it is necessary to ensure all cost-effective efficiency technologies will be applied to the engine. However, the proposed engine standard appears too modest to drive the full suite ofexisting technology adoption and certainly fails to be technology-forcing. We urge the agencies to strengthen the engine standard. NRDC believes that strong engine and vehicle standards are important for improving industry competitiveness and supporting manufacturing jobs. Strong fuel efficiency promote technology innovation and adoption . When more technology is added to vehicles, demands for labor-and therefore jobs-are increased. Working with the BlueGreen Alliance, NRDC is assessing U
.S

. jobs associated with making and applying technologies that improve fuel efficiency in medium- and heavy-duty trucks
. We believe that the standards can boost manufacturing jobs across the country. Today, more than 36,000 engineers, technicians and assembly workers are employed in over 380 facilities across 43 states to develop, design and build components and trucks that help haul goods using less fuel. Fuel efficiency and carbon pollution standards also help make all truck manufacturers more competitive. Compared to their fuel-guzzling predecessors, fuel -efficient trucks will be less vulnerable to sales declines when diesel and gasoline price spikes. Also, standards-driven technology advancements will put U.S. manufacturers in a leadership position on the international market as the European Union , China, Japan and other countries implement their own truck efficiency requirements. NRDC believes that strong medium- and heavy-truck fuel efficiency and carbon pollution standards are good for the economy and the environment. We greatly appreciate the hard work of the agencies on this comprehensive and thorough proposal. As I've described today, there are opportunities to strengthen the standards to maximize the benefits to our nation. NRDC looks forward to working with the agencies to make improvements for the final rule. Thank you very much for your attention
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