NRDC 

Testimony of Luke Tonachel 

Director, Clean Vehicles and Fuels Project 

Natural Resources Defense Council 

EPA and NHTSA Hearing on the Proposed 

Phase 2 Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and 

Heavy-Duty Engines and Vehicles 

August 6, 2015 

Chicago, IL 

My name is luke Tonachel and I direct the Clean Vehicles 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 than most people, the phase 2 medium- and heavy-duty truck proposal 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 agencies 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 for heavy trucks. The latest projection from the Energy Information Administration 

shows that medium- and heavy-duty trucks will be a fast-growing source of oil demand and carbon 

pollution in the transportation sector if new truck standards are not implemented. NRDC believes 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 significant 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 believes that there are two areas where the agencies should modify the proposal. 

First, the compliance timeline 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 

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timeline 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 of existing 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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