Testimony of Robert Cadle 

Director, R&D Engineering, Transportation Systems 

Honeywell 

Public Hearing on Proposed Rule: 

Greenhouse Gas Emissions and Fuel Efficiency Standards 

for Medium- and Heavy-Duty Engines and Vehicles- Phase 2 

Long Beach, CA 

August 18, 2015 

Good morning and thank you for opportunity to speak here today and provide feedback on the 

Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and 

Vehicles-Phase 2 rulemaking proposal. My name is Rob Cadle and I represent the Transportation 

Systems business at Honeywell International, a leading provider of turbomachinery solutions for light 

and heavy duty passenger and commercial vehicles. 

We applaud the EPA, NHTSA and CARB for their efforts to make the Phase 2 rule making process 

transparent and data-driven, soliciting and considering multiple views across the industry. We also 

appreciate the ten year timeline through 2027 and the three-phased approach because it provides the 

industry with clear milestones that support long-term investment in the development of enabling 

technologies. 

The testimony I am providing today focuses on two specific areas: 

1. The engine efficiency improvement targets outlined in the Heavy Duty tractor portion of the 

proposal. 

2. The consideration given to certain fuel types in the heavy duty pickup and van, and Mediumand Heavy-Duty vocational truck portions of the proposal. 

We appreciate that revised weighting factors for the SET cycle C02 emissions for the HD long haul 

tractor engine standard have been included in the proposal. These revised weighting factors better 

represent real-world operating conditions of long-haul trucks with minimal additional complexity. 

However, the new weighting factors effectively represent a "regulatory downspeeding", and we 

estimate this will result in a cycle-weighted fuel consumption improvement of approximately 1%, with 

no changes made to the engine. This essentially means that 2021 model year engines only need to be 

0.5% more efficient than the 2017 baseline, a 0.12% per year improvement over 4 years. This is well 

below the industry's historical "continuous improvement" rate of change in engine efficiency. The new 

weighting factors have a similar impact on subsequent reduction levels. 

For this reason, we believe there is room to make the engine-level C02 reduction larger than is reflected 

in the current proposal, without the need for wide-spread adoption of advanced technologies like 
Rankine Cycle waste heat recovery. Honeywell can help provide data and work with the EPA to refine 

the inputs to the model to better reflect the improvements that air system technology can provide in 

order to enable this. 

We believe that new regulations should be technology neutral, setting standards that everyone must 

meet, without favoring one particular approach over any other. Fuel neutrality is critical to ensure that 

the proposed rule can be met in the most cost-effective manner for industry and consumers. We are 

therefore concerned with several aspects of the proposed rule regarding fuel neutrality. 

1. First, requiring heavy duty pickup trucks and vans powered by diesel and gasoline engines to 

each improve fuel efficiency by 16% from the 2017 baseline will only achieve the targeted overall 

fleet C02 reduction if diesel/gas engine share remains constant. It is likely that gasoline-powered 

vehicles will be able to achieve their required decrease in fuel consumption at lower cost and 

complexity than diesel-powered vehicles, resulting in a shift towards gasoline vehicles which emit 

more C02 than their diesel counterparts, thus increasing total fleet C02 emissions. An alternative 

is to simply require a 16% fleet average C02 emissions reduction, and allow the industry and 

consumers to pick the fuel and technology combination that offers the best value while meeting 

the requirement. 

2. The current proposal also excludes gasoline engines from the MD/HD Vocational portion of the 

Phase 2 regulation. The cost differential between diesel and gasoline engines has increased 

substantially over the past 10 years, as diesel engines have adopted technologies to comply with 

NOx and PM regulations. This has made diesel engines less competitive on initial cost, and the 

industry has seen a steady increase in the market share of gasoline engines in class 3-5 

applications. We believe that the proposal as written will further increase the initial cost of 

diesel engines while allowing gasoline engines a "free pass" on C02. This will likely result in a 

much larger share for gasoline in these markets and has the potential to create a double 

negative effect: higher operating cost for vehicle users and higher C02 emissions for the fleet. 

We intend to elaborate on these items in our written comments and will provide further supporting 

data. 

Honeywell supports continued efforts to keep the United States at the forefront of greenhouse gas 

reduction and fuel efficiency technology, while balancing the needs of industry, consumers and the 

environment. We believe strong targets are feasible and are committed to working with government 

and industry to provide innovative technologies that provide a clear end user payback. Thank you again 

for the opportunity to speak today.