Tes timony of Robert Cadle Director, R&D Engineering, Transportation Systems Honeywell Public Hearing on Proposed Rule: Greenhouse Gas Emissions and Fuel Efficienc y Standards for Medium- and Heav y-Duty Engines and Vehicles- Phas e 2 Long Beach, CA August 18, 2015



### Good morning and thankyou 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 ofturbomachinery 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 ofenabling 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 ofthe proposal.
2. The consideration given to certain fuel types in the heavy duty pickup and van, and Mediumand Heavy-Dutyvocational truck portions ofthe proposal. We appreciate that revised weighting factors forthe SET cycle C02 emissions forthe 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 newweighting factors effectively represent a "regulatory downspeeding", and we estimate this will result in a cycle-weighted fuel consumption improvement ofapproximately 

### 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 ofchange in engine efficiency. The new weighting factors have a similar impacton 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 ofadvanced technologies likeRankine 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 orderto 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 mostcost-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 ofthe Phase 2 regulation. The cost differential between diesel and gasoline engines has increased substantially overthe past 10years, 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 ofgasoline 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 forvehicle 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 ofgreenhouse gas reduction and fuel efficiency technology, while balancing the needs of industry, consumers and the environment. We believe strongtargets 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.