Heavy-Duty Vehicle Fuel Efficiency Standards 

EPA/DOT Testimony 

Timothy J. Milburn 

Green Ways 2Go/ www ~enw~s2go com 

tim.milbJ!!Jl@greenways2Go.com /847-826-3314 

Thank you for the opportunity to testify. My name is Tim Milburn, and I represent Green Ways 

2Go, a consulting company in Illinois focusing on smart ways to reduce pollution in 

transportation. I am here in strong support of the proposed standards that will make our larger 

vehicles operate more cleanly and more efficiently for years to come. These proposed 

standards are a good step forward, and I urge you adopt these standards as a minimum, to 

ensure the significant reductions in oil consumption, greenhouse gas and other harmful 

emissions. 

I have spent much of my career in coal, oil, gas and biofuel applications as a combustion and 

pollution control engineer. I understand the chemistry and physics of the resulting products of 

combustion and how they interact with the environment once they leave the tailpipe. Based on 

the broad consensus of many experts, I agree the time is now to act to reduce C02 emissions; 

else we face increasingly serious challenges related to climate change. The transportation 

energy sector represents about one third of the total C02 generated in the US. 

Based on US Energy Information Administration data, the targeted larger vehicle group 

represents about 20% of the transportation total, second to light duty vehicles, at 54%. A key 

role of a democratic government is to create reachable, practical targets that benefit society 

and provide fair mechanisms to achieve these targets. If CAFE standards for light duty 

vehicles have been deemed necessary, this same logic should equally be applied for the 

larger vehicles, as this vehicle group represents the highest per vehicle miles and lowest fuel 

efficiencies and therefore the highest sources of pollution per mile driven and a large 

contributor to pollution and the associated negative human health and environmental impacts. 

The plan further targets having a two-year pay back in fuel savings vs. the incremental costs. 

This will be compelling to the fleet owners, who should be money ahead after just two years. 

The prosed standards would establish a level playing field, defining areas where American 

innovation can provide solutions that benefit society as a whole, by continuing to lead the US 

and the world on a path of responsibly managing man's impacts on the earth's ecosystems, 

while reducing the need for the US to import oil. This leads to economic stimuli, jobs. reduced 

risks and reduced costs required to globally protect oil, reduced trade deficits and a more 

competitive US global economic profile. These technical advances will soon come from 

somewhere in the world and having the US leading these improvements will result in exporting 

of US te~hnologies , meaning even more American jobs and cash flow. 

Initiatives like the Fuel Efficiency Standards help educate all of us on why we should be 

mindful of proper stewardship of the finite air, water and land resources we share. 

I urge you to finalize and adopt these or stronger standards. Simply put, this is the right thing 

to do. Thank you for the opportunity to testify.