Testimony of Doug Corcoran Director of Public Sector, Southern California Waste Management Before the United States Environmental Protection Agency (EPA) National Highway Traffic SafetyAdministration (NHTSA) Concerningthe Proposed Phase 2 Greenhouse Gas Emission and Fuel Efficiency Standards for HeavyDutyTrucks August 18, 2015 Good morning, I am Doug Corcoran, Director of Public Sector for Waste Management's (WM) Southern California Area. Thank you forthe opportunityto testify on the Proposed Phase 2 rule for heavy-duty trucks. Waste Management is a leading provider ofcomprehensive waste and environmental services in North America. Headquartered in Houston, WM operates in 48 states in the U.S. and most Canadian provinces. As part ofour collection operations, we own and operate a fleet ofabout 18,000 heavyduty refuse trucks---- so this rule will have a significant impact on our operations. Before discussing ourviews on particular aspects ofthe proposal, we want to commend the Environmental Protection Agency and the National Highway Traffic SafetyAdministration forthe very collaborative process you used to develop this proposal. You were open, transparent and you sought s

takeholder information and encouraged input. At WM, we were very pleased to be invited to share with you our strategyto build a cleaner, more reliable natural gas fleet. We believe the resulting proposal reflects careful consideration ofourviews, providing a regulatory framework that can build upon the initial success of Phase 1, allowing us to continue to grow our natural gas fleet while complyingwith future GHG emission standards. The proposed Phase 2 Rule is very important to WM

. Let me tell you why. In 2007, WM identified a set ofsustainability goals that included reducingthe greenhouse gas (GHG) emissions from ourcompany fleet 15 % by 2020. Well, we exceeded that goal in 2011, and have reduced our fleet emissions by over 20 percent. We did so by steadily converting our fleet to cleaner burning, natural gas fueled vehicles

. Here in Southern California, we have converted 85 percent ofour fleet (over 1,100 heavy duty vehicles) to natural gas, while nation-wide nearly 25 percent ofour refuse vehicles run on natural gas. That makes ourfleet North America's largest heavy-duty natural gas fueled fleet. The natural gas trucks have been good for our customers and communities where we operate, good for the environment and good for our business

. Each truck eliminates the use of8,000gallons of diesel fuel a year, which is replaced by cleaner burning natural gas. Natural gas trucks have nearly zero particulate emissions and reduce greenhouse gas emissions by over 20 percent. The trucks are

### quieterthan their diesel counterparts, and

... (this is important) 

### they run on homegrown, secure sources offuel. Our strategy overthe comingyears is to make 90 percent or more ofour newfleet purchases natural gas trucks. Because ours is a nation-wide fleet and fueling strategy, 

### it will be important to have a consistent rule across all 50 states. We are also investing in natural gas fueling infrastructure. We operate about 75 natural gas fueling stations across the country, right now. Buildingthese stations is expensive and that can be a barrier to local governments thatwish to increase theirown public, natural gas fleets. That is why nearly 40% ofour stations are open to public and/orcity access. Workingwith our manufacturing partners and with our regulators, such as the South Coast Air Quality Management District, we have seen steady improvements in heavy-duty natural gas engine technology. For example, in future model years, enclosed crankcases will enable significant reduction in fugitive methane emissions from trucks- making an already clean technology even more environmentally beneficial. We view today's natural gas vehicles as a bridgeto the future, a bridgeto even cleaner running vehicles. As a next step towards further reductions in ourgreenhouse gas footprint, we are using the gas produced by our landfillsto make renewable natural gas for our vehicles.

• For example, 380 WM refuse trucks in California run on renewable natural gas from our Altamont Landfill ; • We plan to fuel several hundred more vehicles with new renewable natural gas production at our landfill in Milan, Illinois; and • We are working with other landfill owners to purchase renewable natural gas to fuel even more vehicles. On a lifecycle basis, renewable natural gas reduces greenhouse gas emissions by upwards of90 percent

. Therefore, the Phase 1 and Phase 2truck rules can work in avery complimentary way with the EPA's Renewable Fuel Standard. The transition ofour fleetto cleaner burningfuel is a sustainability issue- for our company, for our communities and customers, for the environment and for national security. In closing, Iwant to be clear that Waste Management supportsthe Environmental Protection Agency's and the National HighwayTraffic Safety Administration's Phase 2 goals of reducing greenhouse gas emissions and improvingthe fuel efficiency of heavy-dutyfleets.

Thank you.