Testimony of Doug Corcoran 

Director of Public Sector, Southern California 

Waste Management 

Before the 

United States Environmental Protection Agency (EPA) 

National Highway Traffic Safety Administration (NHTSA) 

Concerning the Proposed Phase 2 Greenhouse Gas Emission and Fuel Efficiency Standards for HeavyDuty Trucks 

August 18, 2015 

Good morning, I am Doug Corcoran, Director of Public Sector for Waste Management's (WM) 

Southern California Area. 

Thank you for the opportunity to testify on the Proposed Phase 2 rule for heavy-duty trucks. 

Waste Management is a leading provider of comprehensive 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 of our collection operations, we own and operate a fleet of about 18,000 heavyduty refuse trucks---- so this rule will have a significant impact on our operations. 

Before discussing our views on particular aspects of the proposal, we want to commend the 

Environmental Protection Agency and the National Highway Traffic Safety Administration for the very 

collaborative process you used to develop this proposal. You were open, transparent and you sought 

stakeholder information and encouraged input. At WM, we were very pleased to be invited to share 

with you our strategy to build a cleaner, more reliable natural gas fleet. 

We believe the resulting proposal reflects careful consideration of our views, 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 complying with 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 of sustainability goals that included reducing the greenhouse gas (GHG) 

emissions from our company 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 of our fleet (over 1,100 heavy duty 

vehicles) to natural gas, while nation-wide nearly 25 percent of our refuse vehicles run on natural gas. 

That makes our fleet 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 of 8,000 gallons 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 
quieter than their diesel counterparts, and ... (this is important) they run on homegrown, secure 

sources of fuel. 

Our strategy over the coming years is to make 90 percent or more of our new fleet 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. Building these stations is expensive and that can be a barrier 

to local governments that wish to increase their own public, natural gas fleets. That is why nearly 

40% of our stations are open to public and/or city access. 

Working with 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 bridge to the future, a bridge to even cleaner running 

vehicles. 

As a next step towards further reductions in our greenhouse gas footprint, we are using the gas 

produced by our landfills to 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 of 90 

percent. Therefore, the Phase 1 and Phase 2 truck rules can work in a very complimentary way with 

the EPA's Renewable Fuel Standard. 

The transition of our fleet to cleaner burning fuel is a sustainability issue- for our company, for our 

communities and customers, for the environment and for national security. 

In closing, I want to be clear that Waste Management supports the Environmental Protection 

Agency's and the National Highway Traffic Safety Administration's Phase 2 goals of reducing 

greenhouse gas emissions and improving the fuel efficiency of heavy-duty fleets. 

Thank you.