# TESTIMONY OF.·
Kenneth McA/inden Advanced Heavy-Duty Regulations Supervisor Vehicle Environmental Engineering Ford Motor Company



# EPA and NHTSA Public Hearing "Phase 2 Greenhouse Gas Emissions Standards and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles" Thursday , August 6 , 2015Good morning , I'm Ken McAiinden , Advanced Heavy-Duty Regulations Supervisor for Ford Motor Company. It is a pleasure to be here today to provide our perspective on this very important rulemaking . We commend the efforts of EPA and NHTSA in the difficult task of developing this second phase of their greenhouse gas emissions and fuel efficiency standards for medium and heavy-duty eng ines and vehicles. Moreover, we commend the agencies for working closely with the California Air Resources Board in developing these proposed standard s. We are committed to working with EPA, NHTSA and ARB to finalize these regulations as a single national program that would allow manufacturers to continue to build a single fleet of vehicles and engines.
Before I talk about the proposed rulemaking, I would like to spend a moment telling you about the progress that Ford is making in executing our long term sustainabi lity plan . Since the Phase 1 Heavy Duty Greenhouse Gas requirements were promulgated, Ford introduced a whole new line offull sized vans called "T ransit", which feature fuel efficient V6 and turbocharged gasoline engines as well as a five cyli nder Diesel engine. Ford's complete and incomplete vehicles in this segment consist of Transit and Econoline vans , F-Super Duty trucks and motorhomes.
Ford is investing bi llions of dollars over the next five years to introduce technologies that improve fuel economy and reduce th e greenhouse gas emissions of our fleet. We' re driving innovation in every part of our business to deliver advanced new products and to change the way the world moves . Commercial truck customers demand technologies that provide "value for money" while providing truck functionality , whether it's volume for

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### people or cargo , the ability to haul large loads, or to work off-road . Fuel economy continues to be very important to our commercial truck customers , and Ford has invested in technologies to maintain customer satisfaction . You will continue to see us offer more great products with advanced , innovative technologies to improve the fue l efficiency of our vehicles and to deliver outstanding quality and features that our customers desire. Turning now to the proposed rulemaking , Ford supports the continuation of the harmonized greenhouse gas emissions and fuel consumption regulatory framework for over 8500 pound vehicles. The Phase 2 proposal offers cha llenging greenhouse gas and fuel economy targets , particularly in the context of new emissions standards and changes to test fuel properties in the same time period . These externa l factors increase the effective stringency and technology forcing aspects of the Heavy Duty Greenhouse Gas proposal beyond what the numerical value of the standards alone would suggest. As mentioned earlier, we offer essentially two types of complete vehicles , a van and a pickup truck ; therefore it is of critical importance to provide manufacturers with adequate lead-time to meet these requirements . As with Phase 1, the proposal includes a range of compliance mechanisms such as the ability to carry forward credits from prior model yea r s as well as vocational vehicle and engine averaging , banking and trading provisions. Ford supports expansion of the Phase 1 allowances to generate emission credits for 

### C02 

### improvements for technologies providing on-road fuel consumption benefits that are not captured by the emissions test cycles or models . Ford supports the establishment of standards that:

Pag e 3 of 5 August6, 2015• Recognize the needs ofthe trucking industry and other commercial users • Increase the use of known technology found to be feasible and effective in this market segment • Preserve the utility and functionality of these commercial vehicles including maintaining separate gasoline and diesel targets • Are compatible with the complexities of the marketplace ; and • Avoid unintended consequences Ford has some concerns with the accuracy of the Greenhouse Gas Emissions model used to determine compliance for Vocational Vehicles , particularly in the case of vehicles with Heavy Duty Gasoline and Light Heavy Duty Diesel engines. Ford recommends that data is used to validate the model for these engines. Ford will provide detailed written comments on this subject once we have fully evaluated the model and will continue to cooperate with EPA and NHTSA requests for data to support the refinement of the GEM model. Finally, Ford recognizes the benefits for the country of continuing a uniform National Program to address greenhouse gases and fuel efficiency from medium and heavy-duty vehicles . The EPA and NHTSA Phase 1 proposal was the first step to providing the clarity, certainty and flexibility necessary to achieve the aggressive greenhouse gas emissions reduction goals that we all share. The proposed Phase 2 builds and expands on this progress , setting challenging targets for industry for the next decade. Once again , Ford appreciates the opportunity to provide our testimony on this important rulemaking. We

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### are continuing to revi ew all of the technical aspects of the proposal and we plan to provide detailed written comments aimed at achieving and finalizing regulations consistent with the commitment that all parties have made to this national program . Thank you and I will be glad to take any questions.

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