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, 2015 
Good 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 engines and vehicles. Moreover, 

we commend the agencies for working closely with the California Air Resources Board 

in developing these proposed standards. 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 sustainability plan. 

Since the Phase 1 Heavy Duty Greenhouse Gas requirements were promulgated, Ford 

introduced a whole new line of full sized vans called "Transit", which feature fuel 

efficient V6 and turbocharged gasoline engines as well as a five cylinder 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 billions of dollars over the next five years to introduce technologies that 

improve fuel economy and reduce the 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 fuel 

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 challenging 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 external 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 

years 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: 

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• Recognize the needs of the 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 review 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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