[ c~ii>ce~ed Scientists 

August 6, 2015 

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The Union of Concerned Scientists is the nation's leading science-based nonprofit, 

putting rigorous, independent science to work to solve our planet's most pressing 

problems. On behalf ofUCS's more than 450,000 supporters and network of nearly 

17,000 scientists, engineers, and public health professionals, I would like to thank EPA 

and NHTSA for their continued efforts to reduce fuel use by and global warming 

emissions from heavy-duty trucks. These vehicles are responsible for a significant and 

growing fraction of fuel use and globa l warming emissions. Le ft unchecked, they 

would undermine efforts throughout other sectors to reduce fossil fuel use and its 

impact on the environment. This proposal provides an opportunity to improve upon 

the first phase of fuel economy and emissions regulations in this sector to continue to 

reduce the impact of this critical part of the economy. 

UCS has provided input throughout this rulemaking process, and we will continue to 

do so to ensure that these regulations are based on the best available science. Our 

analysis of the technologies that could be cost-effectively applied over the next decadei 

indicates that the average fuel consumption from new trucks in 2025 could be reduced 

by 40 percent, compnred to trucks sold in 2010. The agenc ies' proposal of a 36 percent 

improvement by 2027 fa lls well short of what this ana lysis indicates is possible. While 

EPA and NHTSA have certainly put forth a tremendous effort to write a rule based on 

up-to-date data, there are nonetheless still many aspects of the rule that should be 

improved. 

First and foremost, waiting until 2027 to fully implement the level of stringency that 

the agencies have proposed is unnecessary. There is ample evidence that the 

technologies needed to comply with the stringency in the proposed alternative are 

either in the marketplace now or could be well before 2024. Data from the publicprivate SuperTruck partnership and independent organizations like the National 

Academies' National Research Counc il and the Southwest Research Institute, as well as 

discussions with both suppliers and manufacturers, have all supported our target of 40 

percent by 2025. Based on this analysis, we recommend that the agencies accept 

Alternative 4, which would end in 2024, as this path is much more consistent with the 

n •. :_,._~ ..,_ tnn., --··-- ... ,..,,...,. .... --·-la.A .,.,._r 
trajectory of the industry to-date and what manufacturers are capable of achieving. 

The agencies should not extend the timeline of the rule out to 2027-2029 without using 

this additional lead-time to increase technology adoption and improve technology 

effectiveness significantly beyond what is currently in the proposed alternative. 

There are also spec ifi c areas where we beli eve the rule does not reflect the technology 

already anticipated over the coming decade. Most notably, the agenc ies have left 

significant improvements on the table for Class 8 tractor engines. The 4.2 percent 

improvement in efficiency over a 10 year span is dramatically lower than the pace of 

improvements already achieved by manufacturers under the Phase 1 standards, and it 

does not reflect the level of improvement already being achieved in manufacturers' 

R&D projects. This has resulted in an extremely conservative engine standard, one 

which is roughly two to three times lower than what could be accomplished by 2027. 

While the engine test cycle has been improved to more accurately reflect the real world 

duty cycle of these engines, the engine standard itself significantly undermines the real 

world savings that should be expected from tractor-trailers in the timeframe of this 

rule. 

Another area of the proposed standards that needs further adjustment are the 

regulator·y targets for vocational vehicles. The agencies have improved their 

characterization of this sector by more accurately capturing the diverse duty cycles of 

these vehicles. They have also made powertrain testing an integral part of the 

regulation, which will help capture the improved efficiency of a better integrated 

engine and transmission. And lastly, the agencies have created a new pathway for 

secondary manufacturers to participate in the regulations through the "delegated 

assembly'' provision, which will increase the flexibility for both primary and secondary 

manufacturers, including the small, innovative manufacturers already selli ng 

vocational hybrids today. 

Despite these improvements to the vocational vehicle framework, the proposed target 

does not reflect the fu ll range of improvements avail able to these vehicles. The 

agencies have underestimated the fuel reduction potential of both conventional 

technologies like advanced transmissions and aerodynamic devices and more advanced 

technologies like hybrid and electric vehicles. This has resulted in a vocational vehicle 

standard that is signifi cantly weaker than what can be achieved by 2027-such a 

standard will not help drive technology investment, nor will it expand the offering of 

effi cient vehicles for the fleets that need them. As in the case of tractor engines, the 

agencies appear to be lagging what the industry is already on track to accomplish. 
There are many other areas in which UCS believes the rule can be improved, including 

trailer aerodynamics, its treatment of natura l gas, and its assessment of gasoline 

engines for pick-ups and vocational vehicles. Achieving a 40 percent improvement by 

2025 would save an additional200,000 barrels of oil per day in 2035 compared to the 

proposed rule. It would also bend the curve on emissions below today's levels in spite 

of future increases in goods movement via truck.;; That is the level of advancement we 

would expect this regulation to achieve. 

We will continue to engage with the agencies to provide further data to strengthen the 

rule and ensure we can achieve the maximum technologically feasible, cost-effective 

reductions in this sector. Thank you, 

Dave Cooke 

Vehicles Analyst 

Union of Concerned Scientists 

i Khan, S., D.W. Cooke, and L. Tonachel. 2015. Fuel savings available in new heavy-duty trucks 

in 2025. Transportation Research Board paper 15-4977. Presented at the 94th annual meeting of 

the Transportation Research Board, J anuary 11- 15,2015. Wash ington, DC. 

ii Union of Concerned Scientists. 2015. Newly proposed heavy-duty truck efficiency standards 

for 2018- 2029. Online at http jjwww.ucsusa.org!sites/default/files/attach/2015/07/proposedheavy-duty-vehicles-standards.pdf, accessed July 29, 2015. 

H A L F THE O I L SO LUTI O N: 

HEAV Y- DUTY T RU CK EFFIC I EN CY 

Newly Proposed Heavy-Duty 

Truck Efficiency Standards for 

2018-2029 

Conunercial trucks could use less fue l and save billions 

Heavy-duty trucks-ranging from tractor-trailers and garbage 

trucks to delive ry vans and ltu·ge pickups- make up just 7 

percent of vehicles on the road, but use more than 25 percent of 

the fuel. And with projected increases in freight volume, that 

number is like ly to grow. 

The Obama administration has proposed new rules 

governing the fuel efficiency and global warming emissions of 

these vehicles that build on an earlier round of standards 

(2014-2018). This is the most comprehensive effort yet to 

reduce the fuel usc and global warming emissions of 

commcrcinl trucks and, if adopted, will help improve upon 

technologies already in the marketplace. saving truckers fuel 

and reducing costs for consumers. However, UCS analysis 

shows that setting higher ta rgets than those proposed is feasible 

Proposed Standards Would Save Billions of Gallons of 

Oil, But We Could Save Even More 

'01/) Q)'E 

Ill 10 

O-o 

O.c 

0 10 ......... 

Q.(/) 

%Reduction 

in 2027 

Savings in 

2035 

%Reduction 

in 2025 

Savings in 

2035 

21-33% 12-16% 16% 

550,000 barrels of oil per day 

120 MMT of g lobal warming emissions 

24-37% 25% 16% 

750.000 barrels of oil per day 

160 MMT of global warmmg emiss1ons 

A II classes of heavy-duty vehicles can be improved in the coming years. 

Our analysis indicates that these nucks could deliver more savings than 

the go1•ernment's proposed standards require, in a shorter time. 

NOTE: Sav1ngs 1n 2035 and percent 1mprovemert are compared w.th bus1ness as 

usual. represented by the government's .. more oynam•c .. baselone. The proposed 

s:anda•ds would ac..,•eve a 36 percent reductoon on new truck fuel co'lsumptoor 

compared woth 2010. the UCS a~>alysos "oulo acr eve a ~0 oerce'lt red.;Ct•on. 

Rarges ond1cate d fferent levels of fuel consumptoon reduCtiOns for dofferent 

types of veh1cles w tn•n a particular class. M'1T = ,....1I1Jon me:nc tons. 

SOURCrS FP;\ ANO No• fSA 201!>. KIIA"- COOKL. ANO ror-.A(;H~l 7015 

and could del iver eve n greater savings, sooner (see the table). 

Reducing Oil Consumption, Global Warming 

Emissions, and Consumers' Expenses 

The costs of fuel used by commercial trucks are included in the 

price of goods we pu rchase (UCS 2015). By shielding owners of 

truck fleets from volatile oil prices. the proposed medium- and 

heavy-duty vehicle global warming emissions and fuel economr 

standards for model years (MY) 2018 th rough 2029 would 

reduce costs for businesses and, by extension, all consumers. 

According to Environme ntal Protection Agency (EPA) 

estimates, these standa rds wou ld, if fin Ji ized: 

• Reduce oil consumption by 550,000 barrels of oil per 

day in 2035-that's about half the oil the United States 

imports from Saudi Arabia daily (EIA 2015) 

• Avoid I billion metric tons of global warming 

emissions over the lifetime of the trucks covered by the 

ru le-rough ly equivale nt to the emissions crented by 

powering all U.S. homes for one year (EPA 2015) 

• Save truckers more than $160 billion over the length of 

the rule, even when fac toring in the additional upfront cost of improved truck technologies 

• Reduce toxic air pollution from idling trucks and 

refineries lhat produce fuel. resulting in an additional 

$37 billion in health and welfare benefits. including 

reductions in mortality and hospitalizations 

The Proposed Standards for MY2018- 2029: An 

Overview 

The proposed regulations cover three classes of vehicles: 

tractor-trailers (or •·big rigs''), vocational vehicles (a dive rse 

category that includes delivery vans, buses, garbnge trucks, nnd 

utility trucks), and henvy-duty pickup trucks and cargo vans. 

The standards for each vehicle class are set in discrete 

steps, with the strongest level of improvement occurring in 

2027; however, the rule runs through 2029 and would prevent 

requiring fu rther improvement until at least 2030. 
TRACTOR-TRAILERS 

Tractor-trailers are the biggest guzzlers of fuel on the road, 

averaging just about six miles per gallon. By 2027, the proposed 

standards would require tractors to become 18 to 24 percent 

more efficient than under the earlier standards, depending on 

rr~1ctor rype. 

Trailers were not regu lated under the first round of 

standards, but are included in the proposed rule. Improving 

trailer tires and reducing the aerodynamic drag of trailers will 

have big benefits for fuel economy and emission reductions 

(UCS 2014). The proposed standards would apply to standard 

box van trailers and would result in an additionall2 percent 

fuel savings by 2027 for tractor-trailers, while other trailers like 

Oatbeds and rankers would be required to improve 4 percent. 

VOCATIONAL VEHICLES 

Vocational vehicles are the broadest class of heavy-dury 

vehicles. but are subdivided into just three categories in the 

ret,rulations, depending on how they are used: urban vehicles, 

multi-purpose vehicles, and regional vehicles. The proposed 

rule would require improvements in all categories, yielding a 12 

to 16 percent improvement over the previous regulations. 

HEAVY DUTY PICKUPS AND CARGO VANS 

Pickup trucks and cargo vans with a weight rating (including 

payload) of greater than 8,500 pounds (e.g, Ford F -250 SuperDuty) are also considered heavy-dury vehicles. VVhile the 

standards for these vehicles fall well short of the improvements 

expected in their light-duty counterparts, heavy-dury pickups 

and cargo vans would nevertheless be required to reduce fuel 

consumption 16 percent beyond the earlier regulations. 

The Standard Should Be Strengthened to Achieve 

40 Percent Fuel Savings by 2025 

The administration's proposal builds strongly on the first round 

of standards that were issued in 20 II, but there is still room for 

improvement. Where the proposed standards would require a 

36 percent reduction in fuel consumption from new heavy-dury 

veh icles by 2027 (compared with 2010 levels), UCS <1nalysis 

reveals that the average fue l consumption from new trucks 

could be reduced br 40 percent by 2025 using cost-effective 

technologies that are currently being deployed or demonstrated 

(ACEEE et al. 2014). So not only are the government's proposed 

targets less stringent than ours, but they are also two years 

slower than what our analysis indicates is both cost-effective 

and technically feasible. 

The proposal also fails to capture the full suite of costeffective technologies available for each vehicle cbss. For 

example, greater aerodynamic improvements are possible for 

trailers. and powertrain technologies for tractors and vocational 

vehicles that have already been identified by the government 

could be deployed much more broadly. 

There's No Reason Not to Do Better 

The heavy-duty vehicle standards as proposed by the EPA and 

the National Highway Traffic Safety Administration are an 

important step in the right direction, but the urgent need for 

climate action makes it critical that the agencies act to reduce 

oil consumption and global warming emissions from this sector 

as quickly as technology and cost considerations will allow. 

UCS analysis shows that the technologies availuble to 

achieve a 40 percent reduction in fuel consumption can be 

incorporated into new trucks by 2025, rather than waiting until 

2027. Doing so would save an additional 200,000 barrels of oil 

per day in 2035, and avoid an additional 40 million metric tons 

of global warming emissions annually- equivalent to shutting 

down 12 coal-fired power plants (f:PA n.d.). 

[ cgJ!lceined Scientists F",lllll~ HII y Rt·:HIU:\ .1 'I·.!<Sitl:'\0:'\1.1:'\ www.ucsusa.org/truckefftctency 

The Union of Concerned Scll!ntists puts rigorous, independent sciena to work to_ solt·c ou~ planet's _most pressing problems. Jormng ~ith citizen~ across the 

country, we combine technical a11alysis and effective advocacy ro create mnovatrve, practrcal solutrons for a healthy, safe, and sustar11able futttr~ 

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