# [

**c~ii>ce~ed** 

# Scientists

August 6, 2015 u csusa. o r g Two Brattle Square, Cambridge, MA 02138-3780 t 617.547.5552 f 617.864.9405 1825 K Street NW, Suite 800, Wash ington, DC 20006- 1232 t 202.223.6133 f 202.223.6162 500 12th Street, S uit e 340, Oak la nd , CA 94607-4087 t 510.843. 1 872 f 5 1 0
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### Th e Union of Concerned Scientists is the nat ion's l ead i ng science-based nonprofit, putting r igoro u s, independent science to work to so lve our planet's mo st pressing problems. On be h alf ofUCS's more than 450,000 supporters and network of nearly 17,000 sc ientists , eng inee rs , and publi c health profe ss ion a ls, I would like to thank EPA and NHTSA for their continued efforts to reduce fu e l u se b y and global warming em iss ions from heavy-d uty truck s . Th ese vehicles are r espo nsible for a significant and grow i ng fract ion of fue l u se and globa l war min g em iss ions. Le ft u nc hecked, they would undermine efforts throughout other sectors to red uce foss il fuel u se and its imp act on the environment. T his proposal provid es an opportunity to impro ve upon the first phase of fuel eco nomy and em issio ns regulation s in this sector to continue to r ed uce the impact of this cr it ical part of the economy. UCS has prov ided input throughout th is rulemaking process, and we wi ll contin u e to do so to ensure that these regu lations are based on the best avai lable science. Our analys is of the technologies that could be cost- effectively applied over th e next decade i indicates that th e ave ra ge fuel consumption from new trucks in 2025 could be reduced by 40 percent, compn r ed to tru cks so ld in 2010
. The age nc ies' proposal of a 36 percent improvement by 2027 fa ll s we ll short of what th is ana l ysis i ndicates is po ss ible. Whi l e EPA and NH T SA have certain ly put forth a tremendous ef fort to write a rule based on up-to-date data , there are nonetheless still many aspects of the rule that s hould be improved. F i rs t and f oremo st, wait ing u nti l 2027 to f u lly imp l ement the level of str i nge ncy that the agenc ies hav e proposed is unn ecessary. Ther e is amp le evidence that the technologies needed to comply with the str ingency in the proposed alternative are e ith e r in the marketp lace now or could be well before 2024. Data from the publicprivate SuperTruck partnersh ip and i ndependent organizat ions like the Nat iona l Academ i es' Nat i ona l Rese arch Counc il and the Southw est Research In s t itute , as we ll as discussions with b oth s uppliers and manufacturers, hav e all s upported our target of 40 percent by 2025. Based on th is analysis, we recommend that the agencies accept Alternative 4, which wo u ld end i n 2024, as th is path is much more consistent with the

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### tra j ecto ry of the indu st ry to-date and what m anufacturers ar e capabl e of ac hieving
. The age nci es s hould not ex te nd th e t i meline of the rul e out to 2027-2029 w ithout using this additional lead-time to increase technology adoption and improve technology effectiveness significantly beyond what is currently in the proposed a l ternative. Th e re ar e a lso spec ifi c ar eas where we b e li eve th e ru le does not re fl ect th e techno logy a lready a nticip ated ove r the coming decade
. Most n otab ly, the agenc ies h ave l eft sign ifi cant improvements o n th e table for C lass 8 tractor eng in es . Th e 4.2 

### percent i mprovement in effic iency ove r a 10 year span is dramatically lower than the pace of improveme nts already ac hi eve d b y manufactu r ers under the Pha se 1 

### standards, a nd it does n ot reflect th e leve l of improv e me nt a lready bein g ac hi eve d in manuf acturers ' R&D projects. This h as resu lted in an extremel y conse r vative engine standard, o n e which is roughly two to three times lower than what could be accomp li shed by 2027
. While the engine test cycle has been improved to more accurately reflect the real world duty cycle of these e n g in es, the e ngin e standard i tse l f sign ifi ca ntly undermines th e r eal world sav in gs th at s h o uld be expected from tractor-tr ail e rs in the timef r ame of this rule. Another area of the proposed standards that needs furt h er adjustment are the regulator·y targets for vocatio n al ve hi c les . T he age nc ies hav e i mproved the i r c h aracterization of this sec tor b y more accurate l y captur in g th e d i ve rse d uty cycles of these ve hicle s. T hey have a lso made powertra in testing an integra l p art of the regulat ion, w hi ch will help capture the im proved efficiency o f a better integrated engine a nd transm ission. An d lastly, the agencies have created a new pa th way for secondary manufacturers to p articip ate in the regulations through the "de l egated asse mbl y'' provi sio n , which will increase the flexibility fo r both prim a r y a n d seco nd a r y manufactu re r s, includin g th e small , inn ova tive manufacturers a lready se lli ng vocational hybrids today
. Despite these improvements to the vocat iona l veh i cle framework, the proposed target does n ot r eflect th e fu ll range of im p rovements ava il able to these veh i c les. The age nc ies h ave underestimated the fuel r e duction potential of both conve nti o n a l technologies like advanced transm issions and aerodynamic devices and more advanced technologies l ike hybrid and electric vehicles
. Thi s h as resulted in a vocational veh icl e standa rd that is sign ifi cantly weaker than what can be ac hi eved b y 2027-such a sta nd a rd will not he lp dr ive technology investment , n o r w ill it expand th e offerin g o f ef

fi c ie nt ve h icles f or the fl eets that need th e m. As in the case of tr actor engines, the agencies ap p ear 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 it s assessmen t o f gasol ine engines for pick-ups and vocatio n a l ve hi c les . Ac hi eving a 40 percent improvement b y 2025 would save an add itional200,000 barre ls of oil per day in 2035 compared to the proposed rule. It wou ld also bend th e cu r ve on e missions b e low t oday's le ve ls in sp ite of future increases in goods moveme nt vi a truck. ;; That is the l eve l of advancement we wo uld expect th is regu lation to achieve
. We will conti nue to engage w i th the agen ci es to provide furth e r data t o strengthen the rule and ens ure we ca n ac hi eve the maximu m tec hn o logica ll y f eas ible, cost-effective reduct ions i n this sector . Thank yo u ,

D ave Cooke Veh icles Analyst Union of Concerned Scient ists

i 

### Kha n , S
. , D.W. Cooke, a nd L . Ton ac h el. 2015. Fue l savin gs ava il abl e in new h eavy- du ty trucks in 2025
. Transportatio n Research Board p ape r 15- 4977
. Presented at the 94th a nnu a l meeting of the Tran sporta tion Resea rch Board , J a nu ar y 11

- 15 ,20 15. Wash in gton, DC. ii 

### Uni o n of Concerned Scientists. 20 15. New ly propos e d h eavy- duty truck effic iency s t andards for 20 1 8

- 2029. On lin e at 

### httpjjwww.ucsusa . org!s ites/default/fi l es/attach/20 15 /07/p r oposed

h eavy -du ty -veh icles-sta ndard s .

pdf, accesse d Ju ly 29, 2015.H A L F THE O I L SO LUTI O N : HEAV Y- DUTY T R U CK EFFIC I EN CY 

# Newly Proposed Heavy- Duty 

# Truck Efficiency Standards 

# for 2018-2029 Co nun erc ia l t ruck s cou ld 

# us e lessfue l and sa v e bill i on s Heavy-d u ty tru cks -ranging from tracto r - tr ailers and garbage trucks to de liv e ry vans and ltu·g e pickups

- m ake up ju st 7 percent of vehicles on th e road, but use more than 25 percent of the f u el. And with projected in creases in freight vo l ume, th at numbe r is like ly to g row. The Obama adm ini stration h as proposed new rules governing th e fue l effic iency and global warmin g em issions of the se ve hicl es that bui l d on an earl ier r o und of sta nd a rd s ( 2014-2018)
. This is the most comprehensive effort yet to reduce the fuel usc and g lobal warming e mi ss io n s of co mm c rcin l tru cks an d , if adopted, w ill h e lp improve up o n technologies already in the marketplace. savin g truckers fuel a nd reducing costs for consumers . H owever, UCS a na lysis shows th a t se ttin g hi gh er ta r ge ts th a n those propos ed i s feas ibl e 

### Prop ose d Standards W o uld Save Billi on s o f Gallon s of Oil , But 

### We Could Save Even M o re

'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 barre l s of o i l per day 120 MMT of g l oba l warming em i ss i ons 24-37% 25 % 16% 750.000 barrels of oil per day 160 MMT of global warmmg emiss1ons AII classes o f heavy-d uty v ehicl es ca n b e im proved in th e coming years. Our analysis indicates that th e se nucks could deliver more savin gs than the go1•ernment 'sproposed standards require, in a shorter time. NO TE : Sav1 n gs 1n 2035 and p ercent 1mprovemert a re c o m pared w .t h bus 1 ness as usua l
. represe n ted by t h e g o vernment's
.. more oy n am• c .. base l one. T h e 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 ond1c at e d fferent levels of fuel consumptoon r eduCt i Ons for d offerent ty p es of veh1cl e s w tn•n a pa rt i cu l ar c l as s. M'1T = ,....1 I 1J o n me:nc ton s. SOURCrS FP;\ ANO No• fSA 201!>. KIIA"- COOKL. ANO

**ror-.A(;H~l** 7015 and could del iver e ve n g r eat er savings, so oner (see th e tab le). 

### R

educing O il Consumption, Global Warming Em i ssions, and Consumers' Expenses Th e costs of fuel used by commercial trucks are i ncluded in the p ri ce of goo ds w e pu r c ha se (UCS 20 15)
. By shielding owners o f truck fl eets from volatile oil prices
. the proposed medium- and h eavy-du ty vehicle globa l warming emissions and fuel economr s t a ndards for mod e l yea rs (MY) 20 18 th rou gh 2029 wo uld reduce cos t s for b u s ines ses and , by extension, all consumers . According to Environ me ntal Protection Agency ( EPA ) esti mat es, these sta nd a rd s w ou ld, i f fin Ji ized : • Reduce oi l consu mpt i on by 550,000 barrels of oil per day in 2035-t h at's about half the oil the United States im ports fro m S a u di Arab ia daily (EIA 2015) • Avoid I b illi on m etric ton s of g lob a l warming emissions over the li fetime of the trucks covered by the ru le-rough ly equ ivale n t to the em iss ions crented by powe rin g a ll U.S. homes for one year (EPA 2015 ) • Save truckers more than $160 billion over the length of the ru le, eve n wh en fac toring in the additional upfront cost of imp r oved truck tec h nologies 

## • Reduce toxic air pollution from idling trucks and refi n e ri es lhat produce fuel. r esultin g i n an additional $37 b illi on in h ealth and w e l fare benefits. including reductions in mortality and h o spitalizati o ns 

### Th e Proposed Standards for MY2018

- 2029 : An Overview T h e proposed regulations cover three classes of vehicles: tractor-trailers ( or •·big rigs'' ) , vocat ional veh i cl e s ( a div e rs e catego ry that includ es deliv ery vans, buses, garbnge trucks, nnd u t il i ty tru c ks) , and h envy - duty picku p trucks a n d cargo vans. Th e standards fo r each vehicle class are set in discrete steps , with the s trongest leve l of impr ove ment occurring in 2027 ; h oweve r, th e ru le ru n s throu g h 2029 and wou ld prevent requirin g fu rth er improvement unti l at least 2030.TRACTOR-TRA IL ERS Tractor
- trailers are the biggest guzzlers of fuel on the road, averagingjust about s ix miles per gallon. By 2027 , the proposed standards would require tractors to become 18 to 24 percen t more efficient than under the earlier standards, depending on

**rr~1ctor** rype. Trai lers were not regu lated under the fir s t 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 app ly to standard box van trailers and wou ld result in an additionall2 percent fuel savings by 2027 for tractor-trailers, while other trailers li ke Oatbeds and rankers would be required to improve 4 percent.
VOCATIONAL VEHICLES Vocational vehicles are the broadest class of heavy-dury vehicles. b u t are subdiv id ed into just three categories in the ret,ru lations, depending on how th ey are used: urban vehi c l es, multi-purpose vehicl e s , and regional vehicles. The proposed rule wou ld require improvements in all categories, yielding a 12 to 16 percent improvement over the previ ous regulations.
HEAVY DUTY PICKUPS AND CARGO VANS Pickup tru cks and cargo vans with a weight rating (incl udin g payload) of greater than 8 , 500 pounds (e.g, Ford F-250 Super
Duty) are also considered heavy-dury vehicles. VVh ile the standards for these vehicles fal l well short of the improvements expected in their light-duty counterparts, heavy-dury pickups and cargo vans would nevertheless be required to redu ce fuel cons umption 16 percent beyond th e ea rli e r r eg ulatio ns. 

### 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 wou ld require a 36 percent reduct i o n in fuel consumptio n from new heavy-dury veh i cles by 2027 (co m p ared 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 dem o nstrated (ACEEE et al. 2014)
. So not only are the government's proposed tar gets less stringent th an ours, but they are a lso two years slower than what our analysis in dicates is both cost-effective and technically feasible. Th e proposal also fails to capture the full suite of cos t effective technologies available for each vehicle cb ss . F o r example, greater aerodynamic improvements are possible for trailers. and powertrain techno logies for tractors and vocational veh ic les th at have already been id ent ifi ed by the government could be deployed much more broadly. 

### There's No Reason Not to Do Better Th e h eavy-duty vehicle standards as proposed by the EPA and the Nationa l Highway Traffi c Safety Administration are an imp o rt ant step in the right direction , but the urgent need for climate action makes it critica l that the agencies act to reduce oil consumption and global warming emissions from this sector as quickly as technology an d cost considerations will allow. UCS analysis shows that the technologies availuble to achieve a 40 percent redu ct ion i n fuel consumpt ion can be incorp orated into new trucks by 2025, rather than waiting until 2027. Doing so would save an additiona l 200,000 barrels of oil per day in 2035 , and avoid an additional 4 0 million metric tons of global warming emissions annually

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

# [ cgJ!lceined Scientists

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