Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 1 1 ENVIRONMENTAL PROTECTION AGENCY and 2 NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION 3 NATIONAL PUBLIC HEARING ON GREENHOUSE GAS EMISSIONSAND 4 FUEL EFFICIENCY STANDARDS FOR MEDIUM- AND HEAVY-DUTY 5 ENGINES AND VEHICLES - PHASE 2 6 7 8 9 10 11 Tuesday, August 18, 2015 12 9:04 a.m. 13 14 15 16 17 18 Westin Hotel, Long Beach 19 333 East Ocean Boulevard 20 Salon C and D 21 Long Beach, California 22Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 2 1 PARTICIPANTS 2 EPA/NHTSA MEMBERS: 3 KRISTIN AMERLING, DOT, Co-Presiding Officer 4 CHRISTOPHER GRUNDLER, EPA, Co-Presiding Officer 5 BILL CHARMLEY, EPA 6 RYAN HAGEN, NHTSA 7 RYAN POSTEN, NHTSA 8 STEVEN E. SILVERMAN, EPA 9 AMY ZIMPFER, EPA, Region 9 10 11 PANEL 1: 12 MARY NICHOLS, California Air Resources Board 13 14 PANEL 2: 15 GRACE NAPOLITANO, Congresswoman 16 17 PANEL 3: 18 BARRY WALLERSTEIN, South Coast Air Quality Manageme nt 19 District 20 BEN SHARPE, International Council of Clean 21 Transportation 22 MIKE O'CONNELL, PepsiCoPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 3 1 PARTICIPANTS (CONTINUED) 2 PANEL 3 (CONTINUED): 3 BRIAN MORMINO, Cummins, Inc. 4 HENRY HOGO, NACAA 5 NICK JILES, Office of California Senator Ricardo La ra 6 7 PANEL 4: 8 TIMOTHY A. BLUBAUGH, Truck and Engine Manufacturers 9 Association 10 JORGE RODRIGUEZ, BlueGreen Alliance 11 STEVE BERRY, DAVID KAYES, DAVID MAJORS, DANIEL KIEF FER, 12 Volvo/Daimler Trucks North America/Navistar, 13 Inc./PACCAR 14 JIM STEWART, Sierra Club 15 16 PANEL 5: 17 HILARY SINNAMON, Environmental Defense Fund 18 JASON WYNNE, Pew Charitable Trusts 19 DOUG CORCORAN, Waste Management 20 ALLIS DRUFFEL, California Interfaith Power & Light 21 TOM FULKS, Diesel Technology Forum 22 DON ANAIR, Union of Concerned ScientistsPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 4 1 PARTICIPANTS (CONTINUED) 2 PANEL 6: 3 BARBARA KISS, General Motors 4 JEFFREY BENNETT, Citizen 5 GARY OSHNOCK, FCA US LLC 6 MATT SOLOMON, NESCAUM 7 DIANE HART, Citizen 8 WILL BARRETT, American Lung Association in Californ ia 9 10 PANEL 7: 11 BILL VAN AMBURG, CALSTART 12 CYNTHIA WILLIAMS, Ford Motor Company 13 MICHELLE KINMAN, Environment California Research an d 14 Policy Center/Environment America Research and 15 Policy Center 16 URVI NAGRANI, Motiv Power Systems 17 JONATHAN FLECK, ADF Limited 18 19 PANEL 8: 20 RAYMOND C. WILLIAMS, NAFA Fleet Management Associat ion 21 JOSHUA GOLDMAN, TransPower 22 TILDEN CURL, Tecco Trucking, Inc.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 5 1 PARTICIPANTS (CONTINUED) 2 PANEL 8 (CONTINUED): 3 JESSE PRENTICE-DUNN, Sierra Club 4 LEIGH MERINO, Motor and Equipment Manufacturers 5 Association 6 DARYL GALE, Citizen 7 KIRSTEN JAMES, Ceres 8 KIRSTEN JAMES, Dignity Health 9 10 PANEL 9: 11 RASTO BREZNY, Manufacturers of Emission Controls 12 Association 13 NIDIA ERCEG, Coalition for Clean Air/California Cle aner 14 Freight Coalition 15 PAUL McNAMARA, Utility Trailer Manufacturing Compan y 16 DOUGLAS MacLAUGHLIN, Citizen and Union of Concerned 17 Scientists 18 ANDY SWANTON, BYD Motors 19 DAVID FINK, Climate Resolve 20 21 PANEL 10: 22 JACK GILLIS, Consumer Federation of AmericaPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 6 1 PARTICIPANTS (CONTINUED) 2 PANEL 10 (CONTINUED): 3 EDWARD LOVELACE, XL Hybrids 4 CHARLES IRVIN DREW, Union of Concerned Scientists 5 BRETT BARRY, Clean Energy Fuels 6 DENNIS RODRIGUEZ, Siemens Corporation 7 ROB CADLE, Honeywell International 8 KEVIN GOLSCH, Exa Corporation 9 DOROTHY KELTY, Union of Concerned Scientists 10 11 PANEL 11: 12 JOSEPH McLAUGHLIN, Citizen 13 JEFFREY GROSSMAN, STEMCO 14 GORDON TAYLOR, Citizen 15 LARRY FROMM, Achates Power 16 MONA SHETH, Advanced Engine Systems Institute 17 BENOIT LACROIX, Effenco 18 LOLA UNGAR, League of Women Voters/ League of Women 19 Voters of Los Angeles County 20 BILL DALE, Union of Concerned Scientists 21 22Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 7 1 PARTICIPANTS (CONTINUED) 2 PANEL 12: 3 ABAS GOODARZI, U.S. Hybrid Corporation 4 JOHN REED, North American Repower 5 JEFFREY RABIN, Citizen 6 7 PANEL 13: 8 LAWRENCE LITVAK, Citizen 9 10 11 12 13 14 15 16 17 18 19 20 21 22Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 8 1 P R O C E E D I N G S 2 MS. ZIMPFER: Good morning. Thank you very mu ch 3 for being here. My name is Amy Zimpfer. I am an 4 associate director of the U.S. Environmental Protec tion 5 Agency's Southwest region, region 9. And I have 6 responsibilities for clean energy and climate chang e. 7 On behalf of Jerry Blumenfeld -- he is our 8 regional administrator of U.S. EPA's Pacific-Southwest 9 region -- I would like to welcome you to today's public 10 hearing on the proposed greenhouse gas emissions an d 11 fuel efficiency standards for medium- and heavy-dut y 12 engines and vehicles. It is very fitting that this 13 hearing is being held here today in Long Beach. 14 California is a national leader on climate change 15 policy development and innovative technology. The 16 state has a long track record of supporting vehicle 17 technology advancement as a means for reducing 18 emissions that contribute to California and to the 19 nation's daunting air quality challenges. 20 The proposed rule is the second phase of EPA a nd 21 the Department of Transportation's National Highway 22 Traffic Safety Administration's joint program toPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 9 1 regulate the greenhouse gas emissions and fuel 2 efficiency of heavy-duty engines and vehicles. As with 3 Phase 1, this proposed rule provides an opportunityto 4 spur the development and deployment of cost-effecti ve 5 technologies that will help to reduce heavy-duty on

6 highway vehicle emissions. 7 I am very pleased to see you all here today. And 8 I look forward to listening to your comments and ideas 9 on this important joint federal rulemaking. 10 It is now my pleasure to introduce our very 11 distinguished presiding officers: Mr. Christopher 12 Grundler and Ms. Kristin Amerling. They have joine d us 13 from Washington, D.C. to hear your comments firstha nd. 14 Mr. Grundler is the director of the U.S. EPA's Offi ce 15 of Transportation and Air Quality. Ms. Amerling is the 16 Deputy General Counsel at the U.S. Department of 17 Transportation. 18 So, with that, I would now like to turn to Mr. 19 Grundler and Ms. Amerling to give their introductor y 20 remarks. Thank you. 21 MR. GRUNDLER: Thank you very much, Amy. 22 We are delighted to be here in Long Beach. Le t mePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 10 1 add my welcome. We are thrilled that so many peopl e 2 from very different organizations and citizens have 3 taken time today to come, tell us what they think o f 4 our proposal. 5 Chairing these public hearings is I consider o ne 6 of the most important parts of my job. It is an ho nor 7 to do these hearings and to hear directly from peop le 8 what they think of decisions that their government is 9 making. So this is a very important responsibilityand 10 very humbling responsibility. We are here to liste n, 11 and we are very pleased to be here. 12 On July 13th, EPA and the NHTSA proposed the 13 second phase of our joint program to regulate the 14 greenhouse gas emissions and fuel economy of heavy- duty 15 engines and vehicles. This proposal, which EPA has 16 proposed under the Clean Air Act and NHTSA has prop osed 17 under the Energy Independence and Security Act, is an 18 important part of the President's kind of action pl an 19 to address the challenges of global climate change and 20 energy security. The agencies worked together to 21 propose a line standard so that manufacturers can b uild 22 a single fleet that complies with both standards. ForPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 11 1 over two years now, our agencies have conducted 2 extensive testing and research and have worked with 3 industry states and many of you to develop these 4 ambitious, yet achievable, standards that we believe 5 encourage the deployment of advanced cost-effective 6 technologies to reduce both fuel consumption and 7 greenhouse gas emissions. 8 The environmental and economic benefits of thi s 9 proposal are substantial. The standards, as propos ed, 10 would cut greenhouse gas emissions by a billion met ric 11 tons, conserve up to 1.8 billion barrels of oil, an d 12 save vehicle owners fuel costs of about $170 billio n 13 over the lifetime of the vehicles sold. 14 This proposal will also represent an opportuni ty 15 to spur innovation in the clean energy technology 16 sector in this country, creating opportunities for job 17 growth, promoting a new generation of cleaner, more 18 efficient trucks. 19 EPA and NHTSA worked hard to ensure that standards 20 are harmonized between our two agencies. And the 21 agencies have also worked very closely with the Sta te 22 of California's Air Resources Board from day one inPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 12 1 developing the proposed standards. 2 This second phase of our program is designed t o 3 allow manufacturers to continue to build a national 4 fleet, as I noted, that satisfies all requirements 5 under EPA's and NHTSA's programs and would help to 6 address the greenhouse gas reduction goals of 7 California and other states well into the next deca de. 8 Although we have put a great deal of work into our 9 proposal, these phase 2 proposed standards are just 10 that. They are proposed standards. 11 We encourage and welcome feedback from 12 stakeholders and the public to help us craft a fina l 13 program that will achieve significant fuel savings and 14 emission reductions while ensuring the heavy-duty 15 industry will continue to meet the diverse needs ofour 16 transportation sector. 17 Today's hearing is being held to allow interes ted 18 parties to provide us with comments on this proposa l in 19 person. There is also an opportunity for anyone to 20 send us written comments. And we encouraged you todo 21 so. The written comment period will close Septembe r 22 17th. To find out how to submit these writtenPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 13 1 comments, you should go to our websites. And copie s of 2 those instructions are also available outside at th e 3 reception table. We expect to take final action on 4 this proposal sometime next spring. 5 Now I would like to introduce our other panel 6 members sitting with me and then outline how today' s 7 hearing will be conducted. With me today from EPA is 8 Bill Charmley, the director of our Standards Divisi on, 9 sitting to my left; Steve Silverman from our Officeof 10 General Counsel and sitting next to Amy; Amy, who h as 11 introduced herself, from our Air Division in San 12 Francisco. Representing the Department of 13 Transportation is Kristin Amerling, the Deputy Gene ral 14 Counsel; Ryan Posten, the Associate Administrator f or 15 Rulemaking, at the end of the table; and Ryan Hagen , 16 sitting next to Ryan, from NHTSA's Office of the Ch ief 17 Counsel. 18 We will be conducting this hearing informally, and 19 formal rules of evidence do not apply. The presidi ng 20 officers, however, are authorized to strike stateme nts 21 from the record that are deemed irrelevant or 22 needlessly repetitious and to enforce reasonable li mitsPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 14 1 on the duration of the statement of any witness. 2 Today's hearing is scheduled to run until abou t 6: 3 00 p.m., but we will be here as long as it takes to 4 allow everyone who wants to testify to do so. We w ill 5 be using panels to speed up the process. The list of 6 preregistered panel members and their order is prov ided 7 with the agenda at the reception table. We will be 8 updating that as we go along up on the screen here. We 9 ask that each person keep their testimony to five 10 minutes or less. If anyone here wishing to testifyhas 11 not already signed up, please do so outside at the 12 table. Whether or not you testify, we would like 13 everyone attending to please sign in. 14 And when all of the witnesses on the panel have 15 finished, those of us on the government panel will have 16 an opportunity to ask questions. We plan to go thr ough 17 the first five panels before breaking for lunch. We 18 will begin the afternoon session with panel 6 at 1: 30 19 p.m. 20 Again, after today, if any speaker wishes to make 21 any corrections to their remarks for the record, pl ease 22 submit those corrections to EPA or NHTSA within 30Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 15 1 days. 2 I have one final announcement before turning i t 3 over to my colleague from DOT. We would like to 4 provide additional notice regarding a proposed chan ge 5 to the engine testing regulations in 40 CFR 1036.50 1(g) 6 that would require the exclusion of any work performed 7 by the engine during any idle portion of the duty c ycle 8 when calculating total engine work. This proposed 9 change was included in the proposed regulatory textbut 10 not highlighted in the preamble. This change has t he 11 potential to impact the effective stringency of the 12 engine standards. 13 For gasoline engines, this means that the 14 effective stringency could increase without a chang e to 15 the numerical stringency of the gasoline engine 16 standard. So to ensure that commenters have adequa te 17 opportunity to comment on this issue, we are placin g 18 into the docket for this rulemaking a memorandum 19 providing additional detail on this proposed change . I 20 believe it has already been submitted to the docket . 21 So commenters interested in the gasoline engine 22 standards are encouraged to read this memo and prov idePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 16 1 comments on the change along with other comments onthe 2 rule. 3 At this time, I would like to ask Ms. Amerlingto 4 give her introductory remarks. Welcome. 5 MS. AMERLING: Thank you. And good morning, 6 everyone. On behalf of the Department of 7 Transportation and its operating administration, th e 8 National Highway Traffic Safety Administration, or 9 NHTSA, I want to thank you for taking the time toda y to 10 come and provide comments and take time out of your 11 busy schedules to do so. 12 This hearing follows our joint hearing on Augu st 6 13 in Chicago, where we heard from dozens of commenter s. 14 And we welcome continued public input today and 15 throughout the comment period. 16 NHTSA and the Department of Transportation, weare 17 proud to work with our partners at EPA to develop a 18 joint proposal for the second phase of greenhouse g as 19 emissions and fuel efficiency standards. Our goal is 20 to build on the successful phase 1 standards for 21 vehicle model years 2014 through 2018. The propose d 22 phase 2 fuel efficiency and greenhouse gas emission sPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 17 1 standards would cover model years 2021 through 2027 and 2 beyond and apply to semi trucks, large pickup truck s 3 and vans, and all types and sizes of buses and work 4 trucks. For the first time, standards would apply to 5 most heavy-duty trailers. EPA trailer standards wo uld 6 start in model year 2018 while NHTSA trailer standa rds 7 would be mandatory beginning in 2021. The agencies are 8 committed to the goal of setting a single set of 9 national standards that are cost-effective for 10 consumers and businesses and deliver favorable payb ack 11 periods for truck owners. 12 EPA and NHTSA jointly issued several documents 13 related to the notice of proposed rulemaking. They 14 included a preamble and draft regulatory impact 15 analysis. These documents describe the proposed 16 regulations and supporting information and analysis 17 related to the proposal. 18 In addition, on June 19th, NHTSA published a d raft 19 environmental impact statement for the proposed NHT SA 20 fuel efficiency regulations. The draft EIS compare s 21 the environmental impacts of the proposed fuel 22 efficiency regulations with those of a number ofPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 18 1 regulatory alternatives. Today's hearing provides 2 opportunity for the public to comment on both the 3 notice of proposed rulemaking documents and NHTSA's 4 draft environmental impact statement. 5 Please note that while the comment period for the 6 notice of proposed rulemaking closes September 17th , 7 the comment period for the draft environmental impa ct 8 statement will close on August 31st. Feedback from 9 stakeholders and the public helps us best craft a f inal 10 program for the country. Your input is important t o 11 us, and we look forward to hearing what you have to 12 say. 13 A few procedural notes before we call the firs t 14 panel. I would like to ask that each panelist plea se 15 state his or her name and affiliation and please sp eak 16 slowly and clearly so our court reporter can record 17 these proceedings accurately. 18 Also, to assist in running the hearing 19 efficiently, we will be using a light timer. We ar e 20 asking commenters to limit comments to five minutes so 21 that everyone has the opportunity to speak. The gr een 22 light will turn on when you begin your testimony. ThePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 19 1 yellow light will come on at four minutes. And thered 2 light will turn on after five minutes. 3 To get people smoothly to the front table duri ng 4 panel changes, we have arranged a staging area for the 5 second panel after announcing the first panel, we w ill 6 invite the second panelists to come over to the sta ging 7 chairs. 8 At this time, I will turn things back over to Mr. 9 Grundler. 10 MR. GRUNDLER: It is my distinct honor to welc ome 11 our first speaker: the Honorable Mary Nichols, cha ir 12 of the California Air Resources Board and distingui shed 13 alumna of the Environmental Protection Agency. 14 Welcome, Mary. 15 MS. NICHOLS: Thank you so much, distinguished 16 panel and, if I may say so, colleagues. I also wan t to 17 thank Congresswoman Grace Napolitano, who is here, for 18 graciously allowing me to be the first panelist as I 19 rush out for the next engagement. 20 So, if I may, I am Mary Nichols, the chair of the 21 California Air Resources Board, and I really apprec iate 22 the opportunity to present California's input on th ePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 20 1 proposed phase 2 greenhouse gas rules for medium an d 2 heavy-duty vehicles. As you know, ARB staff 3 coordinated closely with both EPA and NHTSA for nea rly 4 two years to help develop the technical analyses th at 5 inform this proposal. We have much appreciated the se 6 opportunities to work with our federal agency partn ers 7 to establish strong national standards to drive down 8 greenhouse gas emissions and position the United St ates 9 at the forefront of efforts to address global clima te 10 change, an issue that President Obama has rightly made 11 a top priority. 12 Nationally, the proposed phase 2 standards are 13 expected to save over 77 billion gallons of fuel an d 14 cut CO2 emissions by over 1 billion metric tons, 15 helping to stabilize the climate and to reduce our 16 reliance on foreign oil. This is a good start. 17 Since the release of the proposal, ARB's team of 18 scientists and engineers has been carefully evaluat ing 19 the technical details of the proposal to assess its 20 stringency and ability to maximize greenhouse gas 21 reductions. ARB's team is currently midway througha 22 deep technical dive. And we will be submitting mor ePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 21 1 comprehensive final comments by the mid September 2 deadline. So my comments here today are based on o ur 3 assessment to date. 4 First of all, California commends the signific ant 5 effort put towards the development of this proposal . 6 And we want to be sure to emphasize that this is an 7 important step forward that in many ways builds on the 8 success of the current phase 1 standards. The 9 proposal, however, misses some critical opportuniti es 10 to reduce greenhouse gas emissions further to save 11 fuel, save fleets money, and spur development of 12 advance, low, and zero-emission technologies. 13 Earlier this month, EPA demonstrated its globa l 14 leadership in addressing climate change with the 15 announcement of the clean power plan. My hope is t hat 16 the phase 2 standards can be strengthened as the fi nal 17 rule is put forward to stand as another shining example 18 of U.S. leadership in the fight against climate cha nge. 19 Let me get a little bit more specific. 20 In our assessment so far, we have identified 21 several areas where we believe the proposed emissio ns 22 standard should be strengthened or accelerated. Fi rst,Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 22 1 we think you should adopt alternative 4 in order to 2 deliver carbon dioxide reductions earlier. Califor nia 3 strongly recommends the adoption of alternative 4, 4 rather than the proposed alternative 3. While the 2 5 alternatives are nearly identical in terms of 6 technological feasibility and payback periods for f uel7 efficient technologies, alternative 4 accelerates f ull 8 program phase-in by 3 years, from 2027 to 2024. Wi th 9 an earlier phase-in of the final standards, the pro gram 10 will deliver emissions reductions sooner and will 11 accelerate the development of carbon-reducing 12 technologies, including moving us more rapidly towa rds 13 zero-emissions technologies that will be needed to meet 14 mid- and long-term climate targets. In addition, a n 15 earlier implementation date will allow for more timely 16 action to pursue a mandatory lower NOx engine standard 17 nationally. Addressing NOx from these trucks with a 18 third of our state's nitrogen oxide emissions as 19 quickly as possible is absolutely critical for 20 California to meet our federal ozone attainment 21 obligations. 22 On a nationwide basis, alternative 4 would save 10Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 23 1 billion more gallons of fuel and provide about 130 more 2 million metric tons of CO2 reductions by 2030 than 3 alternative 3. In California, alternative 4 would 4 provide about 4 million metric tons more CO2 benefi t by 5 2030 than alternative 3. And phase 1 and phase 2 6 together would reduce petroleum use from the mediumand 7 heavy-duty sectors in 2030 by about 22 percent, a very 8 important step towards reaching Governor Brown's 9 mandate that we achieve a 50 percent petroleum 10 reduction goal for the transportation sector. And, 11 yet, still it is not enough. Let me, then, move onto 12 the next significant area for improvement. 13 We urge you to increase the stringency of the 14 proposal via tighter engine-only standards and 15 consideration of all commercially viable technology 16 improvements. The proposed phase 2 tractor and 17 vocational engine standards are expected to achieve 18 only a modest 4 percent fuel efficiency improvement 19 beyond what the current phase 1 program requires. 20 California recommends that EPA increase the engine 21 standard stringency in conjunction with a correspon ding 22 increase in the whole vehicle standards to levels t hatPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 24 1 capitalize on the full emissions reduction potentia l of 2 efficiency-improving technologies. Recent work by the 3 Southwest Research Institute and others, including 4 Cummins, the largest manufacturer of heavy-duty tru ck 5 engines, all indicate the feasibility of engine CO2 6 reductions in the phase 2 timeframe at levels more than 7 twice what EPA is proposing. 8 ARB's formal comments on phase 2 will propose a 9 stronger standard stringency as well as additional 10 opportunities to tighten the proposed standards via 11 consideration of technology available today. 12 I am going to shorten this a little bit becaus e I 13 can see I am taking longer than I probably should. 14 So our third main point is we would like for y ou 15 to include a greater reliance on advanced technolog ies, 16 like fuel cells and electric vehicles. Deployment of 17 low and zero-emission and other advanced technologi es 18 is the foundation of California's pathway to achiev ing 19 our climate and air quality goals. And we believe it 20 should be a part of the national strategy to meet m id 21 and long-term greenhouse gas reduction targets. 22 Unfortunately, the phase 2 proposal is not sufficie ntlyPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 25 1 stringent to drive market development of hybrid, 2 electric, or fuel cell technologies. For example, the 3 proposal assumes only a modest level of hybrid 4 technology and no significant level of electronic o r 5 fuel cell technology. 6 The proposal also eliminates the advanced 7 technology credits that were included in the phase 1 8 program that were intended to encourage the use of 9 zero-emission technologies. Without any significan t 10 reliance on advanced technologies built into the 11 proposed standards, we estimate that projected 12 increases in truck activity will completely overtake 13 projected CO2 reductions around 2043, resulting in CO2 14 emissions levels from medium- and heavy-duty trucks in 15 2050 that are about 6 percent higher than 2010 leve ls. 16 To actually offset the expected growth in activity, 17 advanced near-zero-emission technologies must be a 18 significant part of the long-term solution. 19 We also urge you to commit in this final 20 rulemaking to beginning at least the development of 21 lower mandatory NOx standards for heavy-duty engine s 22 and vehicles.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 26 1 So I am just going to close by saying that 2 California is fully committed to working with you t o 3 developing a strong national program to reduce 4 greenhouse gas emissions. We will continue to work 5 with our partners at EPA and NHTSA and with other 6 interested stakeholders to make this rule as effect ive 7 as possible at rapidly slashing climate pollution i n 8 all cost-effective ways. 9 And I also would be remiss if I did not point out 10 that while we know that a goal of this rulemaking i s to 11 continue to have one rule that is applicable to all 12 heavy-duty engines and vehicles, that California in 13 looking ahead towards our role in reducing greenhou se 14 gas emissions and facing our unique air pollution 15 challenges must always consider the possibility of an 16 additional California-only program element or eleme nts 17 as we look to the future. 18 So, once again, thank you very much for your w ork. 19 We look forward to continuing this effort. And I w ill 20 be happy to answer any questions if you have any. 21 MR. GRUNDLER: Thank you so much, Chairwoman 22 Nichols.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 27 1 Any questions from the panel? 2 MR. SILVERMAN: Just one. With regard to fuel 3 cell technology, is it CARB's position that should, the 4 standard should, actually be predicated on use of t hose 5 technologies in this timeframe? 6 MS. NICHOLS: We do believe that you have 7 overlooked the opportunity to recognize the advance s 8 that have been made in these technologies and to 9 include in the baseline, if you will, for your 10 consideration, yes. 11 MR. SILVERMAN: Okay. We hope written comment s 12 can pin down how that is feasible. 13 MS. NICHOLS: We will further address this mor e 14 specifically in our written comments, absolutely. 15 Thank you. 16 MR. GRUNDLER: Ms. Nichols, before you leave, I do 17 have an additional not question but request. You n oted 18 in your testimony the work going on at Southwest onthe 19 low NOx engine technology. If the technical staff 20 could provide the results of that work to date as p art 21 of the comments, that would be very useful for us i n 22 considering further action on NOx.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 28 1 MS. NICHOLS: We will be happy to do that. 2 MR. GRUNDLER: Thank you so much for your time . 3 Now I would like to invite the Honorable 4 Congresswoman Napolitano from the great State of 5 California to share her comments. And while 6 Congresswoman Napolitano is making her way up, if I 7 could ask the next panel, panel 3, to gather at the 8 staging area along the wall? Thank you. 9 MS. NAPOLITANO: Thank you so very much for 10 allowing me to come in and be part of this. I am 11 Congresswoman Grace Flores Napolitano from the 32nd 12 Congressional District. And I am the California 13 ranking member on the Transportation Committee in 14 Washington, D.C. So I am on three subcommittees, which 15 was Highway, Rail, and Water. And this is one of t he 16 most important things for us in California, as far as I 17 am concerned. 18 Thank you very much to EPA and DOT for holding 19 these hearings. This is the first one I have been able 20 to listen to. I may not be able to stay very long, but 21 I certainly am very glad to hear that you are goingto 22 be here until everybody is heard from. That isPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 29 1 critical in any of our outreach. 2 My district has a major impact of traffic. I have 3 the Alameda Corridor East, and I also have the truc k 4 traffic of the 60 freeway, the 10 freeway, the 210 5 freeway, all along the corridor that I represent. So 6 you understand I have a great passion for ensuring that 7 we continue to move forward with the help of all ofthe 8 state, federal, county agencies to reduce the emiss ions 9 because whatever happens here at the ports or anywh ere 10 in California creates an environment sometimes thatis 11 hazardous to elderly and to children and those who have 12 health problems. Sometimes I think I am included i n 13 that. 14 But I want to be sure that I let you know thatI 15 have been on this issue with truck emissions back s ince 16 the '90s, when there was a state assembly, when we 17 started a program with a Pico Rivera firm, a truck 18 firm, to be able to convert engines to more lower 19 emission-driven. 20 So it is something that I have very criticallyin 21 mind. I will work with my colleagues. I will work 22 with all of the agencies that I need to. But I wou ldPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 30 1 like to make a couple of comments in listening to y our 2 presentations but also to Mary Nichols, whom I have 3 known for many years. I do support the rule, but I do 4 request that EPA and DOT seriously consider the 5 proposal to reduce flow consumption in new trucks b y 40 6 percent by the year 2025. 7 You know, we in Washington have fought the ide a of 8 climate change. I had my colleagues tell me there is 9 no such thing. Well, unfortunately, we have to 10 seriously understand that we have issues that we ar e 11 going to have to continue to address. And one of t hem, 12 of course, is how does that affect our area? Also, do 13 we work with academia? Do we work with the experts 14 when we get input on fuel cell technology, on findi ngs 15 that researchers have done? 16 And one of the concerns that I have had in wat er, 17 which is my other big issue, is, how are we not ope ning 18 the door for information that will help us maybe lo ok 19 at new technology? And how do we help those that a re 20 unable financially to be able to convert or to purc hase 21 the new trucks? When I visited a truck company in my 22 district, it was about a $40,000 difference in thePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 31 1 purchase of new vehicles that had lower emissions. So 2 the funding, how do we establish a bank, low-cost 3 interest, that can help those that are unable to doit? 4 So there are other areas that we need to actually b e 5 more -- how would I say? -- verbal on so that peopl e 6 understand we are just not trying to put in new reg s 7 but also that we are trying to help them achieve th e 8 importance of that reduction. 9 I do look forward to having a look at the comments 10 during this period -- I understand it is going to b e 11 through September -- that we will continue to addre ss, 12 my colleagues in other states that sometimes look t o 13 California. California has been the leader for man y, 14 many years. And we want to continue to ensure thatwe 15 help other states understand that it is their probl em, 16 too, not just Californians. We have led the way. It 17 is the bellwether for many other states. And we hope 18 that we will continue to help our companies, our owners 19 to be able to be successful in reaching it. This i s a 20 partnership that we must enter into totally and tha t we 21 are able to recognize what that means to the air we 22 breathe and the environment that we all live in andPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 32 1 what our future for our children, our grandchildren , 2 our great-grandchildren -- I already have five -- i s, 3 what are we leaving for them. 4 So, with that, I look forward to maybe connect ing 5 a little later with you and finding out what some o f 6 these comments have brought forth and how we can he lp 7 in Washington bring it before the agencies, my 8 colleagues who sit on those committees that look over 9 the agencies, and how we can be more informed and 10 educated on the issue. 11 So I thank you. You have a great day. And I look 12 forward to listening to some of the testimony. ButI 13 do have other commitments. And I will be leaving a 14 little later. Thank you so very much. 15 Any questions? 16 MR. GRUNDLER: Thank you so much, Congresswoma n. 17 And thank you for your time and reminding us why weare 18 doing this work. Thank you very much. 19 MS. NAPOLITANO: My pleasure. Thank you. And 20 have a great day. 21 (Applause.) 22 MR. GRUNDLER: I would like to invite panel 3 toPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 33 1 the stage. Panel 3 is comprised of the Honorable D r. 2 Barry Wallerstein from the South Coast Air Quality 3 Management District, the executive officer; from th e 4 International Council of Clean Transportation, Ben 5 Sharpe; from PepsiCo, Mike O'Connell; Brian Mormino 6 from Cummins; Henry Hogo, who is representing NACAAin 7 his capacity here today; and Nick Jiles from the 8 California State legislature. Welcome. Dr. 9 Wallerstein, you may proceed when you are ready. 10 MR. WALLERSTEIN: Good morning. As noted, I am 11 Dr. Barry Wallerstein. I serve as the executive 12 officer of the South Coast Air Quality Management 13 District, which is home to about 17 million Souther n 14 Californians, about 5 percent of all Americans, or if 15 you took our geographic area and you ranked it withthe 16 states of the United States, we would be the fifth most 17 populous state. So, as I think is pretty well-known, 18 our region is also home to some of the nation's wor st 19 air pollution problems, especially relative to ozon e or 20 summertime smog and particulates. Our district, fo r 21 example, has already exceeded the current federal o zone 22 standard 59 days this year. And by the time our smogPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 34 1 season ends, it will probably be 90 to 100 days. 2 It is well-established that climate change wil l 3 cause immense environmental and public health impac ts. 4 And we applaud the administration for pursuing a 5 variety of initiatives to help address greenhouse g as 6 emissions. But it is also well-established that 7 climate change would actually exacerbate, make wors e, 8 our local air quality problems, such as surface-level 9 ozone and particulate. 10 Therefore, looking at the whole of what you ar e 11 doing here in this rulemaking, we are very supporti ve 12 of the effort to establish new phase 2 greenhouse g as 13 emissions and fuel efficiency standards for heavy-duty 14 vehicles and engines. We believe that the tighter 15 standards are necessary and, as has already been no ted, 16 are technologically feasible and cost-effective and 17 will also provide, as indicated in your regulatory 18 package, some but limited criteria pollutant 19 co-benefits. 20 Moreover, we support EPA and NHTSA finalizing this 21 rulemaking quickly. And, consistent with the comme nts 22 of NACAA and the California Air Resources Board. I nPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 35 1 essence, our agency is in complete technical agreement 2 that the package can be strengthened in its final f orm 3 as you move forward. 4 Henry Hogo of my staff will be presenting the 5 NACAA comments in this regard in a few minutes. An d 6 our agency fully supports those comments on behalf of 7 the National Association of Clean Air Agencies. 8 Finally -- and I want to get to an important p oint 9 that Chairman Nichols made -- it is very important to 10 note that this rulemaking missed a major opportunit y to 11 help with clean air in Southern California and 12 elsewhere around the nation, specifically establish ing 13 a formal tightening of the federal heavy-duty engin e 14 and vehicle NOx standard. We think that could have 15 been done as part of this effort. Obviously, it 16 wasn't. And so where we are today is to request, a s 17 CARB did, that EPA move forward with a heavy-duty 18 vehicle NOx standard tightening. 19 And it is important to note that heavy-duty 20 vehicles are our largest source of NOx emissions inthe 21 region and that technology exists today that would 22 allow a tightening of the standard. And, frankly, asPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 36 1 we all meet here today, there are improvements bein g 2 made to that technology that we believe would allowEPA 3 to establish a standard at least at the near zero4 emission level of 0.02 grams per brake horsepower h our. 5 Given that the greater Los Angeles area must 6 reduce NOx emissions by more than 50 percent beyondall 7 federal, state, and local regulations within the ne xt 7 8 to 8 years to meet several federal clean air standa rds, 9 we think it is an absolute must that EPA do its fai r 10 share of this effort if attainment is to be achieve d. 11 And the single most important thing that EPA could do 12 would be to tighten the NOx standard. 13 Therefore, as stated by Chairman Nichols, 14 independent of preparation of my comments, we are a lso 15 asking that you initiate -- and in our case, we are 16 asking that you do this immediately -- a parallel 17 rulemaking to this one that will lower the heavy-du ty 18 truck NOx standard and that EPA commit to such acti on 19 in the final regulatory package for this proceeding . 20 Such action will help save literally thousands of l ives 21 annually in the South Coast district and will save 22 thousands of lives elsewhere in the nation. It wou ldPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 37 1 also give Southern California a chance at complianc e 2 with the current Clean Air Act requirements as we 3 proceed to implement the current SIP and prepare a 4 revision to the SIP in 2016. 5 So I want to thank you again for being here to day 6 and for giving me the opportunity to testify. 7 MR. GRUNDLER: Thank you so much, Barry. 8 Mr. Sharpe, proceed. 9 MR. SHARPE: Good morning, and thank you for t he 10 opportunity to provide remarks on this very importa nt 11 rulemaking. 12 I am Ben Sharpe with the International Councilon 13 Clean Transportation. We are a research organizati on 14 that is focused on providing technical information to 15 support government decision-making on policies, wri te 16 these phase 2 regulations for leading vehicle marke ts 17 around the globe. I will make brief comments for t he 18 ICCT about market conditions, the maximum feasible 19 technology and its timing, and international 20 implications related to these rules. 21 First, market conditions in the U.S. freight 22 trucking industry are preventing the uptake of allPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 38 1 available cost-effective technologies. There are 2 substantial market barriers that impede the uptake of 3 efficiency technology. And this regulation would h elp 4 solve such problems. 5 Regarding the agency's analysis on available a nd 6 emergency efficiency technologies, we continue to b e 7 very grateful for the extensive information sharingand 8 dedicated time from EPA and NHTSA staff. The agenc y's 9 work ethic, transparency, and public process are 10 exemplary. The agencies have undoubtedly made a ru le 11 based on rigorous state-of-the-art technology input s 12 from sound data and industry input. 13 Based on several new technical ICCT research 14 studies, I will make brief remarks on the timing ofthe 15 technology deployment as well as on full technology 16 potential, especially in the engine area. In the 17 agency's analysis, the rule is largely predicated o n 18 well-understood, highly cost-effective technologies . 19 The technologies in the engine, power train, 20 aerodynamic, and tire areas are exactly the ones th at 21 suppliers and vehicle manufacturers have been 22 discussing for the rules timeframe.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 39 1 The trailer technologies embrace the emerging 2 technologies that have already been spurred by EPA' s 3 SmartWay program and California's end-use greenhous e 4 gas regulation. Due to the agency's decision to re ly 5 primarily on proven, available, and cost-effective 6 technologies, the agencies can shift the standards 7 three years earlier from 2027, as proposed, forwardto 8 2024. This would still allow sufficient lead time for 9 the manufacturers and truck buyers to gradually 10 incorporate the bulk of all the technologies into t heir 11 operations over the next nine years. 12 We have noted several areas where the agencies do 13 not fully incorporate maximum feasible technology 14 levels. One area is in engines. The agency has 15 proposed to reduce the tractor diesel engine fuel u se 16 by 4 percent from 2017 to 2027. Available technolo gies 17 with payback periods comfortably less than 2 years can 18 reduce new diesel tractor engine fuel use fleet-wide by 19 up to 10 percent from 2017 to 2027 based on our own 20 technical analysis and the research literature. 21 With higher technology penetration rates for U .S. 22 DOE SuperTruck technologies, the standards could goPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 40 1 further yet. In addition, the proposed heavy-duty 2 pickup and van in the proposed heavy-duty pickup an d 3 van as well as gasoline efficiency, standards appea r to 4 fall significantly short in their promotion of the full 5 technology potential. With these two factors, 6 incorporating something closer to the maximum feasi ble 7 technology potential and advancing the timing of th e 8 rule, there is a lot at stake. Based on our analys is, 9 incrementally advancing the timing and modestly 10 increasing the efficiency technology could result i n 30 11 percent greater climate benefits and over 300,000 12 barrels worth of oil savings per day by 2040. Maki ng 13 such changes would be the equivalent of taking 13 14 million 30 mile-per-gallon cars off the road. 15 Finally, this rulemaking is key in establishin g 16 the U.S. as a global leader on freight truck 17 technology. The Governments of Canada, China, Europe, 18 India, Japan, Mexico, and others are considering th eir 19 next policy actions to similarly ensure greater 20 efficiency technology deployment for trucks. The w orld 21 is watching and potentially looking to adopt simila r 22 policy.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 41 1 We provide references to the leading technical 2 research that supports these statements. And we wi ll, 3 of course, elaborate on the points and submit all n ew 4 analysis in our detailed comments to the docket. 5 Again, we thank the agencies for their exempla ry 6 public service. 7 MR. GRUNDLER: Thank you so much, Mr. Sharpe. 8 Mr. O'Connell, welcome. 9 MR. O'CONNELL: Good morning. My name is Mike 10 O'Connell. I am the senior director of fleet 11 operations for Frito Lay North America, a division of 12 PepsiCo. On behalf of PepsiCo, I would like to fir st 13 thank the EPA and NHTSA for the opportunity to test ify 14 today. 15 At PepsiCo, one of the largest fleet operators in 16 the United States, we have seen benefits, both 17 economically and environmentally, that are possible 18 when you take a leadership role and embrace fleet 19 sustainability. We believe that strong phase 2 20 standards will further enhance these efforts. 21 At PepsiCo, we believe that companies that emb ed 22 sustainable business practices into the fabric of t heirPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 42 1 organizations will rise to the top. We call it 2 performance with purpose. And it includes our 3 commitment to finding innovative ways to reduce our 4 impact on the environment, which can also reduce ou r 5 operating costs. The phase 2 standards are in line 6 with this mission. And when combined with a holist ic 7 approach to fleet management, almost certainly we w ill 8 have a positive impact on the fuel efficiency of ou r 9 fleet. 10 That said, we do not believe there is a silver 11 bullet or one simple solution in the quest for over all 12 fuel efficiency and reduction of CO2 emissions. We 13 know that we will continue to rely on different 14 technologies and processes to achieve overall fuel 15 efficiency. At PepsiCo, we have applied different 16 fuels, hybrids, electric vehicles, lightweighting, GPS, 17 and aerodynamics to reduce fuel consumption. Our 18 people are also one of the most important component s in 19 helping drive better fuel performance. Driver trai ning 20 and better maintenance programs also help make our 21 fleet more fuel-efficient. 22 In our opinion, the standards are balanced. T hePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 43 1 EPA and NHTSA have done an excellent job of 2 incorporating feedback from multiple stakeholders, 3 including manufacturers, fleet operators, private 4 operators, and environmental NGOs. Importantly, th ese 5 standards incorporate a realistic view of the fuel 6 economy landscape and the challenges posed by both 7 manufacturers and operators and, most importantly, be 8 informed by known technology and not assumptions. 9 The EPA and NHTSA's approach to evaluate curre nt 10 and future technology adoption into the heavy-duty 11 truck industry with an average two-year payback is a 12 fair assumption and creates a standard built on fac ts 13 and grounded in logic. 14 As in the past, PepsiCo believes that it is 15 important to complement these standards with financ ial 16 incentives to help organizations implement new 17 technologies and alternate fuel strategies. 18 For example, previous incentives help our Frit o 19 Lay North America division build one of the largest 20 private electric fleets in the United States. We 21 believe that additional financial incentives will s pur 22 future opportunities and increase implementation an dPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 44 1 innovation of fuel-saving technologies. For the pa st 2 ten years, we have been an early adopter of alterna te 3 fuel options, including CNG, electric, and propane. We 4 take our leadership role in fleet sustainability 5 standards seriously and partner with government 6 agencies and NGOs, such as the EPA SmartWay program , 7 CALSTART, Pew Charitable Trusts, BSR's future of fu els, 8 Alternative Clean Transportation, the National Clea n 9 Fleets Partnership, and the North American Council for 10 Freight Efficiency. We expect to continue to buildon 11 these partnerships to further collaboration, learn and 12 support shared goals of reducing greenhouse gas fue l 13 consumption. 14 Overall, we recognize and understand that 15 sustainable business practices can lead to innovati on, 16 operational excellence, and business growth. Furth er, 17 we view sustainability as a strength and competitive 18 advantage by aligning these initiatives were greate r 19 efficiency, productivity, and cost savings that canbe 20 reinvested back into our business. 21 On behalf of PepsiCo, I thank you for this 22 opportunity to testify today and look forward to th ePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 45 1 continued efforts to deliver an aggressive, yet 2 balanced rule. Thank you. 3 MR. GRUNDLER: Thank you, Mr. O'Connell. 4 Mr. Mormino, welcome. 5 MR. MORMINO: Thank you. Thank you for the 6 opportunity to testify on the phase 2 proposal. My 7 name is Brian Mormino, and I am the executive direc tor 8 of Worldwide Environmental Strategy and Compliance at 9 Cummins. 10 Cummins thanks EPA and NHTSA for leading an op en 11 and collaborative process. We appreciate the 12 opportunity over the past three and a half years to 13 provide extensive policy and technical input to the 14 agencies and to work closely with a wide range of 15 stakeholders, including the heavy-duty fuel efficie ncy 16 leadership group, which Mike and Pepsi are also a p art 17 of. It is in that spirit of collaboration that I s peak 18 today on key aspects of the proposal. 19 Cummins supports the goal of the phase 2 propo sal 20 to reduce greenhouse gas emissions and fuel 21 consumption. This is an area where our customer 22 interests are directly aligned since lower CO2 fromPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 46 1 heavy-duty engines and vehicles means fuel savings. 2 The proposed regulatory structure of separate engin e 3 and vehicle standards delivers on these important 4 economic and environmental benefits. 5 As outlined in the preamble, a separate engine 6 standard offers a robust, clearly defined complianc e 7 program, requires manufacturers to optimize CO2 and 8 criteria pollutants together and provides the only 9 measure of engine fuel consumption and CO2 emission s 10 under transient conditions. The agencies declare t hese 11 and other advantages of separate engine standards a s 12 "fundamental to the success of the program." Cumm ins 13 wholeheartedly agrees, and, as you heard in Chicagoand 14 will hear today, so do many others. 15 Although the phase 1 regulatory structure of 16 separate engine and vehicle standards is retained f or 17 phase 2, a change in how the engine is characterize d in 18 the greenhouse gas emissions model, or GEM, drives more 19 interaction between the engine and vehicle programs . 20 The phase 2 proposal requires engine manufacturers to 21 both certify a steady-state engine fuel map and pro vide 22 the fuel map to vehicle manufacturers for use in th ePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 47 1 GEM vehicle certification process. This approach i s 2 very concerning because it requires Cummins to rele ase 3 proprietary and confidential business information i nto 4 the public domain. 5 Additionally, the steady-state fuel map is unable 6 to accurately represent engine performance today, a nd 7 it is likely to be even less accurate in the future . 8 Cummins urges the agencies to pursue the alternative 9 cycle average map approach, as described in the dra ft 10 regulatory impact analysis. 11 The cycle average map process is being evaluat ed 12 by EPA and our industry, and it is demonstrating 13 promising results. Additional testing and analysis is 14 planned, and Cummins is committed to continued supp ort 15 of these efforts. We urge the agencies to finalizethe 16 cycle average map approach in the final rule. 17 Another area of concern related to interaction s 18 between the engine and vehicle standards has to do with 19 implied engine stringency. It appears additional 20 engine CO2 reductions beyond the explicit engine 21 standards is assumed in the vehicle standards; for 22 example, associated with engine downspeeding. Cumm insPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 48 1 cautions the agencies against this approach. Impli cit 2 engine stringency in the vehicle program decouples 3 engine CO2 improvements from compliance with NOx 4 standards. This threatens the regulatory integrityof 5 the rule by creating a structure in which in-use NO x 6 emissions can be increased by operation outside 7 expected NOx regulatory limits while in-use CO2 8 emissions are reduced. Implied standards also lackthe 9 regulatory clarity required for focused and sustain ed 10 innovation and engine technology. For these reason s, 11 required engine CO2 reductions should be explicit i n 12 the engine standard. 13 As we consider the explicit levels of the prop osed 14 engine standards, our ability to comply is informedby 15 our experience with SuperTruck, a Cummins-Peterbilt 16 project in partnership with the Department of Energ y. 17 Forty percent of the fuel economy improvements 18 demonstrated in 2014 in our SuperTruck derives from 19 engine advancements and innovations which will be 20 making their way into production engines over the 21 timeframe of this rule. As a result, Cummins is 22 confident we have the engine technologies necessarytoPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 49 1 meet and exceed improvements required by the phase 2 2 engine standards. 3 Lead time and stability are also critical to 4 achieving the goals of the proposal. EPA and NHTSA 5 have proposed three steps of standards for engines and 6 vehicles - in 2021, 2024, and 2027. Cummins suppor ts 7 retaining this timeline for the final rule. The lo ng8 term certainty of knowing the required reductions 9 through 2027 benefits manufacturers, who need to invest 10 and develop and validate reliable fuel-savings 11 technologies; and the end-users, who will ultimatel y 12 depend on them in the market. 13 Finally, Cummins supports a consistent nationa l 14 program. One deviation from this area in the propo sed 15 rule is different standards for diesel and gasoline 16 engines. The agencies should move to CO2 standards 17 that are the same for all fuels, or fuel-neutral, 18 because it is necessary to ensure reductions are 19 achieved, regardless of the fuel or technology used . 20 It is also critical that EPA, NHTSA, and ARB a re 21 all aligned in addressing fuel efficiency and CO2 a s 22 well as NOx. EPA and ARB should work collaborative lyPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 50 1 with the goal of maintaining a national, heavy-dutyNOx 2 and greenhouse gas program. Cummins is committed t o 3 working with both agencies to determine the best pa th 4 for achieving real-world reductions. 5 We still have more work to do to fully underst and 6 the phase 2 proposal and we intend to submit detail ed 7 written comments. Cummins will work with the agenc ies 8 and other stakeholders to make sure both the 9 environment and our customers benefit from the fina l 10 rule. 11 Thank you again for the opportunity to provide 12 these comments and for leading such an open and 13 collaborative process. I look forward to addressin g 14 any questions. Thank you. 15 MR. GRUNDLER: Thank you very much. 16 Henry, welcome. Proceed. 17 MR. HOGO: Thank you. Good morning. I am Hen ry 18 Hogo, assistant deputy executive officer at the Sou th 19 Coast Air Quality Management District. I am here t his 20 morning on behalf of NACAA, the National Associatio n of 21 Clean Air Agencies, a national nonpartisan, nonprof it 22 association of air pollution control agencies in 41Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 51 1 states, the District of Columbia, 4 territories, an d 2 116 metropolitan areas. I appreciate this opportun ity 3 to provide the association's testimony on EPA's and 4 NHTSA's proposed phase 2 standards. 5 NACAA supported EPA's and NHTSA's efforts to a dopt 6 the first phase of greenhouse gas and fuel efficien cy 7 standards for heavy-duty vehicles and engines. Nowwe 8 are pleased to support your agency's efforts to adv ance 9 this program by establishing phase 2 standards. We 10 believe your proposal holds great promise for achie ving 11 further greenhouse gas reductions and better fuel 12 efficiency from heavy-duty combination tractors, 13 trailers, vocational vehicles, and heavy-duty pickups 14 and vans. Fulfilling that promise, however, will 15 require some key improvements to the proposal. 16 But before addressing those, NACAA would like to 17 commend EPA and NHTSA on several aspects of the 18 proposed rule that our association strongly support s. 19 First, we fully endorse the continued inclusion of 20 separate but complementary standards for engines an d 21 full vehicles. This is a fundamental aspect of the 22 rule.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 52 1 Second, the inclusion of standards for trailer s, 2 particularly box trailers, is critical given their 3 significant contribution to fuel consumption by lon g4 haul trucks. 5 Third, we are very much in favor of EPA's prop osal 6 to close the assisting loophole for glider kits, un der 7 which used pre-2013 engines may be installed into n ew 8 glider kits without meeting applicable standards. We 9 agree with EPA that its regulations should be revis ed 10 to require that only engines that have been certifi ed 11 to meet the prevailing standards be eligible for 12 installation into new glider kits. 13 Now I would like to highlight aspects of the r ule 14 NACAA believes should be improved. In a March 18, 2015 15 letter to your respective agencies, NACAA provided 16 recommendations for essential components of a phase2 17 rule. We urge for a rule that would reduce greenho use 18 gas emissions and fuel consumption across the entir e 19 fleet by at least 40 percent on average compared to 20 2010. Unfortunately, we find the overall effective ness 21 of the phase 2 proposal to fall short of our 22 recommendation and significantly short of what can andPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 53 1 should be achieved. Accordingly, we believe the 2 overall stringency of the proposal should be enhanc ed 3 to take advantage of missed opportunities that if 4 incorporated into the final rule would drive techno logy 5 and ensure that maximum benefits are gained. Towar d 6 this end, we believe the proposed engine standard must 7 be strengthened. 8 Others, including the California Air Resources 9 Board, engine makers, and independent nongovernment al 10 organizations, have suggested engine efficiency canbe 11 improved by 15 percent or more compared to the 4.2 12 percent proposed by EPA. Further, their analyses, as 13 well as those of EPA, indicate that technologies to 14 achieve this degree of improvement are currently 15 available and highly cost-effective. We believe itis 16 imperative that EPA strengthen the engine standard in 17 the final rule to reflect this. 18 We respect the timing. NACAA strongly support s 19 EPA proposal alternative 4, under which the standar ds 20 would be fully implemented by 2024. This 21 implementation deadline is entirely feasible and 22 vitally important to spur much needed near-termPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 54 1 emission reductions and technologies innovation. 2 Our March letter also included a recommendatio n 3 that EPA articulate in the proposal the need for 4 significantly lower national heavy-duty NOx standar ds. 5 We are very disappointed that EPA has not included such 6 a discussion in this proposal. Although there is t he 7 potential for ancillary NOx reduction from the phas e 2 8 rule, the achievement of these reductions is not 9 certain. Moreover, even if ancillary NOx benefits do 10 accrue under the phase 2 rule, they will not be nea rly 11 sufficient given the challenges state and local 12 agencies face in attaining and maintaining current and 13 upcoming ozone and fine particulate matter standard s 14 and reaching other environmental goals. 15 We urge that EPA include in the final phase 2 rule 16 a clear and comprehensive discussion of the need fo r 17 very substantial additional NOx reductions from heavy18 duty vehicles and engines and, even more critically , a 19 explicit commitment to begin immediately a separate 20 rulemaking initiating to capture those reductions. 21 In the coming weeks, NACAA will continue studyof 22 the phase 2 proposal and will offer additional commentsPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 55 1 by the September 17th deadline. In the meantime, we 2 appreciate the chance to provide comments today and 3 look forward to continuing to work with EPA and NHT SA 4 on this very important initiative. 5 MR. GRUNDLER: Thank you so much. 6 Mr. Jiles, welcome. 7 MR. JILES: Good morning. And welcome to the 8 beautiful City of Long Beach. You guys were actual ly 9 in our district, Fighting 33rd, which runs from the 10 Port of Long Beach all the way to the southeast Cit y of 11 Vernon. 12 My name is Nick Jiles. I am the district dire ctor 13 for State Senator Ricardo Lara. And I am going to be 14 reading a brief statement today on his behalf that 15 helps paint a picture of some of the health challen ges 16 that communities in our district face daily. 17 So the issue of clean air, clean fuels, and 18 achieving California's ambitious carbon reduction g oal 19 is one of our greatest priorities. Families livingin 20 the communities I represent can't wait any longer. 21 My Senate district is a large bubble of soot a nd 22 toxic air. It is home to refineries, the Port of L ongPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 56 1 Beach, rail yards, and the 710 freeway. On the 710 2 freeway alone, 25,000 heavy-duty trucks travel 3 alongside schools, day care centers, and neighborho ods. 4 In California, we understand that climate change is not 5 just an abstract concept but a public health crisis 6 that is disproportionately impacting our most 7 vulnerable communities, namely the poor and communi ties 8 of color. 9 Cancer clusters, asthma, and low birth weight, 10 these are consequences of poor air quality. And th ey 11 affect communities throughout California each day. For 12 example, if you live in the City of Commerce, you a re 13 140 percent more likely to contract cancer from die sel 14 soot, as opposed to other L.A. County residents. 15 Absentee notes for children suffering from asthma 16 attacks, from bronchitis are a daily occurrence in my 17 district. In fact, 1 in 11 children in L.A. County 18 suffer from asthma. 19 Last year, I worked on S.B. 1204 to incentiviz e 20 the development and deployment of clean technology for 21 heavy-duty trucks, buses, and off-road vehicles. I 22 want to commend the EPA and NHTSA for these propose dPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 57 1 standards that will reduce emissions and make truck s on 2 our roads more fuel-efficient. And these proposed 3 standards represent a significant step forward in o ur 4 efforts to reduce greenhouse gas emissions, but we can 5 do more. In fact, we must do more. 6 In order to meet our reduction goals, we must 7 invest in cleaner transportation technologies with a 8 technology-neutral approach that incentivizes 9 improvements in air quality along with reductions i n 10 greenhouse gases. We have made that commitment in 11 California, investing millions of cap and trade dol lars 12 to the development of clean truck technology. Howe ver, 13 we need an ambitious federal standard that compleme nts 14 and supports these efforts with stringent rules tha t 15 will be implemented as soon as possible. 16 Thank you for your time in allowing me to prov ide 17 brief testimony on behalf of the Senator. 18 MR. GRUNDLER: Thank you so much, panel. Let me 19 see if we have some questions. 20 MR. CHARMLEY: I had a question for Dr. 21 Wallerstein. Barry, so California and ARB is often 22 considered to be a leader and is a leader for advan cedPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 58 1 air pollution standards and regulations. And I thi nk 2 that many of us believe that the South Coast is at the 3 vanguard of that. And I had a question, a request and 4 a question. 5 One would be, the request would be, to the ext ent 6 that your staff over the last several years had lea rned 7 more about and helped support some of these very 8 advanced technologies, like EVs and fuel cells, and 9 PHEVs, in the vocational and commercial sector, any 10 information that you can provide about the experien ce 11 that you all have had with that, that would be very 12 helpful. 13 And my question for you is, above and beyond t he 14 level of the standard, do you or the South Coast st aff 15 have any recommendations for EPA and NHTSA about, i n 16 addition to the standards themselves, other incenti ves 17 that we can provide for spurring the very, very 18 advanced technologies, like EVs and fuel cells? An d do 19 you think that incentives are one way to do that 20 through the regulation or do you think primarily it 21 should be the level of the standard? 22 MR. WALLERSTEIN: First, let me say that when wePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 59 1 look at the issue of climate change and local air 2 pollution problems, including ozone particulate and 3 toxics, and we look at the array of technologies th at 4 are needed to address our local air quality problem s, 5 it is, in essence, the same technologies that are 6 needed to address climate change and GHG from vehic les 7 and engines. And so the programs really overlap. And 8 that is an important concept for everyone to keep i n 9 mind because the dollars invested aren't just for 10 greenhouse gas reduction purposes. If we do it right, 11 they get us to the solution to all of our local air 12 quality problems. 13 We also believe very strongly, as do our 14 colleagues at the state level, that it should be a 15 combination of regulations and incentives. And we 16 would applaud EPA for, for example, for the DERA 17 program. You have done a good job with the amount of 18 funds you have gotten. The problem is the amount o f 19 funds you have gotten is woefully inadequate. 20 At my agency alone, this year, we will provide 21 hundreds of millions of dollars in incentives to he lp 22 fleet operators and individual vehicle owners andPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 60 1 independent truckers to get into a state-of-the-art 2 low-emission vehicle. And we think there are thing s 3 that the federal government could do in the way of 4 incentives, whether it is a financial incentive or some 5 sort of tax credit, such as has been done in the 6 passenger car arena for zero-emission vehicles and so 7 on. And we would love an opportunity to explore wi th 8 EPA what options you might have that could assist i n 9 whatever is done on the pure traditional regulatory 10 approach. 11 In our written submittal, we will provide the 12 information you requested and also give some ideas 13 about how you could help with the incentive side of 14 public policy. 15 MR. CHARMLEY: Thank you very much. 16 I had one other question for Mr. Mormino from 17 Cummins. Brian, first I wanted to thank Cummins an d 18 your colleagues at Eaton and at Navistar and at PAC CAR 19 for the technical leadership on this. The cycle 20 average for representation of the engine standard, 21 while the EPA and NHTSA didn't propose that for pha se 22 2, the only reason we are in a position to ask forPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 61 1 detailed comment on it was because of the amount of 2 effort that you, your company, and Eaton and PACCARand 3 Navistar put into it. And it is something we want to 4 continue to explore because it may very well have s ome 5 significant advantages over the steady-state map. So 6 thank you for your comments on that. We will look 7 forward to continuing to get information from Cummi ns 8 and the OEMs and other stakeholders on that importa nt 9 topic. 10 My question for you is, your very last point 11 regarding NOx standards, I left that a little bit 12 confused on what your message was. You said someth ing 13 along the lines of that Cummins would support movement 14 in the direction of real-world reductions, real-wor ld 15 reductions. Could you elaborate specifically? Areyou 16 supporting or is Cummins saying that you support EPA 17 and CARB working on new national NOx standards beyo nd 18 the current 2010 standards or did you mean that the re 19 were sort of other ways of attaining real-world NOx 20 reductions? 21 MR. MORMINO: Yes. Thank you for the question . 22 In terms of NOx emissions and as we have read thePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 62 1 reports and understood from the California in terms of 2 their needs to meet national ambient air quality 3 standards, there is a 90 percent reduction needed i n 4 NOx in terms of the ambient air emissions. We beli eve 5 that there is a host of ways to get at that reducti on. 6 And we want to collaborate on all of those ways. S o 7 certainly going from older technology to newer 8 technology is a very significant step for replacingthe 9 older vehicles that are on the road. That will res ult 10 in significant NOx reductions. 11 We have also heard the staff at ARB as well as 12 many other stakeholders already this morning talk about 13 further regulatory actions. And to the extent thatwe 14 can collaborate and make sure that it is a national 15 program to address that, Cummins is fully committedto 16 that. And we think that that should also look at t he 17 full suite of options, which include test cycles, 18 perhaps lowering the standard and other elements to 19 make sure that we ultimately get the goal of what NOx 20 emissions need to be reduced in the ambient air bec ause 21 that is the ultimate goal. And so we are fully 22 committed to working with the agencies and others t oPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 63 1 make sure we maintain a national heavy-duty program . 2 MR. CHARMLEY: So, to summarize for you, amongthe 3 things that Cummins would support, Cummins would 4 support new NOx standards at the national level bey ond 5 the current 2010 standards? 6 MR. MORMINO: Yes, we commit to working with a ll 7 the stakeholders to make sure we have a national 8 program. 9 MR. CHARMLEY: Thank you. 10 MR. GRUNDLER: Very happy to hear that. 11 Any other questions from the panel? Mr. 12 Silverman? 13 MR. SILVERMAN: Question for Mr. O'Connell. Y ou 14 mentioned the importance of flexibility in achievin g 15 these standards. In light of that, do you have a 16 preliminary position on 2024 versus 2027? 17 MR. O'CONNELL: You know, as we have gone thro ugh 18 the technology review and we have certainly got mor e 19 detail, we do believe, again, it goes back to the 20 balance and the implementation. I do know that from a 21 manufacturer's standpoint, that changes and iterati ons 22 of change are critical, so staying aligned with modelPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 64 1 year conversions and implementing the technology ata 2 certainly aggressive enough pace to make a differen ce 3 and an impact, but there is a realistic approach tohow 4 much you can absorb into a fleet operation at any o ne 5 time. So the pace of that change is important to 6 achieve the goal. 7 MR. SILVERMAN: Yes. We would certainly be 8 interested in the fleet-wide perspective on that is sue. 9 MR. O'CONNELL: Yes. We can certainly commenton 10 that. 11 MR. SILVERMAN: And I have one further questio n 12 for Mr. Hogo about glider kits. We proposed that t hose 13 standards take effective January 1, 2018, but we al so 14 asked for comment if it could be done sooner. Do y ou 15 have any position on that? 16 MR. HOGO: As representing NACAA, we will be 17 commenting on that. We don't have a position at th is 18 point. 19 MR. SILVERMAN: Okay. We would be interested in 20 comment on that issue. 21 MR. GRUNDLER: I just want to take Dr. Wallers tein 22 for bringing up the Diesel Emission Reduction Act w orkPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 65 1 of EPA. I am only sad that Congresswoman Napolitan o 2 was not here to hear that. Perhaps you should shar e 3 your view with members as well. 4 Thank you, panel. It was very good testimony. 5 MS. AMERLING: Thank you, panel 3. 6 I would like to invite up to the speakers' tab le 7 panel 4. Sitting on panel 4 is Tim Blubaugh of Eng ine 8 Manufacturers Association, Jorge Rodriguez of the 9 BlueGreen Alliance, Steve Berry with Volvo, David K ayes 10 with Daimler, David Majors with Navistar, Dan Kieff er 11 with PACCAR, and Jim Stewart with the Sierra Club. 12 Welcome. Mr. Blubaugh, would you like to begin? 13 MR. BLUBAUGH: Sure. My name is Tim Blubaugh. I 14 am with the Truck and Engine Manufacturers Associat ion. 15 EMA's members were instrumental in working with EPA , 16 NHTSA, and other stakeholders on the historic phase1 17 rule. That rule was a success because the final ru le 18 was structured around certain key principles: adop ting 19 a singlewide nationwide program, increasing the 20 utilization of existing technologies to achieve 21 substantial time gains, recognizing the commercial 22 needs of the marketplace, and avoiding unintendedPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 66 1 consequences. 2 Similar principles should guide the developmen t 3 and implementation of phase 2. Given EPA's and NHT SA's 4 stated intent to adopt a significantly more stringe nt 5 program, one that forces the development of technol ogy, 6 the appropriate and necessary principles are somewh at 7 modified. We still must maintain a single nationwi de 8 program. That not only means that the EPA and NHTS A 9 rules must align but that California must fully 10 harmonize as well. 11 We are aware that California has advocated a more 12 aggressive timeline for the phase 2 standards along 13 with lower NOx limits. California also has indicat ed 14 that they will consider adopting more stringent 15 greenhouse gas and NOx limits on their own if EPA does 16 not act. We have an almost 3-year history of alignment 17 between CARB and EPA heavy-duty emissions standards . 18 That alignment is a fundamental cornerstone of the 19 cost-effectiveness and implementability of the worl d's 20 most stringent criteria emission control program. 21 Full regulatory alignment was, similarly, crit ical 22 to the success of phase 1 and, likewise, is critica l toPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 67 1 the feasibility of phase 2. Given the well-known 2 tradeoff between NOx and greenhouse gas emissions, 3 California must align itself with EPA's phase 2 pro gram 4 and also must continue to fully align with EPA on NOx 5 emissions. To do otherwise would jeopardize the 6 success of both the greenhouse gas fuel efficiency 7 program and EPA's criteria emission control program . 8 It also is essential that the final rule 9 recognizes the commercial needs of the marketplace, the 10 complexity of product offerings, and avoids uninten ded 11 consequences. To that end, the final rule must pro vide 12 adequate lead time and stability; balance stringenc y 13 costs and implementation dates; look to improvement s 14 beyond just those that are in control of the truck and 15 engine manufacturers; account for impacts of traile r 16 design on tractor aerodynamics; and assure uniform, 17 accurate, cost-effective, and reliable simulation 18 modeling and measurement methods. 19 The proposed rule is incredibly complex. It 20 envisions a strong, aggressive phase 2 program. Th e 21 proposal also demonstrates that the agencies have 22 considered multiple options, are open to potentialPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 68 1 changes before the rule is finished, and are commit ted 2 to work with all stakeholders to finalize a rule th at 3 substantially reduces greenhouse gas emissions and 4 improves fuel efficiency in a way that is cost5 effective and implementable, will be accepted by th e 6 customers, and will provide real-world improvements . 7 While those goals are envisioned in the propos al, 8 they are not yet fully realized. We are focused on 9 making sure that the final rule gets it right. To 10 achieve that goal, we are committed to continuing t o 11 work with EPA and NHTSA to assure a strong, effecti ve, 12 and implementable rule is finalized, one that meets the 13 principles that we have long articulated and that we 14 believe EPA and NHTSA support. 15 I want to briefly identify a few key concerns. 16 Today's rule includes a number of proposals to chan ge 17 the phase 1 rule. Manufacturers already have fully 18 committed their product development plans for phase1 19 compliance. EPA and NHTSA must not create uncertai nty 20 and eliminate essential regulatory stability by 21 attempting to make retroactive changes to the phase1 22 rule.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 69 1 EMA members have developed prototype engine 2 tractor and trailer combinations that achieve 3 innovative game-changing improvements in freight 4 efficiency under DOE's SuperTruck initiative. Yet, 5 based on our preliminary assessments, even those 6 SuperTrucks, which include technologies and design 7 elements that exceed what would be commercially viable 8 in 2027, wouldn't be capable of achieving the best 9 performing vehicle requirements contemplated by the 10 proposed rule. Accordingly, we believe that it is 11 necessary to refine the reference assumptions and 12 correct many of the underlying assumptions about 13 technology penetration rates in order to finalize a 14 technologically feasible and implementable rule. 15 With the significantly more robust and complex 16 proposed simulation models come significant test 17 variability. We believe that the agencies can and must 18 minimize the many components that contribute to tha t 19 variability. Where they cannot fully do so, it is 20 incumbent upon the agencies to provide test and aud it 21 margin to account for that variability. 22 As with phase 1, EMA and its members are commi ttedPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 70 1 to working with EPA and NHTSA to resolve the many 2 important open issues. We will be providing our be st 3 technical assessment of the proposed rule and our 4 recommendations for necessary improvements. Our 5 customers have long demanded fuel efficiency. We h ave 6 worked to continually improve it, even while achiev ing 7 incredible reductions in criteria pollutant emissio ns. 8 We intend to continue to provide improved fuel 9 efficiency and the corresponding improvements in 10 greenhouse gas emissions. 11 To that end, it is essential that the final ru le 12 provide an appropriate, fair, cost-effective, and 13 implementable regulatory framework for those future 14 improvements, one that does not disrupt the market or 15 cause serious unintended consequences. We are ready to 16 assist in that effort. 17 Thank you. 18 MS. AMERLING: Thank you, Ms. Blubaugh. 19 Mr. Rodriguez, welcome. 20 MR. J. RODRIGUEZ: Thank you. 21 Good morning. I am Jorge Rodriguez. I am the 22 program coordinator for the BlueGreen Alliance. Th ankPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 71 1 you for the opportunity to make comments on behalf of 2 the BlueGreen Alliance on EPA's and NHTSA's propose d 3 phase 2 standard for medium and heavy truck vehicle s. 4 These standards will increase fuel efficiency and 5 greenhouse gas emissions from long-haul trucks alon g 6 with full size pickup trucks, other trucks, buses, and 7 vocational vehicles. These standards can also cont inue 8 America's auto and manufacturing resurgence. 9 The BlueGreen Alliance is a national partnersh ip 10 of America's largest unions and environmental 11 organizations. We work together to turn today's 12 biggest environmental challenges into our biggest 13 economic and job-creating opportunities. Together with 14 15 million members and supporters, we are a powerfu l 15 and unified voice for good, family-sustaining jobs, a 16 clean environment, and a thriving and fair American 17 economy. 18 The BlueGreen Alliance and its 15 labor and 19 environmental partners recognize the importance of the 20 proposed medium- and heavy truck fuel efficiency an d 21 greenhouse gas emissions reduction rule. America's 22 economy depends on leadership in building the nextPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 72 1 generation of clean globally competitive energy and 2 vehicle technology. These new standards can provide a 3 critical opportunity to sustain jobs, further reduc e 4 the pollution driving climate change and foreign oi l 5 dependency while enhancing the competitiveness of U .S.- 6 manufactured trucks in global markets. 7 For the past decade, the auto industry in the 8 light-, medium-, and heavy-duty sectors, and Americ an 9 workers, represented by the United Auto Workers, th e 10 United Steelworkers, and others, have been at the f ront 11 lines when it comes to rebuilding manufacturing job s 12 and building the world's leading technology needed to 13 achieve deep cuts in carbon pollution and save 14 consumers billions at the pump. 15 Soon-to-be-released research carried out by 16 several of our partners find more than 380 plants t hat 17 are manufacturing fuel-efficient medium- or heavy t ruck 18 vehicles or their components today in states across the 19 country. These include more than 55 companies in 20 California alone and range from major assemblers to 21 companies making key subsystems to large and small 22 manufacturers of components, trailers, tires, and t hePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 73 1 steel and aluminum that goes into them. Done right , 2 this standard can spur investment, secure and grow 3 jobs, and enhance U.S. competitiveness across these 4 businesses and technologies and the industry as a 5 whole. 6 We greatly appreciate the thorough and systema tic 7 process EPA and NHTSA have taken in developing this 8 proposal. It is critical that an effective rule wo rks 9 for the environment, for the economy, and for the 10 thousands of hard-working American women and men in 11 heavy truck, component, and related industries. Th e 12 auto industry and autoworkers have been at the 13 forefront in proving that America can lead globallyin 14 combating climate change while rebuilding our 15 manufacturing sector and creating and sustaining 16 quality jobs. We urge the agencies to continue the ir 17 thorough and deliberate process to ensure that the 18 final truck rule will continue this trajectory. 19 Together, the previous rounds of cars and heav y20 duty and light, medium, and heavy truck standards 21 achieve the largest greenhouse gas reductions ever 22 undertaken in the U.S. and one of the largest globa lly.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 74 1 We thank EPA and NHTSA for their work to date and 2 look forward to working with the agencies and all o f 3 our partners to ensure that we keep on combating 4 climate change by building great trucks. Thank you . 5 MS. AMERLING: Thank you, Mr. Rodriguez. 6 Mr. Berry, welcome. 7 MR. BERRY: Thank you. The Volvo group has wo rked 8 with our colleagues at Daimler, Navistar, and PACCAR to 9 prepare a joint statement. So we will defer our ti me 10 to Dan Kieffer from PACCAR, who will make the statement 11 for us. 12 MS. AMERLING: Okay. Thank you. Mr. Kieffer, 13 welcome. 14 MR. KIEFFER: Thank you. Good morning. My name 15 is Dan Kieffer, Director of Emissions Compliance fo r 16 PACCAR. I am speaking today on behalf of the major 17 heavy-duty truck manufacturers in North America: 18 Daimler, Navistar, PACCAR, and the Volvo Group. 19 Together we manufacture the vast majority of U.S. 20 medium-duty and heavy-duty vehicles in size Classes 4 21 through 8. We appreciate the opportunity to addres s 22 this hearing.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 75 1 This phase 2 greenhouse gas and fuel efficienc y 2 rule is historic in its scope and complexity. The 3 proposed rule will regulate a wide array of customi zed 4 vehicles, including a broad range of tractor 5 applications, utility trucks, street sweepers, conc rete 6 mixers, local delivery trucks, dump trucks, buses, 7 motor coaches, and many more. 8 As OEMs, we serve the needs of many thousands of 9 American companies that rely on trucks to conduct t heir 10 daily business. We must design each vehicle to mee t 11 the specifications of its intended application whil e 12 optimizing the fuel consumption and providing our 13 customers with a reasonable return on investment. 14 Today's scientific research on climate change and 15 related environmental concerns have made our missio n 16 more critical and more complex. We recognize the 17 problem. And, just as we work closely with EPA, NH TSA, 18 and other agencies to successfully implement phase 1 19 reductions, so shall we strive to address the urgen t 20 need for sustainable solutions in phase 2. 21 The four truck manufacturers I am representing 22 today are all members of the Truck and EnginePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 76 1 Manufacturers Association. We fully support the 2 testimony provided by EMA. There is a long list of 3 technical and protocol issues that we will work clo sely 4 with the agencies to resolve. EPA and NHTSA have s et 5 very ambitious goals for this industry, and we willdo 6 everything we can to ensure that this regulation wi ll 7 translate into significant real-world efficiency ga ins 8 for our customers as well as major benefits for 9 society. Our goal is a classic win-win scenario, a nd 10 we are hopeful we can achieve it. 11 We would like to emphasize that we fully suppo rt 12 the complete vehicle approach proposed by the agenc ies. 13 Measurement and modeling of the full vehicle, inclu ding 14 the engine and all other components, is the best wa y to 15 assess the real-world performance of these vehicles . 16 As stated by EMA, it is important to perform 17 measurements and modeling using sound engineering 18 methods, and we must get this right. We will work with 19 the agencies to resolve the various certification 20 procedures and compliance margin issues we have 21 identified in the proposed rule. 22 There are four major points that we would liketoPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 77 1 make today in regard to engine testing and evaluati on. 2 First, engines are best evaluated based on how they 3 operate in the vehicle; considering the engine size , 4 the power output, the vehicle power demand, and the 5 driveline characteristics; that is, by the full veh icle 6 approach. 7 Second, we must also consider the installation 8 impact of the engine-related systems, including spa ce 9 requirements, weight, and cooling demand, all of wh ich 10 can significantly impact the aerodynamic design of the 11 tractor-trailer combinations and reduce efficiency. 12 The third point is that it is important to res pect 13 the simple fact that NOx emissions are proportionalto 14 engine work. Technology that reduces the engine wo rk 15 required to complete emissions, such as improving 16 aerodynamics or reduced rolling resistance, inheren tly 17 results in a proportional reduction in total NOx 18 output. However, this is not the case with engine 19 efficiency improvements where there is a well20 documented tradeoff between NOx reductions and engi ne 21 efficiency. Excessive demands on the standalone en gine 22 efficiency would limit the potential for NOx reduct ion,Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 78 1 especially in urban duty cycles, where NOx emission s 2 are most critical. 3 And, finally, the many American businesses tha t 4 rely on our vehicles are concerned about the 5 incremental investment and operating cost of comple x 6 new engine technology. Putting excessive emphasis on 7 the engine as a standalone component can result in 8 costly engine technology that would bring little orno 9 benefit in many real-world applications. 10 American businesses have already seen signific ant 11 increases in vehicle cost, in more expensive 12 maintenance associated with the increasingly comple x 13 engine and after-treatment systems. Unnecessarily 14 stringent engine standards will only exacerbate today's 15 trend of delaying new truck purchases and prolongin g 16 the use of higher-emitting vehicles. 17 Summing up our points concerning the engine 18 regulation, the fact is that the vehicle manufactur ers 19 must have the flexibility to optimize the complete 20 vehicle design for maximum efficiency at the lowest 21 cost and complexity. Minimizing total cost of vehi cle 22 ownership is at the top of the priority list for ou rPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 79 1 customers. 2 Concerning aerodynamics, measurement and analy sis 3 of tractor-trailer aerodynamics is extremely comple x. 4 We recently provided detailed feedback to the agenc ies 5 on improvements to these procedures and would 6 appreciate careful consideration of these 7 recommendations. For now, we would like to emphasi ze 8 that significant aerodynamic improvements can only be 9 achieved by treating the tractor and trailer as a 10 system. Even our SuperTruck designs could not achi eve 11 the tractor aerodynamic performance targets if test ed 12 according to the proposal. These details must be 13 addressed. 14 In response to those arguing for an even more 15 aggressive and stringent overall efficiency target, we 16 caution that the most experienced technical experts , 17 that some of the world's largest commercial vehicle 18 manufacturers are still working through the 19 implications of the proposal's requirements. 20 As proposed, the regulation will limit or 21 eliminate our ability to meet the basic customer 22 requirements for many of the thousands of widelyPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 80 1 variant applications we support today. Based on ou r 2 current analysis, it is not clear that the proposed 3 alternative three targets, which include a number o f 4 unrealistic technology penetration rates, can be 5 achieved. 6 One thing we are certain of is that we could n ot 7 achieve and, therefore, cannot support the pull-ahe ad 8 of these standards according to the plan identifiedas 9 alternative 4 in the proposed rule. 10 We look forward to further discussions with th e 11 agencies and their technical experts on these impor tant 12 matters. I appreciate the opportunity to speak on 13 behalf of Daimler, Navistar, PACCAR, and the Volvo 14 Group and will close by reaffirming our industry's 15 commitment to working with the agencies to resolve the 16 rule's outstanding issues and to deliver major 17 reductions in our vehicles' fuel consumption and 18 greenhouse gas emissions. 19 Thank you. 20 MS. AMERLING: Thank you for your comments. 21 Mr. Stewart, welcome. 22 MR. STEWART: I am Jim Stewart, the co-chair o fPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 81 1 the Energy Climate Committee for Sierra Club Califo rnia 2 and also representing the Sierra Club as one of the 3 environmental advisers to the air quality managemen t 4 district here. 5 The official club comments I am sure will be 6 submitted by our excellent national staff. So I am 7 going to speak a little bit from the heart here. T his 8 morning, just like almost every morning, I got anot her 9 text message, right, "Air Alert. Smog levels are 10 unhealthy for sensitive groups." It happens almost 11 every day here in Southern California. 12 You heard Senator Lara's representative speak 13 about the fact that 10 percent of the children in L os 14 Angeles are suffering from asthma. This is a crisi s in 15 our health. Thousands of people die every year in 16 Southern California and elsewhere because we don't have 17 strong national truck standards. These NOx emissio ns 18 you are well aware are killing people. And we needthe 19 people from this trucking industry to do what it sa ys 20 here in this announcement on June 23rd, that the 21 SuperTruck got 12.2 miles per gallon. This is the kind 22 of thing that we need done now.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 82 1 I am thrilled to be able to support the four 2 points that Mary Nichols made on behalf of us suffe ring 3 Californians and the same for Barry Wallerstein and 4 Henry Hogo, who are valiantly fighting. As you hea rd, 5 we need a 90 percent reduction in NOx ambient emiss ions 6 in Southern California to achieve national air 7 standards. How are we going to get that? 8 This business of delay, I mean, you know, 9 alternative 4 is helpful in terms of moving things up, 10 but we need to move things up much, much quicker. We 11 need to start saving people's lives. I don't know if 12 we should like have a moment of silence for the fac t 13 that this past year, 5,000 people died in Southern 14 California from these unhealthy ambient air standar ds, 15 primarily caused by these diesel trucks. So we rea lly 16 need you to not just push the lower NOx emissions 17 standards. 18 We need zero emissions. There is no way that we 19 can make it in Southern California without zero20 emission trucks. And we are looking forward to you 21 making that happen. 22 MS. AMERLING: Thank you, Mr. Stewart.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 83 1 Does anyone on the panel have any questions? 2 MR. SILVERMAN: One question for Mr. Blubaugh. 3 You mentioned changes. Maybe I misheard you, but I 4 thought I heard you say you mentioned changes in ph ase 5 1 procedures, which we proposed certain differences 6 between phase 1 and phase 2 and a few what we thought 7 were exceedingly modest changes in phase 1. Were y ou 8 speaking to those changes to the phase 1 provisions 9 alone or to the changes of them in phase 2? 10 MR. BLUBAUGH: No, no. The first item I menti oned 11 was specifically dealing with the changes to the ph ase 12 1 program. So what we see is a retroactive or goin g 13 back and modifying the phase 1 certification approa ch 14 is something we are opposed to. The manufacturers have 15 already set their product lines and their productio n 16 plans to meet the phase 1 program. And we do not f eel 17 it is appropriate to go back and change the phase 1 18 program. We think we should turn our attention to 19 phase 2. 20 MR. SILVERMAN: Okay. I think in our mind, we 21 thought those were inconsequential proposals. So we 22 would be very interested in the specifics of why yo uPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 84 1 think it is having actual deleterious consequences. 2 MR. BLUBAUGH: Yes. We do. We will submit 3 comments. We believe that it is consequential, wil l 4 require recertification, and will be consequential. 5 And we will submit written comments. 6 MS. AMERLING: Other questions? 7 MR. CHARMLEY: I had one question for either Mr. 8 Kieffer or David Majors. Dan, during your comments on 9 the engine standard, your first point was that it i s 10 very, very important from the OEM's perspective tha t 11 the engines be tested over the types of cycles that 12 they would see in the vehicle. And from that 13 perspective, I would like to know if PACCAR and 14 Navistar have any comments regarding potential bene fits 15 of the cycle average map approach that the agencies 16 requested comment on. So, you know, I think from a 17 technical perspective, some would say that comparedto 18 a 120-point steady-state map, that doing an annual 19 transient test might be more representative of how to 20 evaluate an engine and put the engine into the vehi cle 21 simulation. So do you think, again, that the engin e 22 cycle, average cycle, map approach versus our steady-Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 85 1 state has more opportunity to meet one of your four 2 recommendations for engines, that it be best evalua ted 3 and over how it will actually be used? 4 MR. KIEFFER: PACCAR has been actively involve d 5 with the group developing the cycle average approac h. 6 And I would say at this point, we are still assessi ng 7 the broader range of all engines, all applications to 8 understand the implications of cycle average versus the 9 steady-state approach. At a high level, it does se em 10 to show some advantages, but that is just at the fi rst 11 step. So we need to dive in to determine what the 12 implication is on the broader range, rather than si ngle 13 point. 14 MR. MAJORS: Yes. I would like to reiterate what 15 Dan said. You know, we have really just started to 16 investigate the broad application of the cycle aver age 17 map over all of the duty cycles. I think it is ver y 18 early in the stage to make a comment that it is mor e 19 beneficial than a 130-point map, which is currently 20 written into the standard. So, with the limited amount 21 of data that we have today, there is some promise. 22 Otherwise we wouldn't continue to work on it andPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 86 1 progress it. But right now there is still much mor e 2 work that needs to be done in order to make a 3 definitive statement. 4 MR. CHARMLEY: Thank you. 5 MS. AMERLING: Any other questions? 6 MR. BERRY: Would it be inappropriate to ask f or a 7 moment for a statement for some input from Volvo? 8 MS. AMERLING: Sure. 9 MR. BERRY: We have heard the strong pleas for 10 further NOx reductions from heavy-duty trucks. Andwe 11 understand that situation. And Volvo has been 12 supporting a movement toward evaluating NOx emissio ns 13 from a total vehicle view and not insisting on NOx 14 reductions through the traditional engine-specific 15 approach. 16 And in the context of the greenhouse gas rules , we 17 ask that you not handcuff us with even more stringe nt 18 engine standards that are proposed, which only furt her 19 challenges our ability to support future NOx reduct ions 20 that we understand are so valued in California and 21 across the country. 22 MS. AMERLING: Any other thoughts from the pan el?Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 87 1 MR. CHARMLEY: Can I ask just one? 2 MS. AMERLING: Yes. 3 MR. CHARMLEY: So, Steve, the gentleman from 4 Cummins said that they would be very interested in 5 actually working with ARB and NHTSA on further NOx 6 reductions. Should we take the comment that you ju st 7 made regarding Volvo that Volvo would also support 8 working with ARB and EPA on more stringent NOx 9 standards? 10 MR. BERRY: Volvo Group has already been in 11 discussions with ARB and the air quality management 12 districts about appropriate approaches for NOx 13 reduction. And we welcome further discussion along 14 those lines. 15 I hesitate to say that we would support more 16 stringent NOx standards because that is the point. It 17 is not just through engine NOx standards that NOx 18 reductions can be achieved. We look for the greenh ouse 19 gas-NOx win-win. And we think that we ought to be 20 evaluating those technical approaches and the 21 regulatory framework that supports promotion of tho se 22 and implementation of those approaches.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 88 1 MS. AMERLING: I think that wraps up panel 4. 2 Thanks to all of you for coming and sharing your 3 perspectives. 4 Now we will turn to panel 5. 5 MR. GRUNDLER: Welcome, panel 5. If Hilary 6 Sinnamon is in the audience, please make your way up to 7 the front table. I would like to also welcome fromthe 8 Pew Charitable Trusts, Jason Wynne; Doug Corcoran f rom 9 Waste Management; Allis Druffel from the California 10 Interfaith Power and Light; Tom Fulks from the Dies el 11 Technology Forum; and Don Anair from the Union of 12 Concerned Scientists. Welcome. Ms. Sinnamon, whenyou 13 are ready. 14 MS. SINNAMON: Thank you. 15 MR. GRUNDLER: One more point before you start . 16 Sorry. I will be taking a short, 10-minute, break at 17 the conclusion of panel 5. And then I will be goin g 18 again with panel 6. 19 MS. SINNAMON: Thanks. Good morning. On beha lf 20 of the Environmental Defense Fund and our more than1 21 million members nationwide and nearly 200,000 here in 22 California, I thank you sincerely for the opportuni tyPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 89 1 to testify today in support of a timely and rigorou s 2 phase 2 program to reduce climate pollution and fue l 3 consumption for the nation's fleet of heavy-duty tr ucks 4 and buses, the most swiftly growing transportation 5 source of greenhouse gas emissions in the United 6 States. 7 The proposed standards build on the historic 8 first-ever fuel economy and greenhouse gas standard s 9 for the heavy-duty sector. The success of the firs t 10 phase of the program is already being demonstrated by 11 the demand for more efficient trucks. Model year 2 014 12 heavy-duty trucks saw the highest sales since 2005, and 13 class 8 sales this summer are up an impressive 23 14 percent over the same time last year. 15 This second phase of the program provides a 16 critical opportunity to deliver even greater emissi ons 17 and oil reductions while spurring technological 18 innovation and saving businesses and consumers mone y. 19 Heavy trucks are critical to our economy but a lso 20 consume more than 135 million gallons of fuel everyday 21 and emit more than 450 million metric tons of clima te 22 pollution annually. As mentioned, Southern Califor niaPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 90 1 has the worst air quality in the country. And in L os 2 Angeles County alone, nearly 400,000 children suffe r 3 from asthma while living in an area that fails the 4 health-based standards for both ozone and particula te 5 pollution. The county is also home to the largest port 6 complex in the nation, which relies on heavy-duty 7 vehicles to sustain its operations, vehicles that c an 8 be cleaner and more efficient. 9 California has already demonstrated critical 10 leadership, recognizing the importance of achieving 11 emission reductions from the state's large trucks a nd 12 buses, actions that have spurred critical progress, 13 both statewide and nationally. For example, 14 California's trailer efficiency standards have yiel ded 15 strong benefits and are now an important feature ofthe 16 agencies' proposed rule. And just recently, Govern or 17 Brown announced an initiative to further strengthenthe 18 environmental and economic performance of Californi a's 19 transportation sector. The phase 2 heavy-duty 20 greenhouse gas and fuel economy standards are one o f 21 the single most important opportunities to protect 22 public health and the environment in California andthePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 91 1 nation. 2 While the proposals by EPA and DOT are an 3 important step forward, there are many opportunitie s to 4 strengthen the standards in a way that secures the 5 emissions reductions that are needed to protect our 6 families and communities and that drive American 7 ingenuity to ensure we are innovating to strengthenour 8 economy and protect our environment. 9 In addition to other opportunities, we 10 respectfully make the following central 11 recommendations. Number one, to strengthen the eng ine 12 standard, a separate, rigorous engine standard is 13 essential to deliver permanent, real-world emission s 14 reductions. It also allows EPA and manufacturers t o 15 simultaneously evaluate NOx and CO2, ensuring that 16 efficiency improvements do not result in higher NOx 17 emissions. However, the proposed 4.2 percent engin e 18 efficiency improvement over 10 years falls woefully 19 short of what manufacturers and leading analyses have 20 indicated is viable. Existing technologies have th e 21 potential to cost-effectively increase the engine 22 efficiency by at least 15 percent beyond the 2017Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 92 1 levels. A weak engine standard undermines the over all 2 tractor-trailer standard and fails to drive a wide 3 array of important engine technologies that can del iver 4 real-world reductions. The agencies must finalize a 5 protective engine standard that reflects the innova tive 6 path of today's technologies and carries out its le gal 7 responsibilities under our nation's clean air laws. 8 Number two, accelerate the timing of the 9 standards. To ensure the phase 2 program drives ne eded 10 emission reductions and technological innovation inthe 11 near term, it is essential that standards be fully 12 implemented by 2024. The agencies' own analysis, 13 proposed as alternative 4, indicates this is eminen tly 14 feasible and cost-effective. Speeding the transiti on 15 to cleaner trucks would save an additional 200,000 16 barrels of oil per day in 2035 and avoid an additio nal 17 40 million metric tons of global warming emissions 18 annually. A faster timeline would also hasten the 19 important NOx reductions, 2.4 million tons reduced over 20 the life of the 2 programs, an improvement Californ ia 21 would certainly benefit from. 22 Number three, promulgate protective emissionsPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 93 1 standards for particulate pollution from APUs. 2 Auxiliary power units are among the technologies 3 available to reduce fuel use from sleeper cab tract ors 4 due to idling. However, the particulate standards for 5 diesel APUs, established under the non-road rule, a re 6 not nearly as protective as the truck engine standa rds 7 for model year 2007 and later, which require the us e of 8 diesel particulate filters or comparable alternative. 9 This disparity allows diesel APUs to emit more than 10 five times as much harmful diesel particulates as t he 11 trucks they are relieving. This increase in 12 particulate emissions will be especially significan t at 13 idling hotspots, like diesel truck stops; distribut ion 14 centers; and ports, like here in Long Beach. 15 California has already established more protec tive 16 standards for APUs and has concluded that technolog ies 17 are available and highly cost-effective. We reques t 18 that EPA follow California's lead and put in place 19 protective particulate standards for these units to 20 protect public health and the environment from the 21 harmful impacts of diesel pollution. 22 The phase 2 standards represent an importantPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 94 1 opportunity to protect Americans' health, strengthe n 2 its economy, and improve energy security, all while 3 saving truckers money in fuel costs. I appreciate the 4 opportunity to testify and respectfully request the 5 agencies finalize rigorous protective standards for 6 California and our nation. 7 Thank you. 8 MR. GRUNDLER: Thank you. Mr. Wynne, welcome. 9 MR. WYNNE: Thank you for the opportunity to 10 provide comment today on the phase 2 greenhouse gas 11 emissions standards and fuel efficiency standards f or 12 medium- and heavy-duty engines and vehicles. My name 13 is Jason Wynne, and I am a senior associate with th e 14 Pew Charitable Trusts Clean Energy Initiative. 15 Pew is a nonprofit organization dedicated to 16 improving public policy, informing the public, and 17 invigorating civic life. The clean energy initiati ve 18 has supported prior fuel economy standards promulga ted 19 by the Environmental Protection Agency and the Nati onal 20 Highway Traffic Safety Administration for passengerand 21 light-duty vehicles. We commend the agencies' late st 22 efforts to set ambitious and achievable efficiencyPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 95 1 standards for medium- and heavy-duty trucks. Impro ving 2 the efficiency of America's transportation vehicles is 3 good for our economy, our national security, and ou r 4 environment. 5 The sensibility of these efforts is reflected in 6 the fact that more than 300 businesses and 7 organizations signed a letter of support for the 8 agencies to develop strong standards that will cut oil 9 consumption, reduce fuel costs for companies that r ely 10 on trucks, and decrease emissions across America's 11 roads and highways. This group of signers includes 12 fleet owners, truck component manufacturers, 13 alternative fuel producers, and companies whose 14 products are shipped via freight, demonstrating the 15 broad range of industry stakeholders who want to save 16 money and fuel and reduce emissions from these 17 vehicles. 18 While medium- and heavy-duty vehicles make up a 19 small portion of traffic on the road, they are the 20 second-largest and fastest-growing segment of the U .S. 21 transportation sector in terms of emissions and ene rgy 22 use. Establishing smart and affordable standards w illPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 96 1 facilitate a more sustainable trajectory for this 2 expanding industry. The standards under considerat ion 3 today will help do just that, saving vehicle owners 4 $170 billion on fuel costs, reducing harmful carbon 5 pollution by nearly 1 billion metric tons, and redu cing 6 oil consumption by up to 1.8 billion barrels, more than 7 a year's worth of U.S. imports from OPEC. 8 Setting fuel efficiency and emissions standard s 9 for these vehicles also will help spur new technolo gy 10 innovations in this sector. The Department of Ener gy's 11 SuperTruck program demonstrates that dramatic chang es 12 in fuel economy are possible for class 8 tractor13 trailers. These SuperTrucks can achieve over ten m iles 14 per gallon under real-world conditions—up from toda y's 15 six miles per gallon rating for heavy-duty trucks. 16 Through public-private partnerships as well as rese arch 17 and development, we can help bring new advanced veh icle 18 technologies to the marketplace in a cost-competiti ve 19 way. 20 The International Council on Clean Transportat ion 21 reports that other countries, including China and 22 Japan, are looking to strengthen efficiency standar dsPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 97 1 for medium- and heavy-duty vehicles, providing U.S. 2 entrepreneurs an opportunity to develop new 3 technologies here in the U.S., and export to countr ies 4 to meet their next policy goals. 5 While collectively the proposed phase 2 standa rds 6 will yield $230 billion in societal benefits, some 7 industry experts have noted that even stronger 8 standards are feasible and could achieve up to 40 9 percent greater efficiency among these vehicles by 10 2025, as compared to 2010 levels. We encourage theEPA 11 and NHTSA to consider the information provided by t hese 12 experts and look for opportunities to strengthen th e 13 proposed standards. Furthermore, we ask that EPA a nd 14 NHTSA continue working with the Department of Energ y 15 and its national laboratories to support public 16 programs that will help facilitate advanced vehicle 17 technologies in the marketplace. 18 Thank you again for the opportunity to testify , 19 and I am happy to address any questions you may have. 20 MR. GRUNDLER: Thank you, Mr. Wynne. 21 Mr. Corcoran, welcome. 22 MR. CORCORAN: Thank you.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 98 1 Good morning. I am Doug Corcoran. I am Direc tor 2 of Public Sector for Waste Management's Southern 3 California area. Thank you for the opportunity to 4 testify on the proposed phase 2 rule for the heavy- duty 5 trucks. 6 Waste Management is a leading provider of 7 comprehensive waste and environmental services in N orth 8 America. Headquartered in Houston, Waste Managemen t 9 operates in 48 states in the U.S. and most Canadian 10 provinces. As part of our collection operations, we 11 own and operate a fleet of about 18,000 heavy-duty 12 refuse trucks. So this rule will have a significan t 13 impact on our operations. 14 Before discussing our views on particular aspe cts 15 of the proposal, we want to commend the Environment al 16 Protection Agency and the National Highway Traffic 17 Safety Administration for the very collaborative 18 process you used to develop this proposal. You wer e 19 open, transparent. You sought stakeholder informat ion. 20 And you encouraged input. At Waste Management, we were 21 very pleased to be invited to share with you our 22 strategy to build a cleaner, more reliable natural gasPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 99 1 fleet. 2 We believe the resulting proposal reflects car eful 3 consideration of our views, providing a regulatory 4 framework that can build upon the initial success o f 5 phase 1, allowing us to continue to grow our natura l 6 gas fleet while complying with future GHG emissions 7 standards. 8 The proposed phase 2 rule is very important to 9 Waste Management. And I want to tell you why. In 10 2007, Waste Management identified a set of 11 sustainability goals that included reducing the 12 greenhouse gas emissions from our company fleet 15 13 percent by the year 2020. Well, we exceeded that g oal 14 in 2011 and have reduced our fleet emissions by ove r 20 15 percent. We did so by steadily converting our flee t to 16 cleaner burning, natural gas-fueled vehicles. 17 Here in Southern California, we have converted85 18 percent of our fleet -- that is over 1,100 heavy-du ty 19 vehicles -- to natural gas, while nationwide nearly25 20 percent of our refuse vehicles run on natural gas. 21 That makes our fleet North America's largest heavy- duty 22 natural gas-fueled fleet.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 100 1 The natural gas trucks have been good for our 2 customers and communities where we operate, good fo r 3 the environment, and good for our business. Each t ruck 4 eliminates the use of 8,000 gallons of diesel fuel a 5 year, which is replaced by the cleaner burning natu ral 6 gas. Natural gas trucks have nearly zero particula te 7 emissions. They reduce greenhouse gas emissions by 8 over 20 percent. The trucks are quieter than their 9 diesel counterparts. And -- this is important -- t hey 10 run on homegrown, secure sources of fuel. 11 Our strategy over the coming years is to make 90 12 percent or more of our new fleet purchases natural gas 13 trucks. Because ours is a nationwide fleet and fue ling 14 strategy, it will be important to have a nationwide 15 consistent rule across all 50 states. 16 We are also investing in natural gas fueling 17 infrastructure. We operate about 75 natural gas 18 fueling stations across the country right now. 19 Building these stations is expensive. And that canbe 20 a barrier to local governments that wish to increas e 21 their own public natural gas fleets. That is why 22 nearly 40 percent of our stations are open to thePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 101 1 public and/or city access. 2 Working with our manufacturing partners and wi th 3 our regulators, such as the South Coast Air Quality 4 Management District, we have seen steady improvemen ts 5 in heavy-duty natural gas engine technology. For 6 example, in future model years, enclosed crank case s 7 will enable significant reduction in fugitive metha ne 8 emissions from trucks, making an already clean 9 technology even more environmentally beneficial. We 10 view today's natural gas vehicles as a bridge to th e 11 future, a bridge to even cleaner running vehicles. 12 As a next step towards further reductions in o ur 13 greenhouse gas footprint, we are using gas producedby 14 our landfills to make renewable natural gas for our 15 vehicles. For example, 380 Waste Management refuse 16 trucks in California run on renewable natural gas f rom 17 our Altamont Landfill. We plan to fuel several hun dred 18 more vehicles with new renewable natural gas produc tion 19 at our landfill in Milam, Illinois. And we are wor king 20 with other landfill owners to purchase renewable 21 natural gas to fuel even more vehicles. 22 On a lifecycle basis, renewable natural gasPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 102 1 reduces greenhouse gas emissions by upwards of 90 2 percent. Therefore, phase 1 and phase 2 truck rule s 3 can work in a very complementary way with the EPA's 4 renewable fuel standard. The transition of our fle et 5 to cleaner fuel is a sustainability issue for our 6 company, for our communities and customers, for the 7 environment, and for national security. 8 In closing, I want to be clear. Waste Management 9 supports the Environmental Protection Agency's and the 10 National Highway Traffic Safety Administration's ph ase 11 2 goals of reducing greenhouse gas emissions and 12 improving the fuel efficiency of heavy-duty fleets. 13 Thank you. 14 MR. GRUNDLER: Thank you very much. 15 Ms. Druffel, welcome. 16 MS. DRUFFEL: Good morning and thank you for 17 holding this important hearing in Long Beach and th e 18 opportunity to make comments. 19 My name is Allis Druffel. And I am South 20 California Outreach Director for California Interfa ith 21 Power and Light. We work with 650 member congregat ions 22 in the state to address global warming through ener gyPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 103 1 efficiency, renewable energy, education, and advoca cy. 2 Houses of worship of all faiths are working to 3 implement the commonly held mandate to care for and 4 protect all of creation. Nationwide Interfaith Power 5 and Light is present in 40 states, where we reach a n 6 estimated 18,000 congregations. 7 All major religions have a moral imperative to 8 conserve, steward, and protect the Earth and all of 9 creation. In this day and age, this translates to 10 protecting communities from pollution and lesseningthe 11 threat of climate change while building a renewable 12 energy future and creating jobs, especially for tho se 13 persons in areas that are hard hit by high 14 unemployment. 15 Just recently, Pope Francis released an encycl ical 16 on ecology, exhorting that any efforts to stave offthe 17 worst effects of climate change and regional pollut ion 18 must naturally integrate efforts to alleviate pover ty, 19 address economic and social inequality and improve 20 public health. These concerns are all intimately 21 interconnected. 22 And, as we know, in California, all too often, itPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 104 1 is communities of color and lower-income communitie s 2 that are affected disproportionately by local sourc es 3 of pollution, regional impacts of climate change. And, 4 as a result, persons suffer consequences, such as 5 increased rates of asthma, heart disease, and lost work 6 and school days. 7 The EPA and NHTSA clean truck standards would be a 8 huge step in addressing all of the above. And the 9 standards can be even stronger. The draft rule, as it 10 stands, 36 percent reduction of fuel consumption in 11 trucks by 2027 is a good start. However, we urge E PA 12 and NHTSA to adopt standards that will achieve a 40 13 percent target by 2025. 14 With existing technologies and future innovati on 15 in the works, especially here in California, we can 16 surely reach much better than an average of six mil es 17 per gallon for most heavy-duty vehicles. We also 18 support other organizations, such as the South Coas t 19 Air Quality Management District, in their call for a 20 tightening of the NOx standards. 21 I am sure that Long Beach was chosen deliberat ely 22 as a site for this hearing because of the proximityofPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 105 1 the Ports of Los Angeles and Long Beach. Too many 2 communities here are suffering from pollution from 3 mobile sources. The effects on communities, especi ally 4 along the 710 Alameda corridor, are so bad that it has 5 received the unfortunate moniker of Cancer Alley. The 6 proposed standards have multiple benefits, such as 7 reducing toxic air pollution from idling trucks and 8 refineries, resulting in an estimated $37 billion i n 9 health and welfare benefits and preventing cases of 10 asthma, respiratory illness, hospitalizations, lost 11 workdays, and sick days from school. And, as we he ard, 12 these will have benefits for companies in fuel savi ngs 13 and energy efficiency. 14 Personally, I still remember the fact that I h ad 15 extreme asthma when I was growing up in the '70s an d 16 '80s in Pasadena. I still remember the almost 17 desperate gasping for breath and being forced to li e 18 down quietly inside while other friends played outs ide. 19 Thank God that that has resolved, mainly due to the 20 efforts of the AQMD and strong standards. 21 However, my beautiful, seemingly thriving 30-year22 old niece, while she looks very, very healthy, hasPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 106 1 extreme asthma, brought on by growing up close to t he 2 134 freeway, which is very heavily congested. Whil e it 3 is very uncomfortable for her to experience asthma, it 4 actually pains me when I hear her wheezing and seei ng 5 her use her inhaler constantly. And I know that ma ny 6 in this room can relate to that feeling. 7 I am praying that these standards, especially the 8 stronger standards, are accepted, preventing millio ns 9 of cases of respiratory illnesses as well as cancer 10 exacerbated by pollution. 11 The faith community, especially in the hard-hi t 12 areas of the state, such as Long Beach, Bakersfield , 13 Fresno, and parts of Los Angeles, are extremely 14 concerned and active on the issue of pollution 15 reduction. We are very strong advocates of Califor nia 16 policy, such as AB-32, and are supporters of the S. B. 17 32 and S.B. 350, which will reduce petroleum use in 18 California by 50 percent by 2030. 19 California Interfaith Power and Light and our 650 20 members thanks you, the EPA and NHTSA, for your ong oing 21 efforts to improve public health to protect our cli mate 22 and to build healthier communities.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 107 1 Thank you. 2 MR. GRUNDLER: Thank you so much. 3 Mr. Fulks, welcome. 4 MR. FULKS: Thank you. 5 My name is Tom Fulks. I am the West Coast 6 representative for the Diesel Technology Forum. Th e 7 DTC represents the leaders in clean diesel technolo gy, 8 including engine makers; vehicle manufacturers; 9 equipment manufacturers; and affiliated organizatio ns, 10 such as biofuel makers. 11 I am going to read this statement to you right 12 now. We are going to be very respectful of your ti me. 13 And so we will get through this hopefully within th e 14 timeframe. 15 Today, manufacturers of commercial truck engin es 16 and their components produce the cleanest, safest, most 17 fuel-efficient technology in the world. For all 18 parties, the challenge of further increasing fuel 19 efficiency while maintaining or improving an 20 environmental safety and productivity of commercial 21 vehicles is as complex as it is important. Diesel 22 engines are the prime mover of the global economy a ndPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 108 1 the primary power plant for the wide variety of 2 commercial trucks that are on the road today. And we 3 hope that the outcome of these proceedings builds o n 4 the success already accomplished in achieving near- zero 5 emissions with today's new clean diesel technology. 6 Today, we will focus on three areas. One, new 7 clean diesel technology will contribute to further 8 efficiency gains and continue to be the primary power 9 train for commercial vehicles. Two, climate fuel 10 savings and clean air benefits from new technology 11 diesel engines and commercial trucks in operation t oday 12 are significant and growing. And, three, the frame work 13 for continued success should include appropriate 14 timeframes, uniformity, and harmonization. 15 Today, more than 95 percent of all heavy-duty 16 trucks and the overwhelming majority of medium-duty 17 trucks on the road are diesel-powered. Manufacture rs 18 envision further advances in innovations in diesel 19 engines that will improve efficiency beyond where we 20 are today. That progress, coupled with diesel's 21 unmatched combination of power-increasing energy 22 efficiency, work capability, reliability, and now n ear-Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 109 1 zero emissions environmental performance, along wit h an 2 ability to utilize a variety of low-carbon renewabl e 3 diesel fuels, solidifies diesel's rule for commerci al 4 trucking moving forward. 5 Last year was very strong for new truck sales, 6 with over 186,000 new medium-duty trucks sold along 7 with more than 230,000 heavy-duty trucks, or class 8 8 trucks, sold. The overwhelming majority of these 9 vehicles are powered by clean diesel technology, wi th 10 just a few thousand units powered by other fuels. 11 Since 2000, leaders in clean diesel technology 12 have met the challenge from both CARB and U.S. EPA to 13 virtually eliminate NOx and PM emissions from diese l 14 engines, reducing emissions by as much as 98 percen t 15 from previous levels. In fact, last year, the Amer ican 16 Lung Association in its annual state of the air rep ort 17 identified cleaner diesel fleets as one of the two main 18 contributors in helping the nation achieve cleaner air 19 and meeting the national ambient air quality standa rds. 20 New technology clean diesel engines are being 21 widely embraced by customers, as evidenced by the 22 increasing penetration of the vehicle population.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 110 1 According to vehicle registration data for 2014, ab out 2 37 percent of the roughly 9.2 million class 3-3 heavy3 duty vehicles on the road nationwide are using 2007 4 emissions-compliant or newer engines with near-zeroPM. 5 Of these, 22 percent of the vehicles on the road to day 6 meet the most stringent 2010 and later emissions 7 milestones that require near-zero levels of both PMand 8 NOx. 9 By comparison, there are 120,429 model year 20 10 10 or newer vehicles or, I should say, medium-duty 11 vehicles in operation in California, making Califor nia 12 the third nationwide in terms of total number of ne w 13 diesel technology engines on the road today. 14 New diesel technology is delivering real-world 15 benefits in the fuel savings, and reducing carbon 16 emissions. According to research commissioned by t he 17 DTF, between 2010 and 2014, technologies developed to 18 meet strict diesel emissions standards, beginning f or 19 model year 2010, have generated a substantial fuel 20 savings and emissions reductions. More than 880 21 million gallons of diesel fuel, which equates to 9 22 million tons of CO2, have been saved in that 4-yearPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 111 1 period. 2 I am moving on because I am running out of time. 3 Based on the industry experience over the last deca de, 4 we strongly urge EPA and NHTSA to finalize these ru les 5 to ensure a national program uniform to all 50 stat es, 6 including California, that ample lead time and 7 stability are provided, and that it is compatible w ith 8 the diversity of the commercial trucking marketplac e. 9 In addition, we strongly urge the EPA and NHTS A to 10 ensure that the final phase 2 program be fuel-neutr al 11 in nature. Through the adoption of emissions 12 standards, testing procedures, and other provisions , 13 the proposed rule must ensure that one fuel or 14 technology is not, directly or indirectly, favored over 15 others for any of the categories of the vehicles 16 covered. Various provisions in the current proposa l, 17 particularly for light-duty commercial vehicles as well 18 as vocational trucks, may be skewed to favor one fu el 19 over another or make assumptions that work against the 20 diesel engine option. 21 EPA's and NHTSA's role is to establish and 22 maintain a level playing field that allowsPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 112 1 manufacturers and/or customers to select the techno logy 2 that makes the most sense for their specific needs. 3 While this proposed rule focuses on vehicle and eng ine 4 standards in the context of efficiency and reducing 5 greenhouse gas emissions, we believe it is importan t to 6 also note the benefits from changes to fuels. 7 So, recently and in closing, I will mention th at 8 City of San Francisco recently went to a 100 percen t 9 renewable diesel fuel mix for its entire diesel fle et. 10 UPS has adopted a renewable diesel fuel mandate forits 11 entire diesel fleet. 12 And so, with that, the Diesel Technology Forum 13 thanks you for your time. Its comments will be 14 submitted in writing for both the Chicago hearing a nd 15 today. So have a great day. Thank you. 16 MR. GRUNDLER: Thank you for your time. 17 Mr. Anair, welcome. 18 MR. ANAIR: Thank you. Thanks for the opportu nity 19 to comment today. 20 My name is Don Anair. I am the research and 21 deputy director of the clean vehicles program at th e 22 Union of Concerned Scientists. UCS is a leadingPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 113 1 science-based nonprofit with over 450,000 members 2 nationwide and a network of nearly 17,000 scientist s, 3 engineers, and public health professionals. 4 Reducing oil consumption and pollution from he avy5 duty vehicles has been a focus of our work for more 6 than 15 years. So it is with great interest that I am 7 testifying today before you on the proposal. 8 Tackling pollution and fuel consumption from 9 heavy-duty trucks is a critical task. Left unchecked, 10 global warming emissions and oil use from these 11 vehicles will continue to grow, despite the success ful 12 and ongoing implementation of the phase 1 standards . 13 Fortunately, technical analyses by UCS and others, 14 including the National Academies, shows that much 15 greater improvements aren't only possible but they can 16 be done cost-effectively. 17 UCS applauds both EPA and NHTSA for seeking to 18 address the growing fuel use and emissions by propo sing 19 the new standards for these vehicles. The proposal 20 represents a significant step forward from the phas e 1 21 standards, particularly with the inclusion of trail ers 22 in the standards.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 114 1 However, there are additional opportunities to 2 increase emissions reductions and oil savings from 3 heavy-duty trucks while continuing to provide stron g 4 overall economic benefits from the program. And we 5 urge the agencies to strengthen the rule. 6 First and foremost, the agencies should accele rate 7 the implementation of the standards. Our analysis 8 shows that by 2025, new truck fuel consumption can be 9 reduced 40 percent below 2010 levels. 10 The timing and stringency of alternative 4, wh ich 11 moves the final implementation date from 2027 to 20 24, 12 is much more consistent with the analysis of UCS an d 13 other independent organizations as well as the 14 technical capabilities of the industry. 15 In addition, the stringency of the engine stan dard 16 is much lower than our assessment of the potential 17 cost-effective improvements available over the next 18 decade. As proposed, the standards would require a 19 modest 4 percent reduction in fuel consumption between 20 2018 and 2027. This falls far short of the potenti al 21 improvements over this timeframe. 22 Third, we applaud the agencies for includingPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 115 1 hybrid technology when setting the overall stringen cy 2 of vocational vehicles. Hybrid technology is 3 commercially available today and should be expectedto 4 continue to advance over the timeframe of this 5 regulation. However, in the current proposal, the 6 agencies have underestimated the effectiveness of 7 hybrid technology, both in the reliance only on theGEM 8 and not real-world duty cycles and also be excludin g 9 the benefits of using electric power takeoff and some 10 of the applications that are most likely to utilize 11 hybrid technology, such as in utility bucket truck 12 applications. 13 These exclusions downplay both the cost14 effectiveness of this technology as well as its 15 potential penetration, thus underestimating the tot al 16 potential for reductions in the vocational vehicle 17 sector. The agency should consider, fully consider , 18 the benefits of hybrid technology, including the 19 advancement of hybrid technology development and gr owth 20 in cost-effective applications over the timeframe o f 21 the rule and increase the stringency of the vocatio nal 22 vehicle standards to reflect this.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 116 1 The standards should also support the development 2 and deployment of technologies that are needed to meet 3 air quality standards, protect the health of 4 communities near freight hubs, and achieve deep 5 reductions in climate emissions that are needed in the 6 future. These include technologies like battery 7 electric, plug-in hybrid electric, fuel cell 8 technologies, as well as strong hybrids in the clas s 7 9 and 8 tractors. These are all technologies that ar e in 10 early stages of development or deployment. 11 States like California as well as early adopte r 12 fleets are investing millions of dollars in these more 13 advanced truck technologies, moving them toward ful l 14 commercialization. Even today, there are hundreds of 15 advanced electric trucks that are already operatingon 16 the road today. 17 With Governor Brown's recent executive order 18 calling for the deployment of zero-emission 19 technologies in the freight sector, we can expect t hat 20 the number of these vehicles will increase 21 significantly over the next several years as well a s 22 California's investment of the greenhouse gas reduc tionPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 117 1 funds in these technologies will also be supporting 2 this technology development over the timeframe of t he 3 regulation. 4 EPA and NHTSA can support advanced technology 5 truck development by both increasing the stringencyof 6 the requirements for vocational vehicles as well as 7 restoring advanced technology credits or some simil ar 8 mechanism to incentivize the most advanced 9 technologies. 10 In conclusion, we strongly urge EPA and NHTSA to 11 finalize phase 2 heavy-duty standards that fully 12 capture the technical capabilities and ingenuity ofthe 13 truck manufacturing sector and set a path to even 14 greater emissions reductions and fuel savings in th e 15 future. Strong standards will help to keep America 's 16 truck manufacturing sector competitive, spur econom ic 17 growth, and improve the nation's energy security an d 18 our environment while saving the nation's truck fle ets 19 and their customers billions of dollars in fuel cos ts. 20 Thank you very much. 21 MR. GRUNDLER: Thank you, Don. 22 Questions from the panel? Mr. Charmley?Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 118 1 MR. CHARMLEY: I just have one question for 2 Hilary. Hilary, during your testimony from EDF, yo u 3 mentioned that for the engine standards, you did gi ve a 4 specific recommendation of at least 15 percent or 1 5 5 percent in 2024 based on existing engine technologi es. 6 So I would hope that EDF and UCS and other 7 stakeholders, to the extent that in your written 8 comments that I presume that you all will be 9 submitting, that the more specific that you can be 10 regarding what engine technologies can enable a mor e 11 stringent standard including, but not limited to, a15 12 percent reduction by 2024, that would be very helpf ul. 13 MS. SINNAMON: Yes. We are planning to submit 14 extensive written comments, in addition to some 15 additional analyses we are going to do in the next 16 month on engines. So we will submit that as well. 17 MR. CHARMLEY: Thank you. 18 MR. GRUNDLER: Okay. Thank you, panel 5. Tha t 19 was very helpful. We are going to take a 10-minute 20 break and reconvene at 11:25. 21 (Recess taken.) 22 MS. AMERLING: Jeffrey Bennett with Truck Trai lerPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 119 1 Manufacturing Association; Andrea Marr, Operation F ree 2 Veteran. We are having some issues. We are going to 3 hold on asking you to testify, but I will introduce 4 you. Can everybody hear me? Okay. So we have And rea 5 Marr from Operation Free Veteran, Matt Solomon from 6 NESCAUM, Diane Hart from Union of Concerned Scienti sts, 7 and Will Barrett with American Lung Association in 8 California. Welcome. We will just ask you to holdfor 9 one minute. 10 (Pause.) 11 MS. AMERLING: Okay. We are going to get star ted 12 now. Thank you for joining us. Ms. Kiss, would yo u 13 begin, please? 14 MR. KISS: Sure, certainly. Good morning. My 15 name is Barbara Kiss. I am the director of environment 16 energy policy at General Motors. I am pleased to s peak 17 to you today regarding the EPA and NHTSA notice of 18 proposed rulemaking to address greenhouse gas and f uel 19 efficiency for medium and heavy-duty trucks. 20 General Motors is a major manufacturer of thes e 21 vehicles. And we want to thank NHTSA and EPA for 22 providing the opportunity to comment on thisPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 120 1 regulation. We have been working closely with both 2 agencies and will continue to do so in order to 3 establish standards for this integral part of the 4 American economy. 5 GM supports the adoption of a national standar d 6 covering these vehicles. And it is paramount that it 7 be consistent with some critical and foundational 8 principles. First, it is imperative for NHTSA and EPA 9 to develop a harmonized approach that does not pena lize 10 both consumers and manufacturers in providing produ cts 11 that continue to serve the purposes, functions, and 12 utilities that are needed. 13 General Motors is supportive of the approach u sed 14 during phase 1 of this initiative and encourages th e 15 continued harmonization of CAFE and GHG regulations . 16 By creating an international standard, we can best 17 maximize resources to produce clean and efficient 18 vehicle, which better align with the emissions 19 reductions standards put in place. 20 Second, the program must continue to recognizethe 21 unique functionality and utility needs of the truck ing 22 industry and that we provide vehicles that preservethePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 121 1 performance integrity of these work trucks. Consumers 2 value the payload and towing capabilities. These 3 working vehicles offered in a work factor-based 4 approach standard set by EPA and NHTSA should conti nue 5 to align with the industry and business needs of th is 6 demographic. 7 Third, we have been gaining valuable experienc e 8 concerning the importance of real-world flexible 9 mechanisms contained in the light-duty vehicle 10 greenhouse gas and fuel economy regulations. And t hese 11 lessons can be applied to the medium and heavy-duty 12 fleets. These mechanisms include recognition for 13 technologies that reduce fuel usage in conditions n ot 14 comprehended on the standard fuel economy tests, su ch 15 as colder weather, higher speeds, or extended idle 16 time. 17 GM intends to provide detailed written comment s 18 and data to support the inclusion of similar mechan isms 19 for the heavy-duty regulation. We have also had some 20 favorable experiences with the extended carryforwar d 21 time allowed in the light-duty regulations, which h as 22 resulted in GM achieving fuel efficiency improvemen tsPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 122 1 sooner than required, thereby providing us greater 2 latitude to manage our product cadence in these ver y 3 competitive market segments. Discounts could also be 4 applied to the medium/heavy-duty segments. 5 The agencies' proposed class 2-B and 3 standar ds 6 based on alternative 3 in the notice of proposed 7 rulemaking will continue to drive innovation and ca use 8 GM to invest in and refine new technologies that bo th 9 are appreciated and optimized by American consumers . 10 This path will challenge our product plan and drive 11 considerable technology into our heavy-duty trucks and 12 vans. While we are cautiously supportive of this p lan 13 for future emissions reduction standards, it is 14 important to note that alternative 3 increases the 15 effective stringency far beyond what is a cursory 16 analysis at 2.5 percent per year would suggest. A 17 combination of procedural, modeling, and fuel chang es 18 results in a more stringent regulation. GM intends to 19 discuss these in detail as part of our written 20 comments. 21 Finally, the program must attempt to minimize the 22 potential for unintended consequences, especially f orPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 123 1 the consumer. The heavy-duty fleet does not benefi t 2 from the years of data that have been collected and 3 analyzed for the light-duty fleet. 4 Further, the utility provided and the duty cyc le 5 of these vehicles is completely different from the 6 light-duty fleet. And any attempt to force more 7 stringent regulations, such as alternative 4, wouldbe 8 extremely detrimental to manufacturers, consumers, the 9 U.S. economy, and the millions of transportation10 related jobs. Indeed, comprehensive data for this 11 product segment is only now being accumulated and 12 analyzed for the 2014 model year, which is the firs t 13 year of phase 1. The data should be carefully 14 evaluated by the technical experts at the agencies and 15 compared to the estimates and assumptions that formthe 16 basis for both phase 1 and the proposed phase 2 17 regulations. 18 As mentioned, we will be providing more extens ive 19 written comments to address the breadth of issues 20 associated with the continued expansion of this 21 program. We look forward to working with NHTSA andEPA 22 to assure the program created is national in scope andPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 124 1 consistent with these principles. 2 Thank you. 3 MS. AMERLING: Thank you. 4 Mr. Bennett? 5 MR. BENNETT: Good morning. I am Jeff Bennett , 6 Vice President, Engineering and Product Developmentof 7 Utility Trailer Manufacturing Company here in 8 California. We are also a member of the TTMA, the 9 Truck Trailer Manufacturing Association. 10 Utility Trailer Manufacturing Company apprecia tes 11 the opportunity to comment on EPA's phase 2 greenho use 12 gas emissions proposed trailer regulations. For over 13 100 years, utility trailer manufacturing has 14 manufactured truck trailers. Every day we strive t o 15 improve the standard of living by providing safe, h igh16 quality transportation products and other services to 17 the transportation industry. Being good stewards o f 18 the Earth is a major part of our mission. 19 Truck trailers must perform reliably and safel y in 20 extremely harsh and at times punishing environments . 21 Trailer design has evolved over time in these 22 environments, which is why there is a great concernPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 125 1 about the proposed EPA greenhouse gas 2 regulation for 2 trailers. 3 The EPA regulations propose to reduce the 4 greenhouse gas output of trucks by employing 5 aerodynamic devices to long and short box trailers. 6 The EPA's underlying analysis is incomplete in its 7 failure to demonstrate how the lifecycle of these 8 aerodynamic devices reduces the net carbon footprin t. 9 These trailer aero devices are typically constructe d 10 from metal and plastic that require extreme heat an d 11 significant quantities of petrochemicals to produce . 12 And once attached to the trailer, they are unlikelyto 13 survive more than a fraction of the trailer's expec ted 14 life. 15 Our freight trailers are expected to last 15 years 16 on average. These aerodynamic trailer devices have 17 only been available since 2010. The early adopter 18 fleets have reported spending over $300,000 per yea r 19 replacing damaged skirts and trailer tails on their 20 long box trailers. As a result, the amount of 21 greenhouse gas output to produce and maintain the 22 devices proposed by the agency is still to this dayPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 126 1 unknown and growing. 2 Currently the claimed fuel savings for trailer 3 aerodynamics devices are significantly overstated. For 4 example, there are many trailer aerodynamics device s 5 approved by the EPA's SmartWay that claim to provide 5 6 to 10 percent fuel savings, but these fuel savings are 7 based on overly simplified tests. Some tests, for 8 example, are conducted at a constant cruise speed o f 65 9 miles per hour on level roads. This is not what 10 happens in the real world. 11 A large long-haul customer fleet of ours measu red 12 and recorded the percentage amount of time that the ir 13 fleet, which consists of 4,000 trucks and 7,000 box 14 trailers, traveled at various speeds over the past 6 15 months. On average, these long-haul trucks spent l ess 16 than 1.3 percent of the time at or above 65 miles p er 17 hour and 40 percent of the time, the truck was stopped 18 while the engine was running waiting for traffic or 19 something else. 20 The submitted graph -- I have submitted this g raph 21 to you guys so you can review it further -- 22 demonstrates all the speeds, percentages of all thePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 127 1 speeds, for this study. This study clearly contrad icts 2 the speeds that the agency used in its GEM 2 analys is, 3 which they used 86 percent of the time at 65 miles per 4 hour cruise speed and they ignored entirely the 0 m iles 5 per hour speed. 6 For a proper fuel savings estimate, the 7 aerodynamics fuel savings measured at each speed mu st 8 be multiplied by the actual percentage of time the 9 truck travels at that speed and summed to an expect ed 10 average savings. The agency has failed to provide such 11 a study. In addition, the agency has proposed trai ler 12 speeds in their analysis that are dramatically grea ter 13 than what has been measured in the field. 14 We have performed and included here a study ba sed 15 on an EPA SmartWay-approved trailer side skirt that 16 measured a 7.5 percent fuel savings per the SAE 132 1 17 type 2 modified certification test at 65 miles per 18 hour. Using a CFD analysis, the fuel savings was 19 determined at each speed from 0 to 5 miles per hour . 20 The aerodynamics fuel savings at each speed was the n 21 multiplied by the actual measured fleet percentage of 22 time at that speed and summed up to arrive at a tot alPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 128 1 cruising speed fuel savings of 1.7 percent across t he 2 total measured speed spectrum for this fleet. This 1.7 3 percent savings applies only to the fraction of the 4 fuel used for cruising at constant speed on flat 5 ground, not for accelerations and not for going uph ill. 6 Thus, the total fuel savings is actually less than the 7 1.7 percent of the total fuel used and not the 7 an d a 8 half percent claimed by the EPA SmartWay. 9 How can less than a 1.7 percent of the total 10 expected fuel savings be measured and used to justi fy 11 the greenhouse gas output required to manufacture, 12 install, and later replace when damaged this traile r 13 aerodynamics device? In addition, the agency has 14 neglected the average trailer-to-truck ratio in the 15 typical trailer fleet. Some of our fleets have two 16 trailers for every truck, which then doubles the 17 required time and the required fuel savings for any 18 greenhouse gas payback to justify the trailer aero 19 device vs. its carbon footprint. 20 The agency stated that it intends not to allowany 21 yaw angle effects to measure efficiencies from trai ler 22 aero devices. From our experience from track testi ngPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 129 1 and CFD analysis, yaw angle or crosswinds increase the 2 fuel savings of side skirts and decrease the fuel 3 savings of trailer tails. Therefore, the agency mu st 4 not ignore the effect of yaw angle on trailer 5 aerodynamics devices. 6 The agencies' impact analysis failed to accoun t 7 for the substantial reduction in tire life associat ed 8 with the type 2 low-rolling resistance tires and fr om 9 using tire inflation systems. This increase in tir e 10 degradation requires additional tire replacement du ring 11 the life of the trailer, which increases the greenh ouse 12 gas output. The agency failed to demonstrate how t hese 13 tires and tire inflation systems will generate 14 sufficient savings to make up for the additional 15 greenhouse gas released into the atmosphere from 16 additional tire replacement during the life of the 17 trailer. 18 The GEM model that the agency has proposed for 19 compliance, which includes the use of bins, would b e 20 unmanageable in the trailer manufacturing industry. 21 Trailers are highly customized to specific customer 22 specifications. And no two orders are alike.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 130 1 MS. AMERLING: Excuse me, Mr. Bennett. I just 2 want to remind you we are trying to ask panelists t o 3 keep remarks within five minutes, just a gentle 4 reminder. 5 MR. BENNETT: I am done. I am concluding. 6 MS. AMERLING: Okay. 7 MR. BENNETT: A better approach would be for t he 8 OEM to pick from a list of EPA-approved devices and 9 install on all trailer orders where practicable. 10 Utility Trailer Manufacturing and its customer s 11 welcome any technology that truly reduces the totalnet 12 greenhouse gas output and costs associated with a s afe, 13 clean, and efficient delivery of goods to American 14 consumers. We support EPA's goal but warn against 15 regulations that can overstate fuel and greenhouse gas 16 reductions and that may actually increase greenhous e 17 gas output and not achieve the goal of a cleaner, s afer 18 environment. 19 Thank you. 20 MS. AMERLING: Thank you so much. 21 Next we have Gary Oshnock with Fiat/Chrysler. 22 Welcome.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 131 1 MR. OSHNOCK: Thank you. 2 Good morning. My name is Gary Oshnock. I am the 3 manager responsible for the NAFTA fuel economy and 4 greenhouse gas regulatory compliance at the FCA US LLC, 5 Fiat/Chrysler. The FCA US product lineup features some 6 of the world's most recognizable trucks and engines in 7 this segment. Those trucks include the class 2 thr ough 8 5 variants of our popular Ram pickups and our class 2-B 9 Promaster commercial vans. Our gasoline engines 10 include the award-winning 3.6-liter Pentastar V6 an d 11 the 5.7-liter and 6.4-liter HEMI V8 engines. And o ur 12 diesel engines include the class leading 6.7-liter 13 Cummins turbodiesel I6 and our 3-liter EcoDiesel I4 . 14 Thank you for the opportunity to speak here to day 15 and show support for the U.S. EPA and NHTSA efforts to 16 develop the second set of greenhouse gas and fuel 17 consumption rules for the medium and heavy-duty veh icle 18 segment. 19 We fully support and commend this 2019 through 20 2027 model year phase 2 initiative, as we did the 21 collaboration that produced the national phase 1 ru le. 22 FCA US remains committed to the proliferation of cl eanPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 132 1 technology and reducing vehicle operating costs whi le 2 ensuring our products continue to deliver the 3 performance and functionality our customers demand and 4 deserve. 5 As EPA and NHTSA noted in the light-duty progr am, 6 a single national program "holds out the promise of 7 delivering environmental and energy benefits, cost 8 savings, and administrative efficiencies that mightnot 9 be available under a less coordinated approach." F CA 10 US unequivocally agrees. While we are still analyz ing 11 the proposed rule, I have a few initial comments an d 12 suggestions. 13 We support EPA's and NHTSA's attribute-based 14 standards that recognize the utility and functional ity 15 of these work trucks. Payload and towing capacity are 16 important to the owners of these work trucks. Thes e 17 work factor-based standards acknowledge the inheren tly 18 higher greenhouse gas emissions and fuel consumptio n of 19 higher-capability vehicles. While the light-duty 20 vehicle fleet has been regulated under the NHTSA CAFE 21 program for roughly 40 years, we are still very ear ly 22 in the heavy-duty program. We formally have one fu llPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 133 1 model year of industry data under our belt. 2 Given this limited baseline of real data, it i s 3 concerning that there have been calls for even grea ter 4 stringency beyond the aggressive standards proposedby 5 EPA and NHTSA for phase 2. Comments regarding 6 stringency need to address many contributing factor s, 7 both explicit and implicit. 8 These factors include, but are not limited to -- I 9 have noted five here. Number one, these work truck s 10 have a wide range of duty cycles. So the values of 11 different technologies vary from a customer 12 perspective. Number 2, the challenges of a year-over13 year stringency increase with effectively only two 14 products available to average in this 2-B and 3 15 segment, for us, that is essentially a pickup and a 16 van, a full-sized van, with many variants; number 3 , 17 the concurrent stringency increases in tier 3 and L EV 18 III criteria emission requirements and how to manag e 19 the increased thermal loads and after-treatment 20 systems; number 4, the impact of changing test fuel s 21 and the test procedure adjustments that will be nee ded 22 going into the future. And, number 5, additionalPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 134 1 technologies will be needed given that some phase 2 2 technologies are already in our fleet today. For 3 example, FCA US has cylinder deactivation and cool EGR 4 in today's vehicles, making these technologies 5 unavailable for improvements in phase 2. 6 FCA US strongly believes that a single nationa l 7 fuel consumption and greenhouse gas program will pl ace 8 more clean and efficient vehicles on the road quick ly 9 and at lower cost. Our resources are best utilized 10 when applied to one single national standard versus 11 differing state-level fuel consumption and greenhou se 12 gas requirements. 13 As far as a/c system improvements go, air 14 conditioning system improvements, we believe there is 15 value in recognizing the greenhouse gas and fuel 16 consumption contributions from reducing the energy 17 demand of the a/c systems. We also believe there i s an 18 additional opportunity to further harmonize with th e 19 light-duty program and recognize the added greenhou se 20 gas emission benefit beyond leak reduction that 21 switching to a lower global warming potential 22 refrigerant can provide.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 135 1 We support the flexibility mechanism included in 2 the rule, averaging banking and trading, and the 3 recognition of technology benefits not captured on 4 laboratory drive cycles. We will work with the 5 agencies to make these processes more efficient in the 6 second phase of this program. 7 In closing, FCA US will continue reviewing the 8 proposed rule and submit these and other comments a s 9 part of the formal rulemaking process. We will wor k 10 with EPA and NHTSA and other stakeholders to ensure 11 that an implementable rule is finalized on schedule . 12 Thank you. 13 MS. AMERLING: Thank you. 14 Mr. Solomon, welcome. 15 MR. SOLOMON: Thank you very much for the 16 opportunity today. 17 My name is Matt Solomon. I am the transportat ion 18 program manager for the Northeast States for 19 Coordinated Air Use Management. NESCAUM is the 20 association of air pollution control agencies in 21 Connecticut, Maine, Massachusetts, New Hampshire, N ew 22 Jersey, New York, Rhode Island, and Vermont. MyPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 136 1 testimony reflects the majority views of NESCAUM as a 2 state membership organization. Individual NESCAUM 3 member states may hold views different from the NES CAUM 4 states' majority consensus. 5 Our states commend EPA and NHTSA for proposing 6 rules that will lead to substantial reductions in 7 greenhouse gas emissions from the heavy-duty sector . 8 In particular, we applaud the agencies for maintain ing 9 in their proposal a separate engine standard, whichwe 10 see as critical to the integrity of the proposed ru le. 11 However, the rule as proposed does not take full 12 advantage of available and proven technologies and 13 should be made stronger in several areas. 14 In addition, our states remain strongly concer ned 15 about NOx emissions from this sector and urge EPA t o 16 begin rulemaking to require further reductions in NOx 17 from the heavy-duty trucks at the earliest possible 18 date. 19 I will now briefly mention several specific ar eas 20 in which the rule can and should be strengthened. 21 First, the agencies should adopt the timeline propo sed 22 in alternative 4. Given that the proposed technolo giesPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 137 1 are already mature or have been successfully 2 demonstrated and given our states' need for signifi cant 3 greenhouse gas reductions in the near term, the 4 timeline proposed in alternative 4 is both reasonab le 5 and appropriate. Based on the assessments of the 6 California Air Resources Board and the Internationa l 7 Council on Clean Transportation, a full phase-in ofthe 8 rules by 2024 is technologically feasible. Given t he 9 scope of needed greenhouse gas reductions, and the 10 compelling benefits to freight industries and their 11 consumers from reduced fuel expenditures, 2027 is t oo 12 long to wait to realize the full potential of this 13 rule. 14 Second, EPA should address the potential for 15 further NOx reductions at the earliest possible dat e. 16 Heavy-duty trucks represent the second largest sour ce 17 of NOx emissions in the NESCAUM region, and our sta tes 18 remain very concerned about the need to further con trol 19 NOx emissions from this sector. We thank the agenc ies 20 for acknowledging the challenge that states continu e to 21 face in this regard, and we urge EPA to begin a 22 rulemaking without delay to ensure that the nextPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 138 1 generation of trucks is not only more fuel-efficien t 2 but also much less of a contributor to our states' air 3 quality and public health problems. 4 The engine standard should be stronger. The 5 proposal would reduce fuel consumption from engines by 6 only 4 percent, which is far short of what is 7 achievable over the coming decade. We note that at 8 least one engine manufacturer has indicated potenti al 9 engine efficiency improvements of 15 percent or mor e 10 even with advanced NOx controls. Moreover, the 11 agencies' estimates for both the effectiveness and 12 likely market penetration of engine efficiency 13 technology improvements are far too conservative, 14 according to analyses performed by CARB and ICCT. 15 Certain other requirements should also be 16 stronger. Commensurate with increased engine 17 stringency, the tractor standards should be 18 strengthened to ensure that manufacturers utilize t he 19 full suite of appropriate complementary technologie s, 20 in addition to engine improvements. The agencies a lso 21 should consider strengthening the provisions for 22 vocational vehicles, including the use of aerodynam icPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 139 1 controls. 2 There should be no backsliding on PM from 3 increased APU use. We also urge the agencies to en sure 4 that there are no increases in emissions from eithe r 5 NOx or PM2.5 as a result of the proposed rule. We note 6 that the agencies project an increase in PM2.5 as a 7 result of increased APU use. While idle reduction 8 represents an important opportunity for fuel saving s, 9 any increase in this harmful pollutant is unacceptable, 10 particularly given that appropriate PM control 11 technology for APUs is already in the marketplace a nd 12 currently required by CARB. EPA should adopt simil ar 13 requirements to CARB's for PM control on APUs and 14 should do so concurrently with this proposed phase 2 15 rulemaking. 16 Finally, a note on glider kits. We strongly 17 support the proposed measure to ensure that glider kits 18 are subject to the same applicable regulations as o ther 19 new trucks. This common-sense measure will prevent 20 gaming and will avoid significant amounts of 21 unnecessary emissions of greenhouse gases, NOx, andPM. 22 The agencies request comment on the appropriatePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 140 1 magnitude of the exemption. While we agree that some 2 minimal exemption opportunity is probably appropria te 3 in limited cases, we urge the agencies to set this 4 number as low as is practical without impeding smal l 5 businesses with legitimate claims. 6 In conclusion, the NESCAUM states commend the 7 agencies for a diligent and thorough analysis and f or 8 proposing a rule which is appropriate in structure and 9 scope. However, the agencies should also strengthe n 10 certain provisions to maximize the benefits from th is 11 important program. In addition, EPA should ensure that 12 emissions of other pollutants do not increase as a 13 result of the rule and should commence rulemaking t o 14 reduce NOx from heavy-duty vehicles at the earliest 15 possible date. 16 Thank you. 17 MS. AMERLING: Thank you, Mr. Solomon. Now we 18 turn to Ms. Hart. 19 MS. HART: Hi. My name is Diane Hart. I am a 20 member of the Union of Concerned Scientists, and I come 21 today as a concerned citizen. 22 I am a native Californian. I was born inPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 141 1 Hollywood, and I grew up in Van Nuys in the San 2 Fernando Valley. I can remember as a young girl ho w 3 smoggy it would get and how hard it was some days t o 4 breathe. On the really bad days, your eyes would 5 water. The sky would actually get yellow. And whi le 6 this was very great for beautiful sunsets, it didn' t 7 make for very good breathing. 8 Everybody fussed at the idea of catalytic 9 converters. The car companies screamed they would go 10 out of business. After catalytic converters were 11 installed, the air was much, much cleaner, and the car 12 companies continued to thrive. 13 I was amazed to learn that the new standards w ould 14 cut oil by a million barrels every two days. By no t 15 burning that oil, the United States would over the 16 lifetime of trucks affected by the rule avoid one 17 billion metric tons of global warming emissions. S o I 18 am asking you to strengthen the standard to achieve40 19 percent fuel savings by 2025. 20 One of the things I found, life gets a little 21 tougher as you get older. So let's work to improveat 22 least the breathing part.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 142 1 Thank you. 2 MS. AMERLING: Thank you. 3 Mr. Barrett, welcome. 4 MR. BARRETT: Thank you very much. 5 My name is Will Barrett with the American Lung 6 Association. First of all, I wanted to say that th e 7 American Lung Association shares the administration 's 8 views that climate change, first and foremost, 9 represents a public health crisis and a public heal th 10 opportunity. 11 Earlier this year, we launched a public awaren ess 12 campaign called Doctors for Climate Health to bring 13 this point home here in California. 14 We also support EPA's efforts to update all ofthe 15 standards to mesh the scientific understanding of t he 16 harms we face from criteria air pollutants, toxics, and 17 climate change. We view this joint phase 2 rule 18 proposal as an important step in this direction, bu t we 19 do feel that more is needed to address California's 20 urgent air quality problems. 21 This past April, the American Lung Association 's 22 16th annual state of the air report once again foun dPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 143 1 that the Los Angeles metropolitan area is among the 2 most polluted in the nation for both ozone and part icle 3 pollution. Transportation sector emissions are the 4 leading reason for this. And that pollution from o ur 5 transportation sector threatens the health of all 6 residents of this region but especially our childre n, 7 seniors, people living with asthma, COPD, and other 8 respiratory and cardiac issues. Pollution from the 9 transportation sector is an added burden for those 10 communities most disadvantaged by multiple pollutio n 11 sources, including refineries, ports, rail yards, a nd 12 the many freeways that carry the nation's goods thr ough 13 these communities first and the most. 14 The residents of Southern California and the S an 15 Joaquin Valley here in California have perhaps the most 16 to gain from a strong rule of any area in the natio n. 17 In the past month, we have seen record temperatures , 18 raging wildfires, torrential flooding, and a persis tent 19 drought that has really grown over the last four ye ars 20 into a major threat to air quality. 21 So the American Lung Association offers the 22 following recommendations to strengthen the stringe ncyPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 144 1 and the timing of the proposal and to address sever al 2 key elements of California's ongoing commitment to 3 protecting public health, which I know is shared byeh 4 agencies. 5 We believe the rule should, as has been stated 6 already, achieve a 40 percent fuel savings and the 7 implementation period should follow alternative 4, 8 bringing the rule online by 2024. The urgency of 9 climate change and the air pollution challenges in 10 California indicate that we need all emission 11 reductions as soon as possible to protect public 12 health. A stronger standard and the timeframe unde r 13 alternative 4 will help drive down emissions soonerand 14 help move us faster down the road to clean and heal thy 15 air. 16 Secondly, we urge EPA to immediately begin a l ow17 NOx emission rulemaking on the national level. EPA 18 should begin a new low-NOx standard concurrently to 19 ensure that all trucks working in California and ac ross 20 the nation are held to the standards we need to rea lly 21 protect our citizens from ozone pollution. 22 California's clean air progress must be protectedPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 145 1 against ongoing interstate truck traffic with highe r 2 emissions. With a stronger ozone standard on the 3 horizon, a national low-NOx standard will help all 4 regions with attainment but especially the extreme 5 nonattainment areas here in California. 6 Third, advanced technology credits should be 7 maintained in the proposal, rather than phased out. 8 Given the severe air quality conditions in the Sout h 9 Coast and San Joaquin Valley that many have discuss ed 10 already today, California really truly needs zero11 emission technologies to move our freight and move 12 goods throughout our state. 13 Without a strong commitment to advanced 14 technologies in the proposal, advanced technologies and 15 electrification in the proposal, the overall rule w ill 16 miss a critical tool that California needs to prote ct 17 public health. In particular, we view battery 18 electric, fuel cell, hybrid, and other advanced 19 technologies as vital to achieving the major reduct ions 20 needed here in California. Retaining the focus on 21 advanced technologies will also allow for a stronge r 22 overall standard and greater health and fuel savingPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 146 1 benefits to be achieved. 2 Lastly, as has been stated by several others a s 3 well, we believe that diesel particulate pollution from 4 the increased use of APUs must be reduced through 5 filters. The projected increase in APUs and the 6 associated particle pollution increases must be 7 mitigated with the use of filter, particle filter, 8 systems, as are required now in California. We simply 9 cannot afford tradeoffs in the rule that would allo w 10 for increased carcinogenic soot or climate-forcing 11 black carbon emissions to increase. 12 In closing, the American Lung Association urge s 13 you to continue on with the rulemaking by strengthe ning 14 the proposal with the more rapid implementation of a 15 stronger standard, beginning a low-NOx standard pro cess 16 immediately, maintaining a greater focus on advance d 17 technologies and zero-emission technologies, and 18 preventing any increase in particle or other pollut ants 19 through the implementation of the rule. 20 We appreciate the opportunity to speak with yo u 21 today and look forward to continuing to work togeth er 22 with you with our Air Resources Board here inPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 147 1 California, the local air districts to really conti nue 2 the fight that we are all in to protect public heal th. 3 Finally, as a parent of two daughters in 4 elementary school who are starting school next week , I 5 wanted to thank you for putting forward a proposal that 6 will help protect our future and hope we can contin ue 7 working on that. 8 So thank you very much. 9 MS. AMERLING: Thank you. 10 Are there questions for the panel? 11 MR. CHARMLEY: I had for Mr. Bennett one just 12 clarification and then one question. Could you 13 clarify, were your comments on behalf of Utility orwas 14 it Utility and TTMA or was it just your company? 15 MR. BENNETT: Right now it's Utility Trailer. 16 MR. CHARMLEY: Okay. Thank you. 17 MR. BENNETT: But we are working with TTMA als o. 18 The comments I have here were my own. 19 MR. CHARMLEY: Okay. Thank you. 20 And I had one question for you. You mentionedI 21 think you said the agencies appropriately consider if 22 lower-rolling resistance tires have faster -- you h adPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 148 1 mentioned about the potential for a lower-rolling 2 resistance tires to have faster turnaround, meaning 3 they don't last as long. 4 I know that the American Trucking Association, 5 their Technology and Maintenance Council, did a survey 6 last year. And they gave us the results this past 7 February or March that were rather inconclusive on this 8 point, meaning I think most of the TMC members had 9 thought that the lower-rolling resistance tires wou ld 10 have faster replacement requirements, but when theyhad 11 done a survey, which they acknowledged was not 12 necessarily scientific, it was a survey of their 13 members, it showed that there wasn't any meaningful 14 difference on average. 15 And so I wanted to know that to the extent tha t 16 Utility has information or data that they could sha re 17 and submit during the written comment period on tha t 18 very issue, either your own experience or the 19 experience of your customers, on that issue, any da ta 20 that you could submit would be very helpful. 21 Thank you. 22 MR. BENNETT: Sure.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 149 1 MS. AMERLING: Other questions? 2 MR. SILVERMAN: I have a couple of questions f or 3 Mr. Solomon. If I heard you right, you were sugges ting 4 aerodynamic improvements as part of the vocational 5 vehicle standard. And in your written comments, we 6 explained at page 303 of the preamble why we were n ot 7 proposing that. So if you could comment to the 8 specifics of why we indicated we didn't think therewas 9 a basis for that, we would appreciate that, those 10 specific comments. 11 MR. SOLOMON: Sure. Yes. We are obviously st ill 12 continuing to pore over the details of the rule, bu t we 13 will make sure to touch on that specifically in our 14 detailed written comments. 15 MR. SILVERMAN: In particular, you know, we lo oked 16 at average speeds and did not see that there would be 17 commensurate improvements given the average speed o f a 18 vocational vehicle, but that issue was open for 19 comment. 20 The other thing I wanted to ask you was about 21 glider kits, if you have any position about when th at 22 standard should be implemented. We proposed 2018, butPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 150 1 we asked for comment on an earlier date. 2 MR. SOLOMON: Yes. We are continuing to 3 investigate that. And we will include some 4 recommendations on that in our written comments. 5 MR. SILVERMAN: Good. Thank you. 6 MS. AMERLING: Any further questions? 7 (No response.) 8 MS. AMERLING: Many thanks to all of you for y our 9 comments. 10 MR. GRUNDLER: Panel 7, come on down, panel 7. I 11 would like to welcome Bill Van Amburg from CALSTART , 12 Cynthia Williams from the Ford Motor Company, Miche lle 13 Kinman from Environment California, Urvi Nagrani fr om 14 Motiv Power, and Jonathan Fleck from Deflecktor Aer o 15 Wheel Covers. Welcome. When you are ready, Bill. 16 MR. VAN AMBURG: Very good. And I realize tha t we 17 are the panel keeping you from lunch. So we will move 18 with alacrity. 19 First of all, CALSTART appreciates the opportu nity 20 to provide the comments on the draft phase 2 rules. 21 EPA and NHTSA staff have both been exceptionally 22 collaborative on this. We want to commend the staf fs.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 151 1 You have been open in the process as you work with 2 industry. And we look forward to continuing our wo rk 3 with you as well as with our stakeholders to finali ze 4 these regulations by next spring, which is a critic al 5 timeline. 6 By way of background, for those who don't know , 7 CALSTART is a California-based national clean 8 transportation technologies nonprofit, a coalition of 9 about 150 companies and agencies. Our mission is t o 10 grow a clean transportation industry. So that 11 obviously is our bias. But we definitely support 12 developing strong, effective fuel economy regulatio ns. 13 It is a key component of reducing greenhouse gas 14 emissions, not just through the end of your rule 15 horizon but being on the glide slope, if you will, to 16 midcentury climate change stability goals. 17 With our base in California, we are very sensi tive 18 to the climate change imperative, but we are also very 19 focused on the strong fuel efficiency regulations a s a 20 driver of American technology and economic 21 opportunities that go with it. Many of the advance d 22 efficient technologies that will be needed will bePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 152 1 built and commercialized first in the U.S. because of 2 this rule, and we think that is an additional 3 co-benefit that often doesn't get measured. 4 Now, we are going to offer more complete comme nts 5 to you -- it is a very thoughtful and, therefore, l ong 6 and complex rule -- for the docket. Today I would like 7 to share with you, though, some results of a just8 completed fleet benefit study that we have complete d 9 and then some preliminary high-level observations o n 10 the rule. 11 The new report is titled "Higher Fuel Efficien cy 12 Working for Fleets," and it was built around assess ing 13 what the real business case is from the fleet levelfor 14 higher-efficiency trucks that might be driven by a new 15 high-efficiency rule. We worked with a cross-secti on 16 of fleets representing various applications and tru ck 17 types nationwide to validate the key components of a 18 business case assessment. We collaborated with the 19 NAFA Fleet Management Association to build that. 20 Now, in developing the model, it was interesti ng. 21 We surveyed fleets for their support for and concer ns 22 about fuel efficiency regulations. And we found,Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 153 1 interestingly, 87 percent of the fleet managers whodid 2 respond to our survey -- and I am not going to pret end 3 this was a scientific survey, but of those we worke d 4 with, 87 percent support stronger rules for fuel 5 efficiency. And their primary concern around it wa s 6 cost. They are worried, can we afford to get the 7 higher fuel efficiency and the benefits that go wit h 8 it? 9 And 89 percent said they would be willing to p ay 10 more up front if they felt that there was a payback 11 over the life of the vehicle. They also expressed 12 concerns about reliability and maintenance costs, n ext13 tier concerns. 14 Now, using the lifecycle cost model that we 15 validated with these fleets through this survey andin16 depth conversations we had, we assessed business ca ses 17 in seven specific truck use profiles, class 8 tract ors 18 on the high end, all the way down to class 2-B pickups 19 and vans on the low end. While we did this before your 20 draft rules came out, the categories we used were very 21 similar to the vocational categories you are propos ing 22 and generally which we do support.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 154 1 We looked at different technology packages tha t 2 were most applicable to each use profile. And theyare 3 different. We assembled the packages that could 4 achieve up to a 40 percent fuel economy improvement 5 over 2010 baseline trucks. And we used National 6 Research Council and TRB studies to adapt for the c ost 7 projections. 8 Now, I will provide copies of the report. So we 9 don't deep-dive into all of the details, but we did 10 find there is a reasonable business case payback ba sed 11 on fleet-validated assessment tools for higher fuel

12 efficiency trucks at the levels proposed in your ru les. 13 Indeed, the stringency levels that we modeled in ou r 14 report in most cases were actually higher than thos e 15 proposed in alternative 3. 16 We saw the potential for higher fuel economy 17 targets than those proposed in several use profiles , 18 particularly urban trucks, regional trucks, and 19 vehicles with high worksite idle time. 20 The biggest variables, as you reported in yourown 21 document, were certainly around utilization, mileag e, 22 and fuel used, and the up-front cost of the technol ogyPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 155 1 being the key variables. And fleets have suggestedto 2 us that they would like to see us model payback 3 sensitivity to maintenance costs since that is stil l an 4 unknown as we go forward. 5 Now, in shaping the final rule, we believe you r 6 payback projections are actually reasonable and rea l. 7 Indeed, we see a strong case for higher efficiency 8 targets than those currently called for in several 9 vocational segments. However, some of the technolo gy 10 that can provide this efficiency, such as hybrid an d 11 electric systems, which have been mentioned, will 12 likely not be driven by the current rule stringency 13 targets around vocational. And they are critical t o 14 regions such as California and in the Northeast for 15 some of their compliance goals. 16 Now, fleets do have reliability and concerns about 17 maintenance. And those are worth considering. You r 18 stairstepped approach actually is a very smart way to 19 go about that. But we do believe the rule could be 20 bolstered with greater stringency that might be coupled 21 with additional rule flexibility, such as bringing back 22 the advanced technology credits and/or potentially aPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 156 1 market around advanced credits and a streamlining o f a 2 clear off-cycle credit process to make sure that 3 affordable and achievable efficiency gains do not g et 4 left off the table. 5 Those are our observations at this time. We w ill 6 have much more detail in our written comments, but we 7 do very much look forward to working with the agenc ies 8 to explore these issues. 9 MR. GRUNDLER: Thank you, Bill. Very good 10 comments. 11 Ms. Williams, Ford Motor Company? Welcome. 12 MS. C. WILLIAMS: Good afternoon. My name is 13 Cynthia Williams. I am the associate director of t he 14 Vehicle Environmental Regulatory Strategy and Plann ing 15 Department at Ford Motor Company. It is a pleasureto 16 be here today to provide Ford's perspective on this 17 very important rulemaking. 18 First of all, we would like to commend EPA and 19 NHTSA in this difficult task in preparing the secon d 20 phase of their greenhouse gas and fuel efficiency 21 standards for medium- and heavy-duty trucks and 22 engines. Moreover, we commend the agencies for wor kingPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 157 1 closely with the California Air Resources Board in 2 developing these proposed standards. We are commit ted 3 to working with EPA, CARB, and NHTSA to finalize th ese 4 regulations as a single national program that would 5 allow manufacturers to build or continue to build a 6 single fleet of vehicles and engines. 7 Commercial truck customers demand technologies 8 that provide a value for money while providing truc k 9 functionality. Whether it is volume for people or 10 cargo carrying, whether it is to haul huge loads or 11 just work off-road, fuel economy continues to be ve ry 12 important to our commercial truck customers. And F ord 13 has invested in technologies to maintain or even ex ceed 14 customer satisfaction. You will continue to see us 15 offer vehicles that deliver outstanding quality and 16 features that our customers desire. 17 Ford's complete and incomplete vehicles in thi s 18 segment consist of the transit and Econoline vans, the 19 F super-duty trucks, and motor homes. 20 The second phase of this proposal offers 21 challenging greenhouse gas and fuel economy targets , 22 particularly in the context of the new emissionsPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 158 1 standards and changes to test fuels that are also 2 occurring in the same time period. These external 3 factors increase the effective stringency and 4 technology-forcing aspects of the heavy-duty greenh ouse 5 gas proposal beyond what the numerical value of the 6 standards alone would suggest. In fact, Ford proje cts 7 that many of these technologies, assumed not to be 8 required until final 2027 timeframe, are actually 9 present and will likely be included in the 2024 10 timeframe just to make up for some of these externa l 11 factors. 12 As mentioned earlier, we offer essentially two 13 complete vehicles: a van and a pickup truck. With 14 limited opportunities to implement significant product 15 actions, it becomes critically important to provide 16 manufacturers with adequate lead time to meet these 17 requirements. 18 As with phase 1, the proposal includes a rangeof 19 compliance mechanisms, such as the ability to carry 20 forward credits from prior model years as well as 21 vocational engines, average banking and trading 22 provisions. Ford supports the expansion of phase 1 .Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 159 1 That would account for CO2 improvements for 2 technologies providing on-road fuel consumption 3 benefits that are not captured by emissions test cy cles 4 or models. 5 Ford supports the establishment of standards t hat 6 recognize the needs of the trucking industry and ot her 7 commercial users, increase the use of known technol ogy 8 found to be feasible and effective in this market 9 segment, preserve the utility and functionality of 10 these commercial vehicles while maintaining separat e 11 gasoline and engines targets are compatible with 12 complexities of the marketplace and avoid unintende d 13 consequences. 14 Ford agrees with the revised EPA and NHTSA 15 approach that uses a sophisticated model, the 16 greenhouse gas GEM model, to both drive power trainand 17 chassis improvements. That being said, Ford does h ave 18 concerns with the accuracy of the model for vocatio nal 19 vehicles, particularly in the case with heavy-duty 20 engine, gasoline engines, and light-duty diesel 21 engines. 22 Ford recommends that data be used to validate thePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 160 1 model and intended duty cycle definitions for these 2 engine-vehicle combinations. Ford will provide 3 detailed written comments on this subject once we f ully 4 evaluate the model and will continue to work with E PA 5 and NHTSA to provide data to support the refinementof 6 the GEM model. 7 Finally, Ford recognizes the benefit of the 8 country for continuing a uniform national program t o 9 address greenhouse gas and fuel efficiency from med ium10 duty vehicles and engines. The EPA and NHTSA phase1 11 proposal was the first step in providing clarity, 12 certainty, and flexibility necessary to achieve 13 greenhouse gas emission reductions that we all shar e. 14 The phase 2 proposal builds and expands on thi s 15 progress, setting challenging targets for the indus try 16 for the next decade. Once again, Ford appreciates the 17 opportunity to provide our testimony here today. And 18 we look forward to providing detailed comments and 19 continuing to work with the agencies to finalize a 20 commitment that all parties can adhere to. 21 Thank you. 22 MR. GRUNDLER: Thank you, Cynthia.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 161 1 Ms. Kinman, welcome. 2 MS. KINMAN: Good afternoon. My name is Miche lle 3 Kinman, and I am the clean air advocate for Environment 4 California Research and Policy Center, which is a 5 statewide environmental organization. I am also 6 representing our national partner: Environment Ame rica 7 Research and Policy Center. And, last but not leas t, I 8 am a mother living here in Torrance. And I am deep ly 9 concerned about climate change, air pollution, and the 10 resulting health impacts on our children, especiall y 11 those who live, play, and breathe in close proximit y to 12 freeways and busy roads. 13 Anyone who has ever been stuck behind an 18- 14 wheeler knows just how much they can pollute. But the 15 good news is that making trucks go farther on a gal lon 16 of fuel can curb pollution, help save our planet, a nd 17 save money. 18 We applaud the Obama administration for propos ing 19 standards that will over the lifetime of trucks 20 affected by the rule avoid one billion metric tons of 21 global warming emissions. While this is a strong s tep 22 in the right direction, we urge you to strengthen t hesePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 162 1 standards to ensure the greatest reductions in oil use 2 and global warming emissions. 3 Specifically, Environment California and 4 Environment America support strengthening the standards 5 to achieve 40 percent fuel savings by 2025, which w ould 6 save an additional 200,000 barrels of oil per day i n 7 2035 and avoid an additional 40 million metric tons of 8 global warming emissions annually according to anal ysis 9 by our colleagues at the Union of Concerned Scienti sts. 10 That is the equivalent of shutting down not 1, not 2, 11 but 12 coal-fired power plants. And it would save the 12 average big rig driver $30,000 in annual fuel costs in 13 2025. It is new technology that pays for itself in 14 just over a year. 15 Additional gains could be made through improve d 16 aerodynamics on trailers; improvements in heavy-dut y 17 pickup trucks; and more efficient engines and tract or18 trailers; as well as integrating new technology, su ch 19 as hybrid and electric drive trains in the heavy-du ty 20 vehicle market. 21 It is critical that the proposal be expanded t o 22 capture the full suite of cost-effective solutionsPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 163 1 available for each type of heavy-duty vehicle. Thi s 2 stronger proposal would mean a triple win for clean 3 air, the climate, and consumers. And I urge you togo 4 the extra mile and finalize stronger standards to 5 reduce trucks' fuel use by 40 percent by 2025. 6 Thank you for the opportunity to provide comme nt. 7 MR. GRUNDLER: Thank you very much. 8 Next we have Ms. Nagrani. Welcome. 9 MS. NAGRANI: Good morning. Like all of my 10 colleagues, I am going to start by thanking you. Y ou 11 are having to listen to a lot of us. And that on i ts 12 own is its own chore, unlike just creating the bill , 13 which is quite impressive. 14 A lot of comments today have been made about t he 15 stringency and going towards unnecessary versus 16 appropriate or inadequate. And there has been a lo t of 17 oscillation depending on whether you are talking toa 18 business or whether you are talking to an environme ntal 19 advocate. I think it is very important to recogniz e as 20 a business working in the electrical space, that we 21 want those stringency rules to seem unreasonable. We 22 want them to push the industry to do things better thanPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 164 1 they have ever had to do them because what is 2 considered good today is inadequate. What is 3 considered good today is responsible for the poor a ir 4 quality here. What is considered good today and wh at 5 has been considered progressed to date has allowed one 6 in five children in the San Joaquin Valley to use a n 7 inhaler. 8 Now, if we consider that a problem, what we have 9 to face today, then these standards should err towa rds 10 being unreasonable because then these fuels become 11 bridge fuels. And you are going to have to think about 12 advanced technologies and actually push innovation. 13 Presently in California, if you look at the wa y 14 the structuring of the alternative fuel vehicle 15 technology program is structured, you have the CEC 16 pushing R&D. You have CARB pushing for commercial 17 development. And by the end of those agencies' wor k, 18 you have what should be a market-ready technology. 19 The portfolios of projects coming out of both the 20 CEC and CARB have shown tremendous growth. And CARB's 21 working with you to make sure that this rule is 22 effective is a clear sign that these technologies w illPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 165 1 be well-positioned to start to make it into the 2 national markets. However, additional pressure in 3 other states on a national scale will be needed for 4 these vehicles to not only hit the Californian market 5 but nationally. 6 In the most recent CARB budget, there are two 7 specific elements that have been carved out based o n 8 multisource and drayage. Those are meant to addres s 9 some of the concerns here about areas like Long Bea ch, 10 which have unusually bad air quality because of the 11 amount of goods that are coming into California and 12 going out towards the rest of the nation. However, 13 even if you were to take the entire port and make i t 14 all electric, you would still have port air quality 15 because of these trucks, which don't have a nationa l 16 standard. 17 So I urge you to not only go with the standard s 18 being proposed but strengthen them, as many 19 environmental organizations have supported, becauseif 20 you look around the room today, industry is well21 represented. And everybody from industry has thanked 22 you because you have worked with them. But what is notPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 166 1 represented in the room is citizens who are dealing 2 with the impacts. 3 I don't own a school bus. I don't own a garba ge 4 truck. I don't own a work truck. But I breathe th e 5 air that is polluted by all of those. And your 6 standards will help impact a positive future for my 7 lungs. I definitely was one of those kids who had 8 problems in cross-country because midway through a 9 race, I would have an asthma attack. That is not 10 something we really want our kids to deal with as well. 11 Motiv Power Systems as the builder of an all12 electric power train is working to build the next 13 generation of trucks that will be on the road today . 14 The first all-electric refuse truck in the nation i s on 15 the streets in Chicago. The first all-electric sch ool 16 bus in California is on the roads in King's Canyon 17 taking kids to school today. And all-electric shut tle 18 buses are driving Google employees around Mountainv iew. 19 It is possible for us to do better. And it is 20 possible to make it more costly and expensive to dothe 21 things that are hurting our air today. 22 Thank you for your time. And I also want to s ayPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 167 1 thank you for keeping your patience as we approach 2 lunch. 3 MR. GRUNDLER: Well done. 4 Mr. Fleck, welcome. 5 MR. FLECK: Hello. Thank you. 6 My name is Jonathan Fleck. I live in Minnesot a. 7 My company, ADF Limited, brought the Deflecktor 8 Aerodynamic Wheel Cover, made of fabric, to the mar ket. 9 Our product is standard equipment on the Freightlin er 10 Cascadia Evolution model long-haul truck, which 11 receives credits from EPA under the phase I framewo rk. 12 The smart folks at Freightliner made a series of 13 tweaks, many, like ours, in the area of aerodynamic s, 14 to their existing 2010 EPA-certified Cascadia, and 15 created the 2014 Cascadia Evolution, which is a ful l 7 16 percent more efficient. 17 Our product on that truck is visually quite 18 impactful, as it covers approximately 10 square fee t of 19 cavity, of wheel cavity area. It is a wheel cover. .. 20 We have sold hundreds of thousands of these simple 21 wheel covers. And I want to applaud EPA on 22 incentivizing small, incremental, innovativePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 168 1 technologies that ultimately add value in the big 2 picture. 3 A lot of times, we underestimate the increment al. 4 And when that incremental is scalable, we may very well 5 miss meaningful opportunities that move us to our 6 ultimate goal, in this case CO2 mitigation. 7 Today, our product can be seen approximately 1 2 8 times an hour on trucks in freight lanes across Ame rica 9 on any given day. That number will more than doubl e by 10 this time next year based on deliveries. 11 Our first customer, Schneider National, a char ter 12 member of EPA's SmartWay transport partnership, has 13 deployed our product fleet-wide. In a press releas e, 14 in March of 2010, Schneider National announced flee t15 wide use of our product on their 12,000 trucks, sta ting 16 fuel savings of 150 gallons per truck per year base d on 17 their average fleet speed of 47 miles an hour. Thi s 18 savings, approximately 1 percent, equates to 40 mil lion 19 fewer pounds of CO2 each year for just that fleet 20 alone. The weight of our product is saved in fuel 21 within ten days of typical use on trucks in the lon g22 haul segment. Regardless of how we monetize things , IPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 169 1 am quite proud of that fact as a true measure of va lue. 2 Schneider did extensive fuel economy testing o ver 3 many years and determined through exhaustive 4 replication of these tests on tractors and trailers , 5 that our inexpensive, simple, patented approach made 6 huge economic sense. 7 When wheel covers were placed on trailers as well 8 as tractors, fuel savings proved to be significant, a 9 number that grows to approximately 2 percent when b oth 10 tractor and trailer are equipped on all 8 wheel end s. 11 Schneider knows the fuel savings are double fo r a 12 combination tractor-trailer. Yet, given the ratio of 13 trailers to tractors, the actual return on investme nt 14 is less because trailers sit idle most of the time and 15 often outnumber tractors by a factor of three. We 16 applaud EPA's focus on vigilantly bumping efficienc y of 17 long-haul tractor-trailer combinations through this new 18 phase 2 as it will bring further fuel savings throu gh 19 trailer efficiency. 20 EPA, it appears, took the approach to carve upthe 21 combination tractor-trailer into two regulatory pha ses. 22 In the first phase, a tractor manufacturer offers aPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 170 1 coefficient of drag for their tractor, which in the 2 case of our product is buried within that number an d 3 not quantified. Yet, it is known to be a significa nt 4 contributor in lowering drag. 5 In the second phase, a collection of various 6 products, largely aerodynamic, are encouraged to be 7 incorporated into a trailer to reach the desired 8 increase in efficiency. The truck and the trailer do 9 not operate independent of one another. Making them 10 more incorporated as a single efficient unit is the 11 ultimate goal. However, EPA collects a coefficientof 12 drag from the manufacturer for their tractor and th en 13 relies on its certification methodology for its 14 trailers. 15 When measuring the increases in efficiency of 16 wheel covers on trailers and tractors independent o f 17 each other, the fuel savings get lost in the marginof 18 error of the test methodology. With no enmity 19 suggested, it is our belief that a hugely scalable 20 opportunity is being missed. We suggest a remedy t hat 21 would permit testing of both tractor and trailer in 22 combination for the purposes of aerodynamic compone ntsPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 171 1 that can be fitted to both. We believe current tes ting 2 methodology is sufficient, albeit misapplied to eit her 3 tractor or trailer and not the combination. 4 The market opportunities of aerodynamic wheel 5 covers have gained momentum with many new entrants 6 salivating at the commercial prospects. An aerodyn amic 7 wheel cover is the only aerodynamic component that is 8 functional on both tractor and trailer. And, yet, 9 because of this regulatory process that splits trac tor 10 from trailer in testing, it is lost in the noise. 11 The addition of a single sentence to this 12 regulation that would embrace testing of tractor13 trailer combinations for aerodynamic components fou nd 14 on both would be helpful to permit aerodynamic whee l 15 covers to scale in a marketplace that is worldwide. 16 Thank you for your opportunity to make these 17 public comments. 18 MR. GRUNDLER: Excellent. Thank you very much . 19 Questions for panel 7? Steve? 20 MR. SILVERMAN: Just briefly. Thank you, Mr. 21 Fleck. I take it you don't agree with the referenc e 22 tractor, reference trailer approach, that it is notPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 172 1 serving your objectives? 2 MR. FLECK: We would just like to see both -- it 3 is very rare that you have an aerodynamic component 4 that is both functional on tractor as well as trail er. 5 In fact, we believe the aerodynamic wheel cover is 6 perhaps the only aero component. Thereby, it would 7 make sense for us to test both tractor and trailer in 8 concert with one another versus tractor and then 9 trailer. We have got to do it together. It makes no 10 sense. 11 MR. SILVERMAN: And assuming you are correct, 12 off-cycle credits could encompass any delta betweenthe 13 two approaches. But I take it that approach is too 14 onerous or do you have some objection? 15 MR. FLECK: Well, again, you know, yes. We ar e 16 splitting tractor from trailer. We would like to s ee a 17 single sentence that would permit tractor and trail er 18 for this particular aerodynamic component be allowe d to 19 be tested in that way. 20 MR. CHARMLEY: One question for Mr. Van Amburg . 21 Bill, a couple of different stakeholders today alre ady 22 have suggested that the agencies consider bringing backPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 173 1 or including the phase 2 final rulemaking and credi t 2 multipliers for advanced technologies. And you sai d 3 that was something that your organization, presumab ly 4 meaning your members, support. Certainly it would be 5 helpful if in your written comments now that we have 6 had one or two years now that we are into the secon d 7 year of the phase 1 program any views that your members 8 have on what should be the magnitude of advanced 9 technology credits to sort of balance the fact that 10 when you provide those credits, they serve a long-t erm 11 goal of incentivizing technology but in the very ne ar12 term, you are basically giving up CO2 reductions. Now 13 that we have had, as I said, two years of experienc e, 14 it would be really helpful if members have specific 15 recommendations of did we get it right in the phase1 16 rule? Were the multipliers that we proposed there for 17 EVs and PHEVs and fuel cell vehicles or should it b e 18 some other number? Rather than only just saying, " Hey, 19 bring them back," if you have any recommendations b ased 20 on experience about the appropriate value, that wou ld 21 be very much appreciated. Thanks. 22 MR. VAN AMBURG: We would be very happy to doPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 174 1 that. I think one of the tradeoffs -- and this is why 2 we talked about stringency. I don't think the cred its 3 have value in the absence of higher stringency. An d I 4 think that has been one of the tradeoff challenges. 5 And then you could actually look at what is the 6 reasonable credit needed for that. 7 I think your rule argument was actually very o n 8 point. It was really great to see all of the think ing 9 that went into it. I think you have a strong feeli ng 10 that the stringency levels will be driving some of 11 these technologies. And I think one of the things we 12 want to do is give you good data to show you why we 13 think that may not be the case and that you either need 14 the credits or higher stringency or, frankly, a sma ll 15 combination of both. 16 MR. GRUNDLER: So we would be very interested in 17 that information. I would also like to ask CALSTART 18 because of the relationships you have with many 19 technology vendors. If you have got additional dat a 20 with respect to the costs, both near- and longer-te rm 21 costs, of some of the advanced technologies, that w ould 22 be also very helpful for the agencies.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 175 1 Another request to Ms. Williams from Ford, whi ch 2 mentioned the GEM model accuracy. Obviously that i s 3 crucial for us to get that right. So any informati on 4 you have with respect to your products and how theyare 5 reflected, your technology and how it is reflected in 6 the model would be incredibly useful for us as we 7 proceed toward the final. 8 MS. C. WILLIAMS: Absolutely. 9 MR. GRUNDLER: Okay. Thank you very much, pan el 10 7. We will adjourn now. We will start at 1:30 p.m . 11 with panel 8. Thank you. 12 [A luncheon recess was taken.] 13 14 15 16 17 18 19 20 21 22Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 176 1 A F T E R N O O N S E S S I O N 2 MS. AMERLING: The panel is seated, but let me 3 introduce you all. We are joined on panel 8 by Raymond 4 Williams with NAFA Fleet Management; Joshua Goldman 5 with TransPower; Tilden Curl with Tecco Trucking; Jesse 6 Prentice-Dunn with the Sierra Club; Leigh Merino wi th 7 MEMA; Daryl Gale with the Union of Concerned 8 Scientists; and Kirsten James, representing both Ce res 9 and Dignity Health. So, Mr. Williams, welcome. 10 MR. R. WILLIAMS: Thank you, I guess. Obvious ly 11 people are still coming back from lunch. So we wil l 12 get this started here. 13 Thank you very much for providing this opportu nity 14 to speak today on phase 2: greenhouse gas emission s 15 standards for fuel efficiency standards for medium-and 16 heavy-duty engines and vehicles. 17 I am Raymond C. Williams, here today on behalfof 18 professional fleet managers of NAFA Fleet Managemen t 19 Association. I am a NAFA member and the fleet mana ger 20 for Gothic Landscape, where I am responsible for 21 vehicles in California, Arizona, Nevada. Previousl y, 22 for 30 years, I was fleet manager for Verizon withPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 177 1 responsibility for vehicles in California, Texas, a nd 2 Florida. 3 NAFA members are responsible for a majority of 4 class 3 to 7 trucks and fleets in the United States and 5 Canada. NAFA is an association or professionals wh o 6 manage fleets of sedans, public safety vehicles, 7 trucks, buses of all types and sizes, a wide range of 8 military and off-road equipment. NAFA members are 9 responsible for the specification, acquisition, 10 maintenance, repair, fueling, risk management, 11 remarketing more than 4.6 million vehicles that dri ve 12 approximately 50 billion miles a year. NAFA member s 13 control assets and service well in excess of $100 14 billion each year. 15 Although we have several reservations, the 16 proposed phase 2 standards are consistent with NAFA 's 17 support of federal policies that promote vehicle 18 efficiency while promoting reduction of emission an d 19 fuel use. We believe the fleet industry has a unique 20 opportunity to make a considerable environmental 21 impact. NAFA's sustainable fleet accreditation 22 program, developed in conjunction with CALSTART,Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 178 1 emphasizes the economic and environmental benefits of 2 overall influences of sustainability. 3 As a fleet manager, I am not opposed to increa sed 4 innovation of complexity relative to the fleet indu stry 5 as it pertains to safety, productivity, and the 6 environment. I think innovation in the rapid pace of 7 technology is ever-changing. It is amazing to me w ith 8 all of the complexity that has been added to trucks in 9 the last ten years that industry executives are now 10 starting to begin to understand those costs of the pace 11 of innovation and government regulation. 12 As fleet managers, we have to consider the cos t of 13 phase 2 along with the expected costs of other curr ent 14 federal requirements. Phase 2 standards are not th e 15 only federal proposal that will add costs to the 16 complexity of vehicles. A case in point is NHTSA h as 17 proposed for underwriting crash protection of singl e18 unit trucks. They estimate that it would cost abou t 19 $669 million to equip 342,000 vehicles, one of the 20 proposed costs. 21 Today I would like to focus on three issues: the 22 proposed phase 2 standards must be affordable, mustnotPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 179 1 compromise performance, and must recognize the dive rse 2 needs of companies and agencies that depend upon 3 vocational vehicles and heavy-duty pickups. 4 Fleet managers are responsible for the entire 5 capital budget for new and replacement vehicles. 6 Multi-year capital forecasts are done annually. 7 Capital approval and release to spending is an annu al 8 exercise and depends upon the organization's resour ces. 9 When deciding to purchase or lease a vehicle, a 10 fleet manager first looks at the cost of the vehicl e 11 and how the cost affects annual vehicle replacement 12 budget. The initial cost is always a concern. The 13 projected lifecycle cost, the payback period do fac tor 14 into making the business case for a vehicle. And n o 15 variable cost is more important than fuel. The 16 projected payback periods of the proposal are basedon 17 fuel savings. But as fleet managers, after costs, my 18 primary focus is making sure that vehicle and drive 19 train features meet specific work and duty cycles. 20 A fleet manager appreciates the points of 21 continuing to improvement in emissions, but, as man y 22 have seen, the maintenance costs have increased tri plePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 180 1 the rate of inflation since 2007 as a result of the 2 government emissions regulations. Many of us have also 3 seen increases in engine, exhaust, cooling fuel sys tem 4 repair costs from the 2010-2014-related engine emis sion 5 complexity. 6 NAFA urges the EPA and NHTSA to undertake more 7 robust, sensitive analysis with respect to maintena nce 8 and potential scenarios. The proposal and regulato ry 9 impact analysis do not go far enough to looking at 10 potential maintenance costs. Fleet needs are diver se. 11 Payback periods of fuel savings vary by use. A cas e in 12 point, the duty cycle requirement for a tree-trimmi ng 13 company may differ from a requirement for an electr ic 14 utility company, although both may use a similar 15 vehicle. Some technologies will not fit in the same 16 use. With the respective vocational vehicles, the 17 proposal attempts to create silos. The agency prop osed 18 that a vocational chassis would be presumed to cert ify 19 using the multipurpose duty cycle unless certain 20 criteria are met that indicate that another duty cy cle 21 would be more appropriate. The agency acknowledged 22 that, even within certain vocational vehicle times,Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 181 1 vehicle use vary significantly. 2 In conclusion, NAFA and its members are not 3 opposed to the proposed rule, but we have a 4 reservation. We would like to see revisions to the 5 proposed standards to ensure that the fleet operato r is 6 able to work towards a solution that will work for the 7 best of the vehicle needs for the mission of the 8 company, agency, or institution. 9 Thank you for letting me speak to you today. 10 MS. AMERLING: Thank you, Mr. Williams. 11 Next we will hear from Joshua Goldman with 12 TransPower. Welcome. 13 MR. GOLDMAN: Thank you. 14 I am Joshua Goldman, VP of Business Developmen t 15 for TransPower, based in San Diego County, Californ ia. 16 And we are a company, a start-up, developing next 17 generation technology for electrification of heavy- duty 18 vehicles: on-road and off-road vehicles and cranes . 19 We are in support of anything that increases fuel 20 economy and, thus, reduction of emissions, like 21 criteria pollutants and especially greenhouse gas, but 22 we don't see necessarily a market driver in thesePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 182 1 regulations that has any effect towards the increas ing 2 supply of electric vehicles or zero-emission trucks . 3 And so we ask that you revisit this rule simil ar 4 to work that you have done in the phase 1 regulatio ns 5 but expound upon them. Give an ability for zero6 emission manufacturers, both after-market bodybuilders, 7 like ourselves, as well as the initial OEMs, to be able 8 to market these revolutionary electric vehicles in the 9 competitive diesel and natural gas truck market. 10 MS. AMERLING: Thank you. 11 Mr. Curl, welcome. 12 MR. CURL: Thank you. Thank you very much for 13 having me. 14 My name is Tilden Curl. I am an independent 15 owner-operator from Olympia, Washington, currently 16 nearing 25 years as a truck driver with over 2 mill ion 17 safe miles. I am a life member of OOIDA, and I am here 18 to help others understand the challenges truck drivers 19 face. I want to thank you for this opportunity to 20 speak to you today. 21 As we look ahead to successfully preserve our 22 environment, I would like to take a moment to look backPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 183 1 at where we come from and where we are now. To do 2 this, I have assembled some figures from my own 3 business records over the past 18 years. 4 I purchased a 1995 pre-emissions Peterbilt in 1998 5 for about $65,000. I operated that truck for just over 6 a million miles. Over the lifetime of the Peterbil t, I 7 invested just short of $95,000 into maintenance and 8 repairs, including an engine rebuild and a transmis sion 9 replacement. The last full year of operation, I 10 averaged 6.58 miles per gallon. And that was from a 11 very non-aerodynamic body style. 12 In October of 2008, I traded the Peterbilt in for 13 a new aerodynamic, emissions-compliant 2009 Kenwort h 14 that had a purchase price of $140,000. I operated that 15 truck just over 752,000 miles over nearly 7 years. 16 Over the lifetime of the Kenworth, I invested just 17 short of $105,000 into maintenance and repairs. An d 18 that does not include the $6,000 for the warranty o r 19 any of the repairs covered under that warranty, notto 20 mention the impact that it has on my income or the 21 reputation or reliability which caused to be in 22 unscheduled down time. During my ownership of thisPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 184 1 truck, the fuel economy dropped from 6.62 miles per 2 gallon to only 6.15 for the first 6 months of 2015. In 3 2014, I invested nearly $15,000 into repairs. In t he 4 last 4 months of ownership, I invested just shy of 5 $10,000 in repairs related to the emissions system. It 6 became very clear that ownership of that technologywas 7 no longer cost-effective for my business. The 8 technology did not have enough durability to achieve a 9 reasonable return on investment in a real-world 10 application. 11 Claims of technology paying for itself in a fe w 12 years were extremely overestimated. It became evident 13 that it was less expensive to purchase a new truck, 14 even though it only had 752,000 miles on it. The n ew 15 replacement truck, a 2016-model Kenworth of lack 16 features, cost $167,000. 17 I had originally planned to pay the 2009 off a nd 18 apply the payment amount toward my retirement for t he 19 duration of my time on the road. As I see it, the 20 previous emissions regulations and the rush to push 21 technology beyond tested capabilities have cost me my 22 retirement. There is no mechanism in place toPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 185 1 compensate small business truckers for the cost of 2 these mandates. 3 Small business truckers cannot afford for this 4 pattern to continue. With years of experience deal ing 5 with unplanned maintenance and repairs, such as tho se 6 just previously mentioned, there is a great deal of 7 skepticism and promises of technology that will 8 supposedly not cause much more and ultimately provi de a 9 savings. 10 With this broad background of experience from 11 small business truckers, such as myself, many find it 12 hard to believe that a mandate from EPA and NHTSA w ill 13 truly benefit them. While the agencies' proposal o f 14 alternative 3 mostly pushes for technology which is 15 largely of use today, there are some concerns to be 16 recognized. If the agencies pursue alternative 4, 17 there are many more concerns about, again, thrustin g 18 unproven technology into the marketplace. This wou ld 19 result in more truckers choosing to keep their curr ent 20 trucks on the road even longer. I want to stress t he 21 agencies' approach must allow for ample time for th e 22 OEMs to develop the new technology.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 186 1 There are other unmandated alternatives to ach ieve 2 good fuel economy. My pre-emissions truck worked more 3 efficiently, partly due to my driving skills. If t hose 4 driving skills were taught to others, fuel economy 5 would improve. Highway congestion is another 6 unaddressed proven waste of fuel every year. I 7 estimate that in one day of a recent trip, I burnedan 8 extra ten gallons of fuel due to congestion, the po int 9 being those two suggestions do not involve concerns of 10 unproven technology or unknown costs of the new 11 technology. 12 Small business truckers that purchase this 13 equipment to start up will be challenged to exist i f 14 this regulation proceeds without a reality check. The 15 agencies are seemingly using facts they prefer, wit h 16 little regard for the actual burdens it places on s mall 17 business operations. 18 The technology must have durability. That is 19 crucial for success. We all want a clean environme nt. 20 But the question is, is your focus in the right pla ce? 21 I welcome any questions you may have. And tha nk 22 you very much.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 187 1 MS. AMERLING: Thank you very much, Mr. Curl. 2 Next we have Mr. Prentice-Dunn with the Sierra 3 Club. Welcome. 4 MR. PRENTICE-DUNN: Thank you, and good aftern oon. 5 My name is Jesse Prentice-Dunn. I lead Sierra Club 's 6 work on vehicle efficiency and emissions standards. On 7 behalf of Sierra Club's 2.4 million members and 8 supporters, I applaud EPA and NHTSA for proposing 9 standards that will ensure medium- and heavy-duty 10 vehicles become cleaner and more efficient in the years 11 to come. 12 As representatives from nations prepare to mee t in 13 Paris to discuss how to tackle climate change, the 14 United States has an opportunity to lead the world in 15 reducing oil use and carbon pollution in the 16 transportation sector. In recent years, your agenc ies 17 had done tremendous work in setting historic standa rds 18 that will double the efficiency of our passenger 19 vehicles, which is a key part of the President's 20 climate action plan. 21 The proposed phase 2 standards for medium- and 22 heavy-duty vehicles represent another importantPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 188 1 opportunity to reduce oil use and carbon pollution from 2 our freight trucks. As you noted in your proposal, 3 freight truck oil use is one of the fastest growing 4 sources of oil in the transportation sector. And b y 5 2030, global emissions from freight trucks are expe cted 6 to pass those of passenger vehicles. 7 The proposed standards will significantly cut fuel 8 use and carbon pollution by more than 1.8 billion 9 barrels of oil and 1 billion metric tons of carbon 10 pollution over the lives of vehicles sold. These 11 reductions will save drivers $170 billion at the pump, 12 savings which can be passed on to consumers. 13 While the proposed standards are a step in the 14 right direction, we urge agencies to strengthen the 15 proposal in the following ways. First and most 16 importantly, the agencies should accelerate the 17 timeline of the standards to ensure greater reducti ons 18 in carbon pollution and oil use. 19 As many have talked about, we support alternat ive 20 4. Not only would this alternative reduce oil 21 consumption and carbon pollution by an additional 1 3 22 percent. It would increase net benefits by more th anPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 189 1 $24 billion. 2 Second, the final standard should include a 3 strengthened engine standard. The proposed engine 4 standard would require a fuel use reduction of only4.2 5 percent, much less than research by academics and 6 leading engine manufacturers have suggested. These 7 standards will influence the adoption of engine 8 technology over the next decade and beyond. And itis 9 critical that the engine standard drive technology 10 adoption, instead of locking in mediocre improvemen ts. 11 Third, EPA and NHTSA should strengthen the 12 proposed standards for heavy-duty pickups and vans. 13 Strengthening these standards will reduce the 14 discrepancy and standards for light and heavy-duty 15 pickup trucks, thereby reducing the possibility of 16 market distortions. 17 Fourth, we urge the agencies to restore advanc ed 18 technology credits and utilize real-world duty-cycl e 19 data to fully account for the benefits of hybrid 20 technology. Across the country, manufacturers, fle ets, 21 and states are investing in advanced technologies t o 22 dramatically reduce pollution from freight shipping .Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 190 1 These technologies, strong hybrids to electric powe r 2 takeoff, can significantly reduce fuel consumption and 3 improve air quality. The agencies should support t he 4 development of these advanced technologies with the 5 phase 2 standards. 6 Lastly, I would like to applaud the agencies f or 7 your proposed treatment of glider kits. In recent 8 years, sales of glider kits have skyrocketed, 9 accounting for roughly 2 percent of all class 8 10 vehicles manufactured annually. Many of the engine s 11 used on these vehicles emit substantially greater 12 amounts of NOx and particulate matter than current 13 emissions standards allow. Under the proposal, gli der 14 kit manufacturers will no longer be able to exploita 15 loophole, leading to more health-threatening pollut ion. 16 These proposed phase 2 standards are the resul t of 17 years of tireless work by you and your staff. And I 18 thank the agencies for your work and for all of you r 19 outreach efforts. Once again I applaud EPA and NHT SA 20 for proposing standards that will lead to cleaner a nd 21 more efficient trucks in the years to come. And, a s 22 you move forward, I urge you to strengthen thesePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 191 1 standards to ensure the greatest possible reduction s in 2 oil use and carbon pollution. 3 Thank you for the opportunity. 4 MS. AMERLING: Thank you. 5 Now we will hear from Leigh Merino with Motor and 6 Equipment Manufacturers Association. 7 MS. MERINO: Good afternoon. My name is Leigh 8 Merino, and I am the senior director of regulatory 9 affairs for the Motor and Equipment Manufacturers 10 Association, or MEMA. 11 MEMA is pleased to be here today for the 12 opportunity to present our statement about the prop osed 13 rule. MEMA and our heavy vehicle supplier member 14 companies appreciate the engagement with the U.S. E PA 15 and NHTSA and commend the agencies for their open a nd 16 collaborative approach and their receptiveness to 17 stakeholder suggestions. Collaboration between the 18 government and a wide variety of stakeholders is ke y to 19 the success of such a significant and complex techn ical 20 regulation. Particularly over the past two decades , 21 the medium- and heavy-duty sector in the U.S. has made 22 considerable strides in improving the safety andPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 192 1 efficiency of engines and vehicles. Further 2 improvements present a set of considerable challeng es, 3 challenges that suppliers are prepared to tackle. 4 MEMA would like to present the following 5 preliminary comments and five points. First, comme nt 6 period. MEMA recognizes and respects how importantit 7 is for the agencies to meet the administration's 8 deadlines in promulgating this rulemaking. But we also 9 believe it is critical to ensure that all stakeholders 10 have as much time as possible to digest this comple x 11 rule and to provide substantive, useful feedback tothe 12 agencies. Any additional time the agencies can aff ord 13 to add to the comment period, even a short-term 14 extension of one or two weeks, would be appreciated . 15 Two, regulatory framework. With the promulgat ion 16 of the phase 1 rule, our industry invested a great deal 17 of resources to develop and supply the technologies 18 that would assure that the standards were attainabl e 19 and cost-effective for our customers. Continuationof 20 a uniform program allows vehicle manufacturers to 21 continue investing in the technologies vehicles wil l 22 need to reach and exceed the phase 2 targets. MEMAPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 193 1 strongly supports sustaining a single nationwide 2 program. This approach provides regulatory clarityand 3 is vital to its success. As such, federal and stat e 4 agencies must avoid any potential inconsistencies i n 5 their respective regulations. Also, retaining a 6 separate vehicle and engine requirements provides 7 continuity of the standards, regulatory structures, and 8 strikes a balance between compliance and market 9 latitude. Lastly, the longer timeframe for phase 2 10 provides the industry the foresight and clarity to 11 develop the technologies needed to continue to meetthe 12 standards, particularly during the middle and latte r 13 stages of the rule. 14 Third, engine stringencies. Overall, we belie ve 15 that the technologies available in the near term an d in 16 the pipeline are feasible and achievable. Even so, 17 MEMA believes that there may be some opportunities to 18 boost engine stringencies to further drive innovati on 19 and technology throughout the phase 2 timeframe. MEMA 20 and some of our individual members are still evalua ting 21 and working on developing specific suggestions to b e 22 provided in our written comments.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 194 1 Fourth, fuel neutrality. MEMA maintains that 2 instituting performance-based standards is the bestway 3 to ensure that there are no unintended market shift s 4 resulting from the standards and that the overall 5 objectives of the program are not unintentionally 6 compromised. With respect to heavy-duty pickups an d 7 vans, MEMA proposes an alternative to the proposed rule 8 that would simply require a 16 percent fleet averag e 9 CO2 emissions reduction. Consequently, the industr y 10 and customers pick the fuel and technology combinat ion 11 that offers the best value while also meeting the 12 requirements. Moreover, this would make the regula tory 13 approach similar to the CAFE standards already in p lace 14 for light-duty vehicles and provide the attendant C O2 15 reductions in the most cost-effective, customer16 friendly, and technology-neutral way. 17 Additionally, MEMA is concerned with the propo sal 18 to exclude gasoline engines from the vocational por tion 19 of the rule and about the potential market impact, a 20 possibility the agencies have acknowledged in the N PRM. 21 We believe that regulations that continue to 22 increase the technical complexity of diesel enginesPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 195 1 relative to gasoline engines may result in a much 2 larger market share for gasoline in this space. MEMA 3 is evaluating possible approaches to recommend to t he 4 agencies and will address this further in our writt en 5 comments. 6 Lastly, a wide array of technologies have been 7 recognized. MEMA reinforces our appreciation to th e 8 agencies for the scope and scale of their endeavors to 9 conduct a significant amount of research and data a nd 10 offer a proposal that is more representative of rea l11 world applications. MEMA supports the proposed 12 enhanced distance-based duty cycles with road-grade , 13 the additional transient tests, the optional power 14 train test, and other program flexibilities. They 15 offer visibility to the benefits of technologies 16 previously unseen in phase 1 and offer more real-wo rld 17 parameters to account for those technologies not 18 natured under the greenhouse gas emissions model, o r 19 GEM. 20 Regarding the GEM, MEMA appreciates the agenci es' 21 strategy to address a host of non-power train 22 technologies in the proposed rule under the model a sPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 196 1 well as in aspects of vehicle and trailer standards . 2 The broader range of inputs more accurately exempli fies 3 vehicle performance and provides compliance benefit s to 4 vehicle manufacturers that adopt improved features. 5 We also encourage the agencies to consider 6 expanding the GEM inputs to include additional 7 technologies, supporting details for which are 8 forthcoming in our written comments from MEMA and 9 individual suppliers. 10 My last point is before I conclude as per the 11 supplements to the GEM, MEMA is still evaluating th e 12 details of the agencies' proposals to address and 13 account for innovative, off-cycle technologies. An d we 14 will provide more commentary, although one quick po int 15 about the process, MEMA believes that suppliers sho uld 16 be offered the same opportunity as OEMs to pursue a 17 path to have innovative and off-cycle technologies 18 approved and recognized by developing test procedur es 19 with quantifiable benefits and submitting that for 20 public review by the agencies as the current state of 21 play. 22 MEMA appreciates your time today. MEMA and ou rPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 197 1 members continue to closely evaluate the NPRM, and we 2 are committed to provide more feedback to the agenc ies 3 in our written comments. Thank you. 4 MS. AMERLING: Thank you very much. 5 Ms. Gale, welcome. 6 MS. GALE: Hello. Thank you very much. 7 My name is Daryl Gale. I live in Los Angeles. I 8 am a retired geologist, and I came down here on the 9 Blue Line all the way from Los Angeles. And I woul d 10 like to represent the people who live, work, commut e, 11 and recreate in Southern California. 12 I am a Baby Boomer, a large demographic, like many 13 of you here. And we want to live a longer and 14 healthier life than our parents and our grandparent s. 15 This goal can be problematic with the air quality h ere 16 in Southern California. 17 Like many of you who are my age, I grew up in the 18 post-war prosperous suburban lifestyle. The Americ an 19 public has developed this very voracious, commercia lly 20 fueled appetite for lots of mostly plastic consumer 21 items from overseas. These items go to stores like 22 Wal-Mart, Costco, Target, of which we all shop at, andPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 198 1 are trucked throughout America, mostly coming throu gh 2 the two ports here: the Port of Long Beach and the 3 Port of Los Angeles. All of us have the responsibi lity 4 to think about our consumer behavior. Changing 5 behavior and changing new products always costs mor e at 6 first. And people grumble. And it can be a problem. 7 Many of you in the audience can remember when 8 microwave ovens, handheld calculators, computers, a nd 9 DVD players first came on the market, they were rea lly, 10 really expensive. But, as more and more people bou ght 11 them and adopted them, the demand increased and the 12 price came down. And we all modified our behavior. 13 The same thing for electric and hybrid cars. At 14 first, they had lots of problems. There were no 15 charging stations, and the battery life was really 16 poor. But that has changed. Many of you know peop le 17 or many of you may own a hybrid or an electric car. 18 And the prices also have come down because now you can 19 get a Tesla for only $70 to $100 thousand dollars. 20 That is really great. 21 A lot of things in our collective awareness have 22 changed since the 1960s and the 1970s. We didn't knowPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 199 1 how serious air pollution was. We didn't know how the 2 connection to asthma was. We knew that cigarette 3 smoking was bad, but we didn't know, really, how ba d it 4 was. And, just recently, we found out how criticalit 5 is to cut down on our excessive sugar intake. We 6 didn't know these back then. 7 So what I say, in conclusion, is anything you can 8 do to help us use less fossil fuels, breathe less t ruck 9 effluent, complement the great strides, the Port of 10 Long Beach and the Port of L.A., have done in cutti ng 11 pollution with the shipping will be greatly 12 appreciated. Please implement stricter standards. 13 Thank you. 14 MS. AMERLING: Thank you. 15 And next we will hear from Kirsten James, who is 16 here today separately representing two organization s, 17 Ceres and Dignity, and who will provide comments 18 separately for each. 19 MS. JAMES: Great. Good afternoon. My name i s 20 Kirsten James, and I am with Ceres' California offi ce. 21 Our organization's mission is to mobilize investors and 22 business leaders to build a thriving, sustainablePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 200 1 global economy. 2 Briefly, to just provide a little bit of conte xt 3 on who we are, Ceres coordinates three networks of 4 investors and business leaders. The first is the 5 Investor Network on Climate Risk, which consists of 6 more than 110 institutional investors, with assets 7 exceeding $13 trillion. The second, the Businesses for 8 innovative Climate and Energy Policy, is an advocac y 9 coalition of leading businesses committing to worki ng 10 with policy makers to enact meaningful energy and 11 climate legislation. And, finally, our company 12 network, includes nearly 70 member companies, over half 13 of which are listed on the S&P 500 index. 14 Ceres commends EPA and NHTSA for taking actionto 15 address fuel efficiency and GHG emissions associate d 16 with the medium- and heavy-duty vehicle sector and for 17 its thorough and inclusive rulemaking process. 18 We urge the agencies to strengthen the propose d 19 phase 2 standard under consideration today by adopt ing 20 a standard requiring a 40 percent reduction in fuel 21 consumption by 2025. Alternative 4 comes closest t o 22 that standard. Strict standards will catalyzePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 201 1 investment in high efficiency truck technologies, 2 thereby serving to retain the U.S. leadership posit ion 3 in this sector, save businesses money, promote ener gy 4 security, and reduce climate risk. Such standards 5 would be important drivers of economic growth, 6 benefitting businesses, the trucking industry, and 7 American consumers. 8 Despite higher up-front costs, advanced fuel9 efficient trucks will more than pay for themselves over 10 a typical ownership period due to fuel cost savings . 11 In fact, a joint analysis by Ceres and the 12 Environmental Defense Fund found these standards wo uld 13 reduce freight costs by 3 percent in 2030 and 7 per cent 14 in 2040, an estimated $34 billion annual saving 15 potential. 16 Strict standards are also key to retaining the 17 U.S. leadership position in efficient truck 18 manufacturing and expanding job opportunities in th at 19 sector. We are currently the world leader in the 20 development, production, and use of energy-efficien t 21 and hybrid trucks. Without strong standards in pla ce, 22 companies and investors will lack the requisitePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 202 1 certainty to invest in the development and producti on 2 of new technologies that will allow us to retain ou r 3 primary position and increase job growth. 4 Ceres agrees with the California Air Resources 5 Board, which recommends the adoption of the Alterna tive 6 4 standards at a minimum, stating this option is bo th 7 technology forcing and technologically feasible. 8 Companies in a variety of sectors are increasi ngly 9 interested in tracking scope 3 emissions, includingGHG 10 emissions associated with transportation and freigh t 11 movement, as part of their publicly disclosed GHG 12 assessment. Thus, a growing number of companies 13 support policies such as strict truck standards tha t 14 would help them achieve their own GHG emission 15 reduction goals as well as save money. 16 A recent op-ed written by the CEO of Ben and 17 Jerry's in the Guardian describes similar benefits for 18 companies that rely on trucking to get their produc ts 19 to market. Notably, the CEO calls for a 40 percent 20 reduction in heavy-duty fuel consumption by 2025. 21 In sum, we urge the agencies to adopt standard s 22 requiring a 40 percent reduction in fuel use by 202 5.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 203 1 Such technology-forcing standards would drive 2 innovation, catalyze investment in high-efficiency 3 truck and supplier manufacturing, as well as promot e 4 energy security and reduce climate risk. 5 It is time to move forward aggressively with 6 policies that will optimize private investment in a 7 low-carbon economy, cut freight costs, and reduce GHG 8 emissions from the trucking sector. 9 Thank you very much for the opportunity to spe ak 10 today and your leadership on this important issue. 11 MS. JAMES: And now to the second set of 12 testimonies. So Dignity Health, a member of our 13 Businesses for Innovative Climate and Energy Policy 14 group, asked that I provide testimony on their beha lf. 15 On behalf of Dignity Health and over 400 care 16 centers, including hospitals, urgent and occupation al 17 care centers, imaging centers, home health, and pri mary 18 care clinics, we commend the agencies for taking ac tion 19 to address the fuel efficiency and GHG emissions fo r 20 medium- and heavy-duty trucks. We strongly supportthe 21 adoption of regulations requiring a 40 percent decr ease 22 in fuel consumption by 2025.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 204 1 Dignity Health's healing mission and values compel 2 us to seek ways to further improve air quality and the 3 health of communities throughout the Southwest. St rong 4 phase 2 standards offer a rare opportunity to addre ss 5 serious health concerns associated with climate cha nge 6 and cut freight costs. Strict standards will provi de 7 incentives to increase investment in clean truck 8 technology and to help the U.S. meet federal ozone 9 standards, which Dignity Health activity supports. 10 Our nation's current heavy-duty truck fleet po ses 11 significant health risks to Americans across the 12 country. Freight trucks currently account for abou t 13 half a billion tons of climate-forcing GHG emission s 14 per year and are the fastest growing single source of 15 GHG emissions in the United States. 16 With strong phase 2 standards, the U.S. has th e 17 opportunity to improve air quality and increase rel ated 18 health benefits while sending common sense market 19 signals to spur innovation and accelerate the 20 development of cleaner, cost-effective technologies . 21 For these reasons, Dignity Health supports a strong 22 phase 2 standard, requiring a 40 percent reduction inPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 205 1 heavy truck fuel consumption by 2025. 2 Thank you for your leadership on this importan t 3 issue. 4 MS. AMERLING: Thank you. 5 Are there questions for the panel? 6 MR. GRUNDLER: I would like to ask the rep from 7 MEMA a question about your testimony where you stat ed 8 that some of your members would like to be affordedthe 9 opportunity to gain credit for component testing. Can 10 you elaborate on that? 11 MS. MERINO: Yes. I was referring to the off12 cycle innovative technologies area, where there is an 13 opportunity for an OEM to present a test cycle to h ave 14 it validated and certified by EPA through the publi c 15 process. All we would like is the opportunity to a lso 16 be able to do that. It is a repeat of a comment th at 17 we made under the phase 1 as well. 18 MR. GRUNDLER: But with respect to a particula r 19 component, as opposed to a vehicle? 20 MS. MERINO: Oh, I think it would probably dep end. 21 I think we are still vetting and going through all of 22 the different aspects of the off-cycle innovativePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 206 1 section. 2 MR. GRUNDLER: Okay. 3 MS. MERINO: And so I wasn't prepared to expre ss 4 all of the different elements because of all the 5 different suppliers that we represent, but I think the 6 over-arching point was to make sure that we have an 7 opportunity if the agency will see to it to let us come 8 in and present if we have a supplier that wants to go 9 in and present for the agencies' consideration and 10 technology and have that test protocol certified 11 through the process. 12 MR. GRUNDLER: It has been our experience that , 13 you know, how a particular technology or component is 14 integrated into an entire vehicle architecture real ly 15 matters in terms of its performance. So if when yo u 16 come in or provide those comments, suggest how that 17 could be overcome, that would be useful. 18 MS. MERINO: Absolutely. I will take that bac k to 19 my members. Thank you. 20 MR. CHARMLEY: I had a question for Mr. Curl. I 21 have no doubt that you are a great driver. And you 22 mentioned that, in addition to standards, that ther ePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 207 1 are other things outside of standards that can resu lt 2 in improvements in CO2, including driver education, 3 driver training. And we have done some of those th ings 4 through the EPA's SmartWay program, kind of promote 5 driver training. And I was interested in knowing. I 6 assume that your '85 Peterbilt and your '09 Kenwort h, 7 they, must have both been manuals. 8 MR. CURL: Oh, yes. 9 MR. CHARMLEY: Yes, exactly. One of the thing s 10 that we have heard from the, especially not so much 11 from the owner-operators but from the larger fleets , is 12 their ability to develop and maintain good drivers. 13 And one of the technologies, while our standards ar e 14 performance-neutral, we have projected that AMTs ma y be 15 a technology that more and more at least fleets might 16 go to to help them with driver sort of making not-s o17 good drivers at least better drivers. I wonder if you 18 had any opinion on if that was a good technology to 19 promote through the regulation. 20 MR. CURL: Well, with every pro, there is a co n. 21 So for every benefit, I can show you a down side. For 22 every down side, I can show you a benefit. AnPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 208 1 experienced driver, one who is properly trained in how 2 to drive a truck, how to operate the equipment, can 3 achieve a better economy or efficiency rating in an 4 automatic transmission. Now, if we are going to be 5 putting less-than-trained drivers on the road, it w ould 6 be a large benefit to have any kind of thing you ca n to 7 help avoid the mistakes. But the issue goes back t o 8 training. It doesn't go back to the equipment. 9 MR. CHARMLEY: Okay. Thank you. 10 And I see, Raymond, you are kind of nodding yo ur 11 head that you would agree with that as well. 12 MR. R. WILLIAMS: Yes. I would have to agree with 13 what he is saying because we have a similar experie nce. 14 In my former job with Verizon, we had a lot of over

15 the-road tractors. And it gets into the training. You 16 are absolutely right. It is something we recognize . 17 You can get a lot more fuel-efficient just by drive r 18 training and operating the piece of equipment. And 19 sometimes when you have a less efficient driver, 20 sometimes that automatic transmission versus that 21 manual, there is sometimes a payback on that at some 22 point. So yes, I would agree with what he was justPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 209 1 saying. 2 MR. CHARMLEY: Okay. Thank you. 3 MR. CURL: May I add a little bit more to that ? 4 There is also a financial impact on that as well. The 5 financial impact is the durability in the equipment 6 that I spoke of. Manual transmissions have been pr oven 7 to run well over a million, you know, a million anda 8 half miles without any faults. The automatic 9 transmissions, while they are getting better, they do 10 not have the dependability ratings that the manual 11 transmissions do. So when you employ these types o f 12 technologies, how they have a benefit on one end, t hey 13 are disadvantaged on the other end because they als o 14 create down time over the life span of the equipmen t. 15 MR. CHARMLEY: Okay. Thank you. 16 MR. CURL: Thank you. 17 MS. AMERLING: Any other questions? 18 (No response.) 19 MS. AMERLING: Before we move to the next pane l, I 20 just want to make an announcement that those of youwho 21 were originally slated for panels 12 or later have now 22 been moved up in the schedule to keep the panels fu ll.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 210 1 So please keep your eye on the board there, the scr een, 2 for updates to the schedule. Thank you. 3 MR. GRUNDLER: Thank you. 4 I would like to invite panel 9 up to the tableand 5 invite panel 10 to move over to the staging area. With 6 us today from panel 9 is Rasto Brezny from MECA; Ni dia 7 Erceg from CCAir and CCFC; Paul McNamara, Utility 8 Trailer Manufacturing; Doug MacLaughlin from UCS; Andy 9 Swanton from BYD Motors; and David Fink from Climat e 10 Resolve. Welcome, everybody. Rasto, when you are 11 ready? Thank you. 12 MR. BREZNY: Thank you. Good afternoon. My n ame 13 is Rasto Brezny. I am the deputy director of the 14 Manufacturers of Emission Controls Association. ME CA 15 is pleased to provide comments in support of the 16 proposed rulemaking to establish medium- and heavy- duty 17 greenhouse gas emissions standards and incorporate 18 average fuel economy standards for model years 2018 and 19 beyond. 20 MECA is a nonprofit association of the world's 21 leading manufacturers of emission control technolog ies 22 from mobile sources. The portfolio of products off eredPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 211 1 by our members has expanded beyond exhaust catalyst s 2 and particulate filters, to include technologies th at 3 impact combustion efficiency and improve the overal l 4 CO2 emissions of the power train. 5 We will submit detailed comments by the deadli ne. 6 However, today I would like to focus on a few speci fic 7 aspects of the proposal. MECA strongly supports th e 8 continued use of separate engine and vehicle standa rds. 9 This framework, established under the phase 1 heavy

10 duty standards, ensures the important testing linka ge 11 between engine criteria and greenhouse gas emission s 12 and ensures that manufacturers deliver durable and 13 forcible improvements to truck fuel efficiency. 14 MECA believes that cost-effective technical 15 solutions will be available to allow for the faster 16 2024 implementation timeline included under alterna tive 17 4 in EPA's proposal. Manufacturers need this 18 regulatory clarity to continue to make investments in 19 technologies that will deliver the target reduction s. 20 MECA supports EPA's proposal to lower the cap on 21 N2O emissions by 50 percent. This titer N2O cap, a t 50 22 milligrams per brake horsepower hour, will bePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 212 1 challenging in the expected future of lower exhaust 2 temperatures associated with improved engine 3 efficiencies, but manufacturers have a number of 4 technical opportunities available to them to keep N 2O 5 emissions at low levels. These include improved 6 catalyst formulations, ammonia slip catalysts with high 7 selectivity for nitrogen formation, and efficient u se 8 of urea dosing strategies. 9 We also support the proposal to close the curr ent 10 emissions loophole on truck glider kits. It is time to 11 ensure that all new trucks utilize the clean diesel 12 engine options that have been available since 2010. 13 MECA asks EPA to consider an earlier implementation 14 date for this glider truck provision, instead of 15 waiting until 2018. 16 We believe that PM emissions from auxiliary po wer 17 units should be controlled through the application of 18 proven diesel particulate filter technology. Thereare 19 already examples of small off-road diesel engines 20 engineered with filter solutions. And EPA should 21 follow California's lead and implement policies so that 22 APU engines can benefit from the use of cost-effect ivePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 213 1 filter solutions. 2 Finally, MECA believes that further reductions in 3 NOx emissions from new heavy-duty on-road diesel 4 engines beyond the 2010 highway requirements will b e 5 possible through the combination of advanced diesel 6 engines and evolutionary, not revolutionary, 7 improvements to the existing suite of diesel exhaus t 8 emission-control technologies. 9 Clean diesel emissions technologies and 10 calibrations have evolved and matured since the EPA 11 finalized their heavy-duty emissions standards near ly 12 15 years ago. The current technologies will contin ue 13 to advance by including I-cell density; low thermal 14 mass substrates; improved SCR catalysts, coded dire ctly 15 on particulate filters; and next generation oxidati on 16 catalysts that include low-temperature passive NOx 17 absorber functionalities. 18 The application of SCR technology on diesel 19 engines has allowed engine manufacturers to optimiz e 20 for both low NOx emissions and improved fuel 21 efficiency. And we believe that these optimization s 22 can continue in the future to further reduce both C O2Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 214 1 and NOx. 2 Advanced diesel emission control technologies are 3 currently being evaluated in a California-sponsored 4 test program that demonstrate the ability to meet a 5 .02-gram NOx standard without negatively impacting CO2 6 emissions. The diesel emissions control technologi es 7 being demonstrated in this program are focused on 8 delivering NOx reductions during the cold transient 9 portion of the test cycle and on improving NOx emis sion 10 performance and low-temperature duty cycles. These 11 technologies will, in turn, facilitate the reductio n of 12 CO2 emissions from vehicles by extending the 13 calibration window available to optimize combustion 14 efficiency down to lower temperatures. 15 Furthermore, reduce NOx emissions from heavy-duty 16 engines will provide important cost-effective 17 reductions for regions of the country with current and 18 future ozone nonattainment issues. A MECA-sponsore d 19 modeling study using MOVES2014 estimated the NOx 20 reduction benefit of a national .02-gram federal he avy21 duty NOx standard. When fully implemented, such a 22 program would deliver 266,000 tons per year, or 730Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 215 1 tons per day, of NOx reductions across the 47 2 contiguous states outside of California. 3 MECA asks EPA to initiate a rulemaking that wi ll 4 further reduce NOx emissions from heavy-duty engine s as 5 soon as possible to allow the industry to fully develop 6 optimized future engines that deliver improved fuel 7 efficiency as well as ultra-low NOx emissions. 8 Thank you. 9 MR. GRUNDLER: Thank you, sir. 10 Ms. Erceg, welcome. 11 MS. ERCEG: Good afternoon. And thank you forthe 12 opportunity to testify. 13 My name is Nidia Erceg, and I am the special 14 programs manager with Coalition for Clean Air. I am 15 also a member of the California Cleaner Freight 16 Coalition. The coalition is a partnership of 17 environmental justice, public health, science, and 18 environmental organizations. 19 I want to applaud the EPA and NHTSA for propos ing 20 standards that will make our freight trucks cleanerand 21 more efficient. While the proposed standards are a 22 good first step, I urge you to strengthen thesePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 216 1 standards to ensure the greatest reductions in oil and 2 global warming emissions. I am not just a concerne d 3 citizen, but after having lived more than 35 years here 4 in Southern California and living through smog days at 5 school, I now use an inhaler. 6 I want to talk to you about the health impacts . 7 Climate change is a serious concern for the 26 mill ion 8 Americans, including 7 million children who current ly 9 suffer from asthma. Warmer temperatures promote th e 10 production of harmful ground-level ozone, a known 11 asthma trigger. Climate change is expected to incr ease 12 dangerous ozone levels in many areas. This air 13 pollution, in turn, will worsen asthma symptoms and 14 trigger asthma attacks. Thus, by mitigating climat e 15 change, these standards will help people, like me, who 16 suffer from asthma. 17 It is fitting that we are here today near the 18 anniversary of the Clean Air Act. Although signifi cant 19 progress has been made in improving the quality of air 20 in most U.S. cities and communities, there is still 21 more to be done. 22 By proposing a weaker target, the agencies havePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 217 1 missed opportunities to further reduce oil use and 2 emissions. It is critical that the proposal be 3 expanded to capture the full suite of cost-effective 4 solutions available for each type of heavy-duty 5 vehicle. 6 I want to talk to you also about investments i n 7 standards. Despite reductions in toxic pollutants and 8 strong standards, which are vital for California an d 9 the whole country, we have to invest in clean heavy

10 duty trucks to achieve both greenhouse gas reductio ns 11 and federal air quality standards attainments. The y 12 can give the same investment. And it doesn't make 13 sense to do it twice. 14 We cannot reach attainment of federal standard s in 15 Los Angeles region or the San Joaquin Valley withou t a 16 .02 brake horsepower hour NOx heavy-duty standard. EPA 17 should adopt the 2014 alternative 4 because it is 18 urgent we get the emissions reductions. EPA should 19 also go further on engine standards and on aerodynamic 20 for vocational vehicles. 21 I agree with MECA, who talks about the APUs having 22 a filter requirement nationwide, as they do here inPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 218 1 California. EPA should adopt this regulation 2 expeditiously. And it should also initiate a separ ate 3 rulemaking to lower the NOx standards. 4 Once again, under the leadership of the EPA, 5 progress is being made. And I applaud the 6 administration for proposing standards to make our 7 trucks more efficient. I urge you to finalize stro nger 8 standards that reduce trucks' fuel use by 40 percen t in 9 2025. 10 And I thank you for the opportunity to testify . 11 MR. GRUNDLER: Thank you very much. 12 Mr. McNamara, welcome. Proceed. 13 MR. McNAMARA: Thank you. 14 My name is Paul McNamara. I serve as the gene ral 15 counsel for Utility Trailer Manufacturing Company. We 16 are headquartered locally, in the City of Industry. We 17 are North America's leading manufacturer of 18 refrigerated semitrailers and the third largest 19 manufacturer of trailers in the United States. 20 Every day, our engineers and factory workers 21 strive to deliver a lighter, stronger, more efficie nt, 22 safer semitrailer, something completely consistent withPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 219 1 the phase 2 objectives, but most of what you hear t oday 2 is about the truck, not the trailer. 3 So, for that reason, we ask that you modify yo ur 4 proposal as published in four ways that reflect the 5 nature of the semitrailer industry. First, the tra iler 6 industry is an exceptionally competitive, low-margi n 7 industry. Utility and the other manufacturers have 8 little ability to determine what its customers want . 9 Large trucking fleets purchase the overwhelming 10 majority of semitrailers. And they demand trailers 11 customized for their needs. Unless we meet those n eeds 12 in a reliable, cost-effective way, they won't purch ase 13 the trailer. This reality leads to the following t hree 14 conclusions. 15 Initially, the best approach is one where the 16 customer demand for the technology leads the 17 innovation. We urge NHTSA and the EPA to require t he 18 trailer owner to have certain fuel-efficient equipment 19 on its trailer. The customers then would demand th at 20 the manufacturers installed the equipment on the 21 trailers they purchased. 22 Next, the final rulemaking should encouragePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 220 1 customers to welcome the technologies by exempting 2 those technologies from excise taxes, weight limits , 3 and length and width restrictions. 4 Lastly, we encourage the EPA to abandon its bi n 5 and averaging approach in favor of requiring all va n 6 trailers except those demonstrably unsuited for the 7 approved technologies -- and many trailers fall in this 8 category -- to have the required technology. This will 9 alleviate the crushing administrative burden impose d by 10 the bin and averaging approach. It will also avoid 11 large purchasers attempting to game the system by u sing 12 their market power to pressure a manufacturer to 13 allocate non-aerodynamic equipment-bearing trailers to 14 those large purchasers. 15 While I am on the subject of minimizing 16 administrative burden, we ask you to adopt a 17 streamlined system of compliance. Trailer 18 manufacturers currently affix a plate to each trail er 19 certifying that the trailer meets all relevant DOT 20 requirements. We do that successfully every day, a nd 21 it works. A similar approach would be useful here. 22 Second improvement, maintain flexibility inPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 221 1 out-year requirements. The proposed rulemaking 2 regulations become increasingly stringent by 2027. We 3 understand that it is impossible to forecast the st ate 4 of the transportation industry a dozen years from n ow, 5 but what we know now is that a currently available 6 technology will allow us to meet the 2018 standards . 7 We don't believe we have the technology today to me et 8 those proposed for 2027. Of course, like you, we 9 anticipate advances in technology, but we believe i t 10 appropriate to delay establishing standards so far in 11 the future until the agency and industry have a bet ter 12 grasp on what the transportation industry looks like as 13 it embarks on the second quarter of the Twenty-Firs t 14 Century and on what improvements can be made safelyand 15 economically and on a cost-justified basis. 16 Third, adopt realistic exemptions for classes of 17 equipment where there is no cost-benefit justificat ion 18 for installing the equipment. Manufacturers build many 19 trailers for the food service industry. These are not 20 long-haul trailers. Rather, they deliver the vast 21 quantities of food and beverages from distribution 22 centers to points throughout the city and suburbs.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 222 1 These trailers spend most of their lives on local 2 roads, obeying local speed limits. They may travelon 3 the crowded urban freeways for short distances, but 4 most of their travel is well below 50 miles per hou r. 5 The benefit of aerodynamic devices on these trailer s is 6 negligible. And some of the devices are incompatib le 7 with specifications routinely and necessary in the 8 industry and are likely to be damaged in use. Ther e is 9 no reason to impose the cost of these devices on th ese 10 trailers. 11 Additionally, some of the devices reduce 12 productivity through increased weight and cost. Th is 13 translates to more trailers in use and on the road. 14 Pepsi appeared here earlier today talking about its 15 electric fleet. And, yet, there is no allowance ma de 16 for not having Pepsi buy trailers that have all of 17 these aerodynamic devices where they provide no 18 benefit. 19 And, last, make certain that your regulations 20 apply to imports. Foreign manufacturers import an 21 increasing number of trailers in finished form or i n 22 kits. To ensure maximum benefit from your regulati ons,Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 223 1 they must apply to all trailers. In its rules 2 regulating ozone-depleting fluorocarbons used to 3 manufacture insulating foam in refrigerated trailer s, 4 the EPA did not regulate foreign-manufactured trail ers. 5 As a result, thousands of trailers that were 6 manufactured in Mexico and China are imported here, all 7 using chemicals and processes that EPA has banned i n 8 this country. We ask that you do not overlook this in 9 regulating greenhouse gases. 10 Thank you. 11 MR. GRUNDLER: Thank you very much, sir. 12 Mr. MacLaughlin? 13 MR. MacLAUGHLIN: Thank you for the opportunit y to 14 testify today. My name is Douglas MacLaughlin. I am 15 an emeritus physics professor at the University of 16 California, Riverside. I am here as a private citi zen 17 and a member of the Union of Concerned Scientists. 18 Just as a reminder, the Union of Concerned 19 Scientists is a nonprofit organization that carries out 20 scientific analyses of problems of national and 21 worldwide importance. 22 The subject of this hearing is a body ofPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 224 1 regulations to improve efficiency and reduce emissi ons 2 of heavy-duty vehicles. I am very glad the 3 administration is proposing standards that will do 4 this. 5 I am here because I have several concerns abou t 6 non-sustainable fossil fuel consumption, which I have 7 heard a lot about many of these today, but my chief 8 concern hasn't been talked about all that much, 9 although it has certainly been mentioned. And thatis 10 climate change caused by global warming. The scien ce 11 on climate change has been clear on this for quite some 12 time. 13 Global warming is real. And it threatens the 14 habitability of our planet. In my opinion, more 15 importantly in the opinion of the vast majority of the 16 scientists in the field, it is the greatest threat 17 facing us today long-term, not short-term but long18 term. If we do nothing or not enough, it is a sure 19 thing, long-term. It is not a question of whether or 20 not it will happen in a very, very bad way. It is a 21 question of when. 22 Humanity is capable of overcoming it with a gr eatPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 225 1 effort, but it will take an enormous and complex se t of 2 circumstances to do that. The proposed standards we 3 are dealing with here are a small but very importan t 4 part of a challenge like this. 5 Administration's proposals are a good first st ep, 6 but the UCS and other organizations, as I have hear d 7 today, have shown that they can be strengthened. T hey 8 have analyzed this issue in detail and made specifi c 9 additional proposals. They and other organizations 10 have shown that new technology and new trucks can 11 reduce fuel consumption by a number we have heard quite 12 a bit, 40 percent, by 2025. That is more and faste r 13 than the administration's proposed goal to date, atany 14 rate, of 36 percent reduction by 2027. 15 Achieving the UCS target would mean an additio nal 16 reduction of hundreds of millions of metric tons of 17 global warming emissions annually, equivalent to 18 shutting down quite a few coal-fired power plants. And 19 there are many other benefits. 20 Air pollution, which we have heard about, air 21 pollution and its effect on public health are reduc ed. 22 Truck owners insofar as the technology is successfu l,Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 226 1 truck owners are less vulnerable to volatile oil 2 prices. And our country is less vulnerable to 3 volatility in oil-producing regions of the world. The 4 technology insofar as it is successful will be cost

5 effective. And in the UCS' recommended scenario, t he 6 reduction in fuel cost alone is likely to pay big r ig 7 owners for the new technology in a short period of 8 time. 9 Most important to me, it is an absolutely 10 necessary step in the fight against global warming. 11 And it can be done. 12 So I am very glad that the administration is 13 proposing significant new efficiency and emissions 14 standards, heavy-duty trucks, but they also strongl y 15 support strengthening these standards, achieve the 40 16 percent fuel consumption reduction by 2025 that theUCS 17 and others have shown to be possible. It can be do ne. 18 It must be done. 19 Thanks again for the opportunity to testify. 20 MR. GRUNDLER: Thank you, sir. 21 Mr. Swanton, welcome. 22 MR. SWANTON: My name is Andy Swanton, and I amPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 227 1 the director of business development for BYD Motors , an 2 electric vehicle manufacturer for battery electric 3 buses, taxis, and trucks. 4 First of all, thank you for the opportunity to 5 provide comments and engage with the agencies on th e 6 rule. I would like to express my support for the p hase 7 2 rules, and I applaud the agencies moving forward on 8 aggressive stringency levels that address climate 9 change. 10 The current version of the plan will have real 11 benefits for public health and will provide total c ost 12 of ownership benefits for fleet operators over the life 13 of the vehicles. My concern is that I do not belie ve 14 that the rules alone will drive the adoption of 15 advanced technologies, like fuel cell and electric 16 vehicles. 17 At BYD, we believe that the best approach to 18 accelerate the widespread adoption of clean 19 technologies is consistent and aggressive regulatio ns 20 in combination with incentives for advanced technol ogy 21 adoption. The current stringency levels require a 25 22 percent reduction in stringency levels over the 201 0Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 228 1 baseline by 2027 for vocational vehicles, the categ ory 2 where most electric vehicles will be deployed. 3 It is our belief that this stringency level inand 4 of itself will not result in fleet operators invest ing 5 the time and capital necessary to bring advanced 6 technologies to market. Therefore, BYD supports even 7 more aggressive adoption of these stringency levels , 8 such as alternative 4, which would accelerate the 9 stringency levels by 3 years, to 2024. This change 10 would cause fleet operators to more seriously consi der 11 advanced technologies. It would also allow the 12 agencies the flexibility to evaluate the 13 appropriateness for the inclusion of advanced 14 technologies for future phases and the ability to 15 implement those changes sooner. 16 I would also like the agencies to consider 17 including an incentive for fuel fleet operators tha t 18 are committed to sustainability and are eager to adopt 19 clean technologies. Incentives could include vouch ers, 20 credits, or grant fund programs, whether they are 21 included in these rules or administrated separately . 22 These incentives play a critical role at this earlyPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 229 1 stage of technology development, both in generating 2 interest among fleets and improving the performanceand 3 operational savings associated with the vehicles. 4 Currently battery electric trucks are 5 approximately three times as expensive as diesel 6 equivalents. In order to reduce the price gap, 7 original equipment manufacturers must make sizeable 8 investments in research and development and 9 manufacturing scale. Similar investments have alre ady 10 been made in the bus markets. And, as a result, 11 current electric buses are priced at only a 60 perc ent 12 premium over diesel buses, a premium at which the f uel 13 and maintenance savings result in approximately a 3

- 14 year payback and a favorable total cost of ownershi p. 15 We believe a similar achievement is possible i n 16 the truck markets. The largest cost driver for 17 electric vehicles is the battery use. And BYD has 18 achieved a 7 percent year-over-year improvement dur ing 19 each of the last 4 years. We are forecasting a 10 20 percent annual improvement through 2020. This cost 21 reduction, combined with scale economies from inves ting 22 in large-scale manufacturing for batteries, inverte rs,Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 230 1 traction motors, and associated components, should 2 result in the availability of full battery electric 3 trucks that will have a payback period of 3 years when 4 compared to diesel trucks by the year 2020. This 5 three-year mark is the currently acceptable payback 6 period for fleet operators. This is an exciting 7 opportunity, but to get there, OEMs, like BYD, need 8 assurances that there will be a growing market for 9 electric trucks. 10 Thank you for this opportunity. 11 MR. GRUNDLER: Thank you very much. 12 Mr. Fink? 13 MR. FINK: Good afternoon. Thank you for the 14 opportunity to comment today. My name is David Fin k, 15 and I am the director of campaigns for Climate Reso lve. 16 We are L.A.'s climate advocacy organization based i n 17 downtown Los Angeles, and we are focused on creatin g 18 real, practical solutions to meet the climate chall enge 19 while creating a better region for all Southern 20 Californians today and in the future. 21 First of all, we applaud the administration an d 22 EPA for proposing standards that will make our frei ghtPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 231 1 trucks cleaner and more efficient for several years 2 going forward. And we urge you to strengthen these 3 standards to ensure the greatest reductions in oil use 4 and global warming emissions. 5 Climate Resolve believes it is vital that as a 6 nation and as a state, we take necessary measures t hat 7 both prevent future climate change and help us prep are 8 for expected impacts. Not only will more fuel9 efficient heavy-duty trucks directly reduce greenho use 10 gas emissions, leading to a reduction in long term 11 atmospheric warming, but there are numerous benefit s 12 that will also help us prepare for expected climate 13 impacts, make us more resilient, and stave off the 14 worst-case scenarios. 15 The best science we have tells us that Souther n 16 California will warm four to five degrees in the mi ddle 17 part of this century and the number of extreme heat 18 days -- that is days of 95 degrees and above -- wil l 19 double and in some parts of the region triple. If we 20 continue with business as usual, temperatures are 21 expected to rise an average of nine degrees Fahrenh eit 22 by the end of the century. However, with strongPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 232 1 mitigation measures, we will see a leveling off of 2 warming and a reduction of average temperatures in the 3 latter half of this century. Higher average 4 temperatures and stronger heat waves will have many 5 negative impacts, maybe none more so than on public 6 health. 7 In a typical year, there are a greater number of 8 mortalities attributed to heat than all other weath er 9 events combined. There is also a strong correlatio n 10 between heat and ground level ozone formation, mean ing 11 poorer air quality, a trigger for asthma, and other 12 chronic respiratory ailments. 13 Lastly, our cities already suffer from higher 14 average temperatures than surrounding rural areas due 15 to a phenomenon called the urban heat island effect , 16 which typically pushes temperatures up four to six 17 degrees. There are three main drivers of the urban 18 heat island effect: paved surface area, which mean s 19 roads, rooftops, playgrounds, et cetera; lack of 20 vegetation; and exhaust from automobiles, trucks an d 21 manufacturing. Therefore, the standards being 22 discussed today, which will drive down heavy-duty t ruckPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 233 1 emissions, can play a significant role in helping u s 2 cool our cities and make us more resilient in the f ace 3 of climate change. 4 Once again, we commend the administration for 5 proposing standards that make our trucks more 6 efficient, and we urge you to finalize stronger 7 standards that reduce truck fuel use by 40 percent by 8 2025. 9 Thank you for the opportunity to testify today . 10 MR. GRUNDLER: Thank you very much, Mr. Fink a nd 11 the rest of the panel members. Let me turn to my 12 colleagues and ask if they have any questions. 13 MR. CHARMLEY: One will just be a request for the 14 gentleman from BYD. To the extent that in your wri tten 15 comments on the proposal -- and we hope that you wo uld 16 submit written comments -- that you could provide b ased 17 on your company's experience any cost information, 18 either in the public domain or you could submit CBI , on 19 the cost of hybridization or EVs or fuel cell 20 technology for vocational vehicles, that would be very 21 helpful. 22 And then I actually have a question for thePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 234 1 gentleman from Utility. Mr. McNamara? 2 MR. McNAMARA: Yes? 3 MR. CHARMLEY: One question for clarity. Do y ou 4 and Mr. Bennett, who testified earlier, both work f or 5 the same company? 6 MR. McNAMARA: Yes, we do. 7 MR. CHARMLEY: And were both of your comments on 8 behalf of Utility? 9 MR. McNAMARA: Yes, they are. 10 MR. CHARMLEY: Okay. Thank you. 11 And then my specific question for you was you 12 mentioned -- I think it was your second point -- ab out 13 maintaining flexibilities in the out-years given 14 technology development. And you kind of used as 15 examples 2018. You know how to do 2018. As you ge t 16 out to 2027, maybe it is not quite as certain. So I 17 would certainly encourage the company in their writ ten 18 comments or if you can clarify now -- you know, the 19 proposal has 4 steps: '18, '21, '24, and '27. Wer e 20 you using '18 and '27 as like generic examples or were 21 you being very specific in saying '18, '21, '24 maybe 22 the company knows the pathway and that it is 2027 t hatPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 235 1 you wanted us to maintain flexibility? 2 MR. McNAMARA: Well, first of all, I do not wa nt 3 you to confuse me with an engineer. All right? Bu t I 4 did speak to our engineering department about this. 5 And I focused on only the two extreme years. So I 6 cannot tell you, you know, without doing a deep dive 7 into the formulas contained in the regulations as t o 8 where the crossover point is. 9 I can tell you that from 2018, given the formu la, 10 the performance measurements that we have for the 11 technologies, we believe we can do 2018. We know t hose 12 numbers, and we don't see a way now for doing 2027. In 13 the meantime, where we fall I don't know. That is 14 something we could put in our written comments, tho ugh. 15 MR. CHARMLEY: That would be very appreciative . 16 Thank you. 17 MR. GRUNDLER: Thank you, panel. You are excu sed. 18 MS. AMERLING: I would like to invite the next 19 panel up to the table. This panel includes Jack Gi llis 20 with Consumer Federation of America, Edward Lovelac e 21 with XL Hybrids, Charles Irvin Drew with Union of 22 Concerned Scientists, Brett Barry with Clean EnergyPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 236 1 Fuels, Dennis Rodriguez with Siemens Corporation, Rob 2 Cadle with Honeywell, Kevin Golsch with Exa, and 3 Dorothy Kelty with Union of Concerned Scientists. Mr. 4 Gillis, would you like to proceed? 5 MR. GILLIS: Good afternoon. My name is Jack 6 Gillis. I am director of public affairs for the 7 Consumer Federation of America and its vehicle expe rt. 8 As background, CFA is one of the nation's leading 9 consumer organizations. We are made up of over 250 10 state, local, and national nonprofit organizations. We 11 were established in 1968 to advance the consumer 12 interest through research, advocacy, and education. 13 We really appreciate this opportunity to be he re 14 today to participate because we are very concerned that 15 consumer economic issues be fully considered when t his 16 standard is promulgated. 17 When it comes to goods and services, the Ameri can 18 consumer really does pay the freight. More than $1 ,100 19 of the cost of everyday goods and services goes to pay 20 for the fuel used to transport those goods and 21 services. From the perspective of household energy 22 costs, amazingly, the amount consumers pay for bigPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 237 1 truck fuel is almost as much as they spend for home 2 electricity and about half of what a typical househ old 3 would spend on gasoline. So indeed, we do pay the 4 freight. 5 Two recent Consumer Federation of America surveys, 6 conducted in July of 2014 and last July, found thatthe 7 vast majority of consumers, over 90 percent, believe 8 that some, most, or all of the fuel costs of heavy- duty 9 trucks are passed on to consumers. 10 While much of what you have heard today has 11 largely focused on the environment and industry 12 concerns, consumer economics must be an important 13 component in the decision to implement these propos ed 14 standards. 15 The bottom line, consumers get it. As our surveys 16 show, they understand that they pay the freight whe n it 17 comes to big truck fuel costs. As a result, the 18 Consumer Federation of America supports standards which 19 will significantly increase the fuel economy of big 20 trucks. In this particular case, what is good for the 21 consumer's pocketbook is also both good for the 22 environment and the economics of the trucking indus try.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 238 1 With the average household spending over $1,10 0 on 2 consumer goods and services to cover the costs of f uel3 inefficient trucks, we estimate that implementing t hese 4 standards will put about $200 back into household 5 budgets every year. This results in a national sav ings 6 of a whopping $170 billion. And these billions 7 represent money that will contribute to strengtheni ng 8 America's economy. 9 In both of the CFA surveys, consumers clearly 10 understood the need for action. When asked, nearly 11 three quarters of the respondents favored requiring 12 truck manufacturers to increase the fuel economy of 13 large trucks. Both surveys were conducted by ORC 14 International, surveying over 1,000 Americans, withan 15 error rate of plus or minus 3 percent. 16 Increasing truck fuel efficiency standards is a 17 win-win-win-win. It will benefit consumers' 18 pocketbooks, big truck fleet owners and operators, the 19 environment, and the economy. Clearly, the vast 20 majority of consumers understand how important thes e 21 standards are and want them to go into effect. 22 In addition to the significant consumer benefi tsPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 239 1 of the proposed new standards, there are other stro ng 2 arguments which justify a standard, which we will 3 present in comments to the proposed rule. However, in 4 brief, they include the fact that the benefits of b ig 5 truck energy savings technology far outweigh the co sts. 6 In the first eight years, the payback for a typical 7 tractor-trailer will be five times the cost, and th ese 8 vehicles are on the road substantially longer than 9 eight years. We will be using this cost-benefit ra tio 10 to further refine the financial benefits to househo lds. 11 In addition, these standards will address the 12 market imperfections that cause the underinvestmentin 13 energy savings technology. These market imperfecti ons 14 include uncertainty about future cost savings and 15 transaction costs; different interests of trailer, 16 versus tractor, owners; the different interests of 17 owners, operators, buyers, and sellers. Performanc e 18 standards are an excellent tool to reduce or elimin ate 19 these market imperfections. 20 While others have made strong environmental an d 21 industry economic arguments regarding the benefits of 22 the proposed rule, CFA believes that the consumerPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 240 1 economic benefits will be in the billions. And we look 2 forward to demonstrating why these standards are ne eded 3 in our detailed comments on the proposed rule which 4 will be submitted next month. 5 In closing, we would like to say "Great Job, E PA 6 and NHTSA. Your proposal is considered, collaborat ive, 7 thoughtful, and has great potential." Now, maybe i t is 8 just my age, but we would like to see a little more 9 speed. Nonetheless, on behalf of CFA, we thank you 10 very much for an extraordinary effort as truly grea t 11 public servants. 12 MS. AMERLING: Thank you. 13 Me. Lovelace, welcome. 14 MR. LOVELACE: Thank you. 15 I am Ed Lovelace, representing XL Hybrids as t heir 16 chief technology officer. At XL Hybrids, we are ve ry 17 appreciative of the efforts of the federal governme nt 18 team in developing the phase 2 draft rules and agre e 19 with the basic principles and structures that have been 20 proposed. And, as currently proposed, we support t he 21 preferred alternative. 22 By way of introduction, XL Hybrids is currentl y aPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 241 1 leading fleet electrification company in the U.S. w ith 2 as of May this year over 12 million fleet customer 3 miles per year driving our products all across Nort h 4 America. Our core hybrid electric up-fit products for 5 class 2 to 6 vehicles provide roughly 20 percent fu el 6 and proportional CO2 savings. And our success to date 7 is because of two important factors relevant here. 8 One, XL Hybrids does not significantly alter t he 9 major OEM vehicle and power train. And so major fl eets 10 can buy and service the same major OEM vehicles wit h 11 our system installed without any changes. 12 Two, XL Hybrids' price point is under $10,000 for 13 a class 2B hybrid electric full-sized van and 14 proportionately higher for the larger class vehicle s, 15 which has an attractive payback today for fleets th at 16 have considerable lifetime mileage usage. 17 So, in this context, XL Hybrids has both 18 experience and a stake in these rules as they applyto 19 heavy-duty trucks and vans and have the following 20 additional comments and recommendations. 21 One, we recommend improvements to the 22 hybridization cost models. The learning curve costPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 242 1 models in the regulatory impact analysis table 2-10 0 2 for mild and strong hybrids does not appear to acco unt 3 adequately for the highly specialized manufacturing 4 cost and scaling that is unique to the lithium batt ery 5 market. I have more detailed comments in the writt en 6 portion. 7 Moving on to number two, the projected increme ntal 8 cost for the heavy-duty pickup and vans, strong and 9 mild hybrids, seem a little bit low. The heavy-dut y 10 pickup and van strong and mild hybrid cost projecte d in 11 RIA tables 2-179 and 2-183 are based on weight scal ing 12 from the light-duty sector that do not adequately 13 account for production volume differences between 14 light-duty and heavy-duty sectors. By contrast, we 15 feel that vocational cost targets are reasonable 16 because the weight scalings become a more significa nt 17 factor there. 18 And, most importantly for us, item 3, we recommend 19 expanding the trading compliance paths for addition al 20 flexibility to allow major OEMs to take advantage o f 21 the fuel and emissions savings technologies deploye d by 22 third party up-fitters, like ourselves.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 243 1 After a complete road-worthy, heavy-duty vehic les 2 produce through a multi-manufacturer process. Many 3 vehicles undergo additional modifications by third 4 party companies that install systems that further 5 reduce fuel consumption and emissions, some of whic h 6 are mentioned in the RIA table 2-49. 7 Ford Motor Company alone attributes the 8 introduction to the marketplace of more than 50,000 9 advanced technology medium and heavy-duty vehicle 10 solutions today from third party companies, which a re 11 adding equipment to Ford vehicles that wouldn't 12 necessarily fit the draft rules definition of a 13 delegated assembly. 14 While the EPA and NHTSA are regulating these 15 primary manufacturers, we don't believe the agencie s 16 are prevented from measuring and assigning credits to 17 third party products that produce measurable, robus t, 18 documentable savings that could then participate ina 19 compliance credit marketplace. In XL Hybrids' curr ent 20 business model, our savings right now would primari ly 21 benefit just the end fleets when they could also be 22 contributing in the phase 2 regulation goals. ThePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 244 1 benefits to the public would be a more market-drive n 2 process resulting in a faster introduction of these 3 advanced savings technologies and the potential for 4 achieving greater reductions and stringency. We 5 recognize structuring such a program would be 6 challenging, but we ask that the rules be modified to 7 specifically allow for such a possibility so that s uch 8 a program could be developed. 9 Thank you for your attention today. 10 MS. AMERLING: Thank you very much. 11 Mr. Drew, welcome. 12 MR. DREW: Thank you. 13 My name is Charles Irvin Drew. And I am 14 representing the Union of Concerned Scientists. I am 15 testifying as a citizen and a scientist. I have a 16 Ph.D. in chemistry, and I am an emeritus professor of 17 chemistry. So, therefore, I am going to approach t he 18 truck standards from somewhat of a scientific 19 perspective, emphasizing the carbon cycle a bit. 20 And so we need to understand that the fossil f uels 21 that we burn today have been buried underground for200 22 to 250 million years. And the energy from petroleumPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 245 1 that we use today and that drives our economy comes 2 from ancient sunlight tied up in the chemical bonds , a 3 lot of them carbon bonds. The oil production has 4 brought the petroleum and, thus, the carbon to the 5 surface. 6 Burning petroleum releases the ancient buried 7 carbon in the air in the form of carbon dioxide, as we 8 know. We are, thus, changing the climate and chang ing 9 the Earth dramatically and radically. 10 Simple chemical mathematics shows that a gasol ine 11 engine that burns 110 gallons of fuel produces 1 to n of 12 CO2. Because of a slight difference with diesel an d 13 its density, it is 100 gallons will produce, 100 14 gallons of diesel will produce, 1 ton of CO2. 15 The majority of that CO2, about 55 percent, go es 16 into the atmosphere and absorbs energy that cannot 17 escape the Earth's atmosphere. As you know, this 18 creates global warming. The rest of the CO2 gas 19 produced will be absorbed by the oceans, increasingthe 20 ocean acidity. 21 The molecules of CO2 that enter the atmosphere 22 will stay in the atmosphere and warm the Earth forPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 246 1 almost 500 years. That is 25 generations. The warming 2 of our atmosphere is leading to a horrific conseque nce 3 for humans. And as the sea levels rise, stronger 4 storms and changes in the precipitation will lead t o 5 flooding in some areas and drought in others. 6 The carbon dioxide that enters the ocean combi nes 7 with water to form carbonic acid. This is increasi ng 8 the acidity of the oceans on a global scale. This is 9 bad news for coral, for the aquatic and marine life . 10 The emissions of an 18-wheel tractor-trailer t hat 11 gets 6 miles per the gallon are enormous. Follow 12 through with me on this for a minute. A loaded 18- 13 wheeler that weighs about 40 tons, tractor-trailer and 14 load, with a fuel consumption of 6 miles per gallon 15 will produce 3.73 pounds of CO2 for every mile thatit 16 goes down the road. Many rigs are driven 100,000 m iles 17 per driver. And sometimes there are two drivers. So a 18 rig could be driven up to like 200,000 miles a year . 19 That one trailer going that distance will produce 3 73 20 tons of CO2 per year. That is over 9 times the wei ght 21 of the loaded truck based on a 40-ton rig. 22 Strengthening the fuel economy standards willPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 247 1 reduce not only the cost and emissions but also the 2 emissions. The annual fuel consumption for that 3 18-wheeler that gets 6 miles per gallon driven 200 4 miles a year is 33,333 gallons. That fuel at $4 a 5 gallon costs $133,000. 6 The Union of Concerned Scientists recommends t he 7 standards leading to a 40 percent reduction of fueluse 8 by trucks by 2025. Achieving that target will cut the 9 emissions for that one truck 150 tons per rig per year 10 and cut the fuel costs $53,000. These are huge sav ings 11 of both costs and carbon emissions that we must ach ieve 12 in order to slow global warming. 13 Therefore, I urge the members of this hearing 14 committee to incorporate the Union of Concerned 15 Scientists' recommendations for fuel economy standa rds 16 for trucks. Every effort to slow the burning of ca rbon 17 buys us more time to create a sustainable global 18 planet. 19 Thank you for the opportunity to speak today. 20 MS. AMERLING: Thank you. 21 Now we will hear from Brett Barry. 22 MR. BARRY: Hi. Good afternoon. And thank yo uPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 248 1 for the opportunity to provide testimony on the 2 proposed phase 2 rulemaking. 3 My name is Brett Barry. And I am here today 4 representing Clean Energy, North America's largest 5 provider of both fossil and renewable-based naturalgas 6 transportation fuel. 7 While we are not an engine manufacturer, Clean 8 Energy is a strong advocate within the industry for 9 continued advancements in natural gas engine techno logy 10 towards near-zero emissions performance. 11 We applaud EPA's and NHTSA's development of th e 12 proposed rule, which continues the important work o f 13 curbing tailpipe emissions in a fair and equitable 14 manner. The rule recognizes diversity of fuels under 15 its purview by providing the appropriate amount of 16 flexibility without sacrifice to the rule's ultimat e 17 objective. Specifically, we appreciate the continu ed 18 allowance of cross-pollutant trading of CH4, N2O, a nd 19 CO2. 20 The rule also provides consistency. Continued 21 utilization of the 100-year global warming potentia l of 22 25 for CH4 provides a standard metric across the fu llPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 249 1 array of light-, medium-, and heavy-duty vehicles a s 2 well as other agency rules governing greenhouse gas 3 emissions. New territory is being blazed as the ru le 4 proposes to regulate additional aspects of natural gas 5 vehicles, which will ensure NGBs are providing thei r 6 lowest emissions possible. These include standards for 7 L&G tank hold times and addressing possible methane 8 emissions from open crank cases. 9 While we will ultimately defer to tank and eng ine 10 manufacturers on how best to accomplish the aim of 11 these new regulations, we applaud EPA and NHTSA for 12 addressing these issues that will ensure the 13 elimination of unnecessary methane leaks in engine 14 systems. 15 And, for the record, we are strongly supportive of 16 closed crank systems for spark-ignited engines in o ur 17 space as they have successfully implemented this 18 strategy in Europe. We understand that some 19 stakeholders will be asking that the EPA and NHTSA 20 consider establishing a low-NOx standard for engine s 21 within the final rulemaking, much like the one bein g 22 proposed by the California Air Resources Board.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 250 1 While Clean Energy does not currently have a 2 formal position on this proposed addition to the ru le, 3 we are very proud of our industry's tradition in 4 delivering optional low-NOx performance well in adv ance 5 of competing combustion technologies. Specifically , 6 Cummins Westport has recently announced its plans t o 7 deliver a nine-liter engine available to the market 8 that meets a .02-gram per brake horsepower hour lim it 9 as early as quarter 1 of 2016. Further, Cummins 10 Westport believes that it would deliver similar 11 missions performance for its 12 and 6.7-liter produ ct 12 line as early as Q2 2017 if they receive onboard 13 diagnostic flexibility from the Air Resources Boardand 14 additional R&D funding from local and state agencie s. 15 Of course, the natural gas industry is not onl y a 16 pioneer in eliminating the real impacts of mobile 17 source criteria emissions. It is also a leader in 18 finding solutions to reduce greenhouse gas emission s by 19 investing heavily in renewable natural gas space. We 20 would like to thank the EPA for updating the renewable 21 fuel standards to provide an even greater incentiveto 22 produce renewable natural gas on par with otherPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 251 1 cellulosic fuels. 2 In conclusion, further greenhouse gas reductio ns 3 from renewable natural gas, which is an ultra low4 carbon fuel, have proven to be the lowest carbon fu el 5 source for heavy-duty class 7 and 8 trucks, 6 outperforming both electric and fuel cell strategie s. 7 Combining both the advanced engine technology of 8 natural gas with renewable natural gas blends, and you 9 suddenly have a cost-effective alternative that can 10 deliver power plant-equivalent criteria emissions a nd 11 superior greenhouse gas performance for the medium-and 12 heavy-duty truck space. 13 Lastly, we appreciate the scope of the rule, which 14 looks more at the tailpipe emissions, rather than 15 lifecycle emissions, which we believe should be 16 addressed but in other regulatory frameworks. 17 Thank you. And we appreciate the time. 18 MS. AMERLING: Thank you, Mr. Barry. 19 Mr. Rodriguez, welcome. 20 MR. D. RODRIGUEZ: Good afternoon. My name is 21 Dennis Rodriguez. And I am the chief city executive 22 for Siemens in California. In this capacity, I han dlePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 252 1 our company's municipal approach for the major markets 2 in California. 3 California is leading the U.S. in a transforma tion 4 of the transportation sector. The results are 5 encouraging on the passenger transport side, where a 6 trend towards decreasing fuel consumption and emiss ions 7 is visible. 8 For freight transport, the picture is less cle ar. 9 And Siemens wishes to encourage the EPA to give high 10 priority to implementing solutions that enable 11 renewable energy, such as decarbonized electricity, to 12 achieve a similar shift in freight emissions, as ha s 13 been achieved for passenger transport. 14 The challenge of freight emissions goes beyondthe 15 current consumption. The California Air Resources 16 Board's most recent forecast showed GHG emissions f rom 17 trucks going from about 20 million metric tons CO2- 18 equivalent in 2012 to nearly 35 million metric tons 19 CO2-equivalent in 2050. 20 While light-duty vehicles are forecast to cut 21 their CO2-equivalent emissions over time, freight 22 trucks are forecasted to grow between 2012 and 2040 .Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 253 1 Globally, GHG emissions from heavy-duty vehicles ar e 2 growing rapidly and are expected to surpass emissio ns 3 from passenger vehicles by 2030. 4 Shifting freight to other modes, such as upgra ded 5 rail systems, may play a part of the solution. Tha t 6 said, road freight is anticipated to remain a large 7 part of the transport system. 8 To achieve the general goals of cutting petrol eum 9 use and GHG reduction, it is imperative that freigh t 10 trucks are put on the path toward zero emission. 11 Strong zero-emission goals are also important in gi ving 12 air quality-focused businesses the certainty that t hey 13 need for long-term planning. This is necessary, bo th 14 for technology users and also for companies develop ing 15 solutions when they make investment decisions. 16 Given the goal of California to generate 50 17 percent of electricity from renewable sources as we ll 18 as federal plans for decarbonizing power generation , it 19 makes sense to find efficient ways to make this cle ar 20 energy available to heavy-duty trucks. 21 The electromobility offers a variety of benefi ts, 22 including improved local air quality and the increa sedPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 254 1 energy efficiency, which lowers operating costs. 2 The main obstacle to electrified road freight has 3 been the size and weight required for onboard stora ge 4 of electrical energy. This problem can be solved b y 5 providing power to the truck as it is driving throu gh 6 an overhead catenary system. These catenary soluti ons 7 are currently being built to be demonstrated on pub lic 8 roads. For example, the Swedish Transport Authorit y 9 has recently announced two demonstration projects i n 10 June of this year, including an OCS system being bu ilt 11 by Siemens. 12 In Germany, Siemens is also operating a privat e 13 road, 1.2-mile OCS, freight truck test track. This led 14 German authorities to study the technical feasibili ty 15 of this test track as well as the environmental 16 benefits. The conclusion of that study led the German 17 federal government to approve plans of a public fie ld 18 freight truck trial using our OCS system. 19 Independent reports also confirm the economic and 20 environmental benefits of a catenary solution in 21 California. This led the South Coast Air Quality 22 Management District to commission a project withPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 255 1 Siemens near the Ports of Los Angeles, Long Beach, and 2 the City of Carson, California. Construction of th is 3 project involves vehicles of several different truc ks, 4 one of which is being provided in collaboration wit h 5 Mack Trucks. The goal of the project is to collect 6 data and evaluate the benefits of such a system, 7 especially for highly used road freight operations 8 connecting ports with local rail yards and logistic al 9 centers. 10 Much of California's road freight is concentra ted 11 on road freight corridors, whether it be the I-710, the 12 I-5, highway 60, all of which help form the backbon e of 13 California's freight network. Instead of seeing 14 freight emissions as a difficult challenge, we woul d 15 like to view this as a golden opportunity. 16 Siemens welcomes the focus by federal and loca l 17 officials as well as leading agencies in developing 18 strategies that will reduce road freight emissions. 19 Thank you very much for your time. 20 MS. AMERLING: Thank you. 21 Mr. Cadle, welcome. 22 MR. CADLE: Thank you. Good afternoon. And t hankPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 256 1 you for the opportunity to be here today and provide 2 feedback on the phase 2 greenhouse gas rulemaking 3 proposal. 4 My name is Rob Cadle, and I represent the 5 transportation systems business at Honeywell 6 International, a leading provider of turbochargers for 7 light- and heavy-duty passenger and commercial 8 vehicles. 9 We applaud the EPA, NHTSA, and CARB for their 10 efforts to make the phase 2 rulemaking process 11 transparent and data-driven, soliciting and conside ring 12 multiple views across the industry. We also apprec iate 13 the 10-year timeline through 2027 and the 3-phased 14 approach because it provides the industry with clea r 15 milestones that support long-term investment in the 16 development of enabling technologies. 17 The testimony I am providing today focuses on two 18 specific areas: the engine efficiency improvement 19 targets outlined in the heavy-duty tractor portion of 20 the proposal and the consideration given to certain 21 fuel types in the heavy-duty pickup truck and van a nd 22 medium-duty and vocational truck portions of thePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 257 1 proposal. 2 We appreciate that revised weighting factors f or 3 the SET cycle CO2 emissions for the heavy-duty trac tor 4 engine standards have been included in the proposal . 5 These revised weighting factors better represent re al6 world operating conditions of long-haul trucks with 7 minimal additional complexity. However, the new 8 weighting factors effectively represent a regulator y 9 downspeeding of engines, and we estimate this will 10 result in a cycle-weighted fuel consumption improvement 11 of approximately 1 percent, with no changes made tothe 12 actual engine. This essentially means that 2021 mo del 13 year engines only need to be .5 percent more effici ent 14 than the 2017 baseline, a .12 percent per year 15 improvement over a 4-year time period. This is wel l 16 below the industry's historical continuous improvement 17 rate of change in efficiency. The new weighting 18 factors have a similar impact on subsequent emissio ns 19 reduction levels. 20 For this reason, we believe there is room to make 21 the engine-level CO2 reduction larger than is refle cted 22 in the current proposal, without the need forPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 258 1 widespread adoption of advanced technologies like 2 Rankine Cycle waste heat recovery. Honeywell can h elp 3 provide data and work with the EPA to refine the inputs 4 to models to better reflect the improvements that a ir 5 systems technology can provide in order to enable t his. 6 Additionally, we believe the new regulation sh ould 7 be technology-neutral, setting standards that every one 8 must meet, without favoring one approach over anoth er. 9 Fuel neutrality is critical to ensure that the prop osed 10 rule could be met in the most cost-effective mannerfor 11 industry and consumers. We are, therefore, concern ed 12 with several aspects of the proposed rule regarding 13 fuel neutrality. 14 First, requiring heavy-duty pickup trucks and vans 15 powered by diesel and gasoline engines to each impr ove 16 fuel efficiency by 16 percent from the 2017 baselin e 17 will only achieve the targeted overall fleet CO2 18 reduction if diesel and gas market share remains 19 constant. It is likely that gasoline-powered vehic les 20 will be able to achieve their required decrease in fuel 21 consumption at lower cost and complexity than diese l 22 engine vehicles, resulting in a shared shift toward sPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 259 1 gasoline vehicles, which emit more CO2, therefore, 2 increasing the total fleet CO2 emissions. An 3 alternative is to simply require a 16 percent fleet 4 average CO2 emissions reduction and allow the indus try 5 and consumers to pick the fuel and technology 6 combination that offers the best value while meetin g 7 this requirement. 8 The current proposal also excludes gasoline 9 engines from the medium-duty and heavy-duty vocatio nal 10 portion of the phase 2 regulation. The cost 11 differential between diesel and gasoline engines ha s 12 increased substantially over the past ten years as 13 diesel engines have adopted advanced technologies t o 14 meet more stringent NOx and PM regulations. This h as 15 made diesel engines less competitive on initial cos t, 16 and the industry has seen a steady increase in the 17 market share of gasoline engines in class 3 through5 18 applications. 19 We believe that the proposal as written will 20 further increase the initial cost of diesel engines 21 while allowing gasoline engines a free pass on CO2. 22 This will likely result in a much larger share forPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 260 1 gasoline in these markets and has the potential to 2 create a double negative effect: higher operating cost 3 for vehicle users and higher fleet average CO2 4 emissions. We intend to elaborate on these items i n 5 our written comments and will provide further 6 supporting documents. 7 Honeywell supports continued efforts to keep t he 8 United States at the forefront of greenhouse gas 9 reduction and fuel efficiency technology while 10 balancing the needs of industry, consumers, and the 11 environment. We believe strong targets are feasibl e 12 and are committed to working with government and 13 industry to provide innovative technologies that 14 provide a clear end-user payback. 15 Thank you again for the opportunity to speak 16 today. 17 MS. AMERLING: Thank you. 18 And now we will hear from Kevin Golsch. 19 MR. GOLSCH: Good afternoon. My name is Kevin 20 Golsch. And I am a director of North America field 21 engineering for Exa Corporation. I appreciate the 22 opportunity to speak with you today.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 261 1 Exa Corporation, founded at MIT and based in 2 Burlington, Massachusetts, is a developer of a unique 3 aerodynamic simulation tool based on the Lattice4 Boltzmann method. Our technology has been used for 5 over 20 years by 12 of the 13 major global automoti ve 6 and 5 of the 6 largest global heavy vehicle origina l 7 equipment manufacturers to support product development 8 in the area of aerodynamics, thermal management, an d 9 aero acoustics. For example, customers have improved 10 the aerodynamic efficiency of their products by as much 11 as 10 percent over previous generations. 12 Exa results have been used to support SmartWay 13 certification, EPA's phase 1 greenhouse gas 14 regulations, and some of the most aerodynamically 15 efficiency class 8 tractors on the road today. In 16 fact, some of our customers are using our simulatio n 17 capabilities exclusively for aerodynamic and coolin g 18 designs without the use of physical prototypes, suc h as 19 in the case of Jaguar's lowest drag coefficient 20 vehicle: the XE. 21 We are pleased to see in the proposed ruling t hat 22 computational fluid dynamics, also known as CFD, wi llPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 262 1 continue to be one of the allowed methods for heavy 2 vehicle aerodynamic assessment. The confidence our 3 customers have in our tool has been built from many 4 years of experience performing correlations to othe r 5 test methods, including the full- and reduced-scale 6 wind tunnel testing, SAE type II fuel economy testi ng, 7 coast-down testing, constant speed aerodynamic test ing, 8 and full-scale drag meter testing. Thus, the decis ion 9 to certify the use of CFD for the regulation of 10 greenhouse gas and fuel efficiency will fit well wi thin 11 the aerodynamic design processing used today, help our 12 customers to be efficient and to deliver superior 13 products to the benefit of society. 14 The proposed ruling does, however, introduce 15 challenges from the variations that we expected in the 16 predicted drag coefficients, from not only the allo wed 17 methods, coast-down, wind tunnel, and simulation, b ut 18 also within these tools themselves. For example, w ind 19 tunnel drag coefficients are highly dependent on th e 20 facility chosen. And wind average drag, the drag 21 associated with varying ambient wind conditions may 22 vary by as much as 10 percent between wind tunnelPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 263 1 facilities. 2 Another example in an SAE publication done in 3 collaboration with Global Trucks North America and the 4 National Research Council in Canada, Exa results 5 correlated to the experimental results within 1 6 percent. However, when the same vehicle is simulat ed 7 in the open road condition, the drag value changed by 8 37 percent. 9 It is not clear that the proposed aerodynamic bin 10 structure and the F-alt factor, the aerodynamic fac tor 11 for alternate tools, will alleviate these challenge s as 12 we expect the absolute drag values will differ 13 substantially between different test methods and 14 different facilities. 15 Correlating simulation results with any non-ro ad 16 physical testing requires accounting for many speci fic 17 details of the test setup that are not representati ve 18 of the on-road conditions. CFD offers the advantag e of 19 creating a virtual test environment that is more 20 representative of the on-the-road performance. 21 The preferred setup used by our customers for 22 design and development is a domain that replicates thePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 264 1 open road, including a moving ground, rotating tire s, 2 open grill with realistic engine, bay details, and 3 other factors. 4 Further, our customers also regularly evaluate 5 different wind conditions by considering yaw flow. 6 They can even evaluate the impact of the real-world 7 conditions due to the environmental or traffic8 generated winds. The setup details are necessary f or 9 producing results that are representative of on-the

10 road performance. 11 It is our suggestion that the EPA and NHTSA 12 require a certification procedure for an alternate tool 13 that includes broad validation suite, including 14 different vehicle types from aerodynamic sleepers t o 15 less aerodynamic day cabs. In the proposed program , 16 the coast-down method is a proposed standard to mea sure 17 the vehicle aerodynamic performance. However, we f eel 18 this test procedure does not relate closely to real

19 world fuel efficiency. 20 Since these types of vehicles experience 21 significant changes in aerodynamic drag with relati vely 22 small changes in wind, a better predictor of real-w orldPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 265 1 fuel economy is used as a use of wind average drag. 2 Coast-down testing is limited to near-zero wind yaw 3 angle and does not accurately represent the 4 aerodynamics experienced on the road due to wind. 5 Because of the significant impact of real-world 6 efficiencies due to the wind yaw effects, we feel i t is 7 imperative that wind effects be part of the standar d 8 for both tractors and trailers. 9 The negative consequences of not adopting wind 10 effects into the standard for tractors and trailers 11 include truck and trailer buyers, not realizing the 12 fuel savings implied by the levels of which the tru ck 13 and trailers are certified and the overall emission 14 reductions promised for the program will not be 15 achieved. 16 Some of the proposals attempt to address the 17 inadequacies of the coast-down results by adjustingthe 18 coast-down results through the use of alternate too ls 19 for when they have the drag. We feel, as stated ab ove, 20 that the variations of wind average drag between th e 21 tools and facilities themselves is too significant and 22 it would be an adverse consequence to allowingPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 266 1 alternative tools for adjusting coast-down results. A 2 standard that holds all the tools accountable to a 3 real-world measure of the wind average drag performance 4 of a vehicle, such as constant speed aerodynamic 5 testing, is imperative in ensuring predictable 6 behavior. 7 The joint proposal of EPA and the National Highway 8 Safety Administration to reduce greenhouse gas 9 emissions and increase fuel economy for medium- and 10 heavy-duty highway vehicles will have a very import ant 11 impact on real-world fuel savings and emissions of 12 appropriate standards are adopted. At the same time, 13 those interested in truck fuel economy across the w orld 14 are watching this rulemaking in other governments t o 15 develop their own programs to improve truck 16 efficiencies and cut greenhouse gas emissions. The 17 final rule can set the stage globally in this regar d. 18 The agencies have done a great deal of excelle nt 19 work in exploring how standards for medium- and heavy20 duty vehicles could operate in preparing this progr am 21 for public review. We believe that the proposal ca n 22 and should address standards that promote real-worl dPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 267 1 fuel savings. Our nation has the opportunity with 2 these regulations not only to reduce the greenhousegas 3 emissions but also stimulate the engineering innova tion 4 and, thus, job growth. This can be achieved by mak ing 5 sure that the regulations are providing accurate me ans 6 of establishing vehicle performance characteristics and 7 allowing the manufacturers equal opportunity of 8 achieving them. By doing so, we will help improve our 9 competitiveness at the global market and help our 10 economic growth. We will also get an opportunity t o 11 example of other nations. And this would help redu ce 12 global greenhouse gas emissions. 13 We are excited to actually help this effort wi th 14 the unique technology we developed over the last tw o 15 decades. We strongly believe in the need for our 16 nation and the world to reduce greenhouse gas 17 emissions. We will continue to work with our partn ers 18 in industry to helping them design vehicles with be tter 19 aerodynamic performance and considerably reduce the 20 emissions. We also look forward to helping the EPAand 21 NHTSA achieve these goals. 22 Thank you.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 268 1 MS. AMERLING: Thank you very much. 2 We will turn now to Dorothy Kelty. 3 MS. KELTY: Good afternoon. I am Dorothy Kelt y. 4 And I thank you very much for allowing my testimony 5 today. 6 I am a member of the Union of Concerned 7 Scientists. I want to support the strongest standa rds 8 available to you for trucks serving our local harbo rs. 9 These two ports receive half of all the cargo shipp ed 10 from Asia into the United States. Most of this car go 11 leaves our ports on trucks headed all over the Unit ed 12 States. 13 Increasing fuel efficiency while transporting this 14 cargo all over our country is key to reducing heat15 trapping emissions and improving air quality that 16 Southern California has been working on inch by inc h 17 and step by step for over 50 years. Reducing fuel 18 consumption, thereby reducing emissions, will have the 19 additional effect of reducing toxic air pollution f rom 20 idling trucks and refineries that produce the fuel. 21 The result will be $37 billion in public health and 22 welfare benefits.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 269 1 We have made tremendous progress and are still 2 improving. I wholeheartedly promote your proposal for 3 cleaner and leaner fuel standards on our highways. I 4 urge you to make the standards as strong as possibl e by 5 setting a target of 40 percent improved efficiency by 6 2025. 7 I can remember as a child not being able to se e 8 the beautiful San Gabriel mountains or even the cor ner 9 of my one-block street many times in San Gabriel. You 10 brought us so far. We know that strong standards c an 11 improve our quality of life. We have seen it done 12 before. It is a win for our planet, our state, andour 13 citizens' health. 14 Thank you so much. 15 MS. AMERLING: Thank you very much. Are thereany 16 questions for this panel? Bill? 17 MR. CHARMLEY: Just one question for Mr. Lovel ace. 18 Could you mention your three items? Your first one , 19 you said a cost learning curve for lithium ion 20 batteries and you would provide additional comments . I 21 don't want to wait until September. Were you sayin g 22 that directionally we underestimated the impacts ofPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 270 1 manufactured learning by doing for lithium ion or we 2 overestimated it? 3 MR. LOVELACE: Yes. Well, so it sort of ties into 4 my second comment, which was looking at the cost of 5 hybridization of the heavy-duty vans and trucks. T hose 6 seem too low. 7 But in terms of implying back to what that mea ns 8 in terms of the cost learning curves, you know, I r ead 9 the description of how you came up with the cost 10 learning curves. And, you know, they were kind of 11 generalized trends in learning from manufacturing. And 12 that just sort of registered a bell because lithium 13 battery manufacturing is quite specialized and need s to 14 get the quite tremendous scales before you see real ly 15 measurable reductions. 16 So, honestly, it is not the total dollar level s. 17 It is the shapes of the curves are to me not 18 specifically applicable to hybridization, applicabl e to 19 the other categories. 20 MR. CHARMLEY: Okay. Thank you. 21 MR. LOVELACE: Sure. 22 MS. AMERLING: Steve, did you have a question?Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 271 1 MR. SILVERMAN: A couple of questions. First off, 2 I want to commend Mr. Lovelace for slogging throughthe 3 RIA. I am sure if you had any insomnia difficultie s, 4 that would have rectified them. 5 I thought I heard you say there should be 6 increased trading opportunities. I am not sure if you 7 meant to address just within the what we call avera ging 8 sets; for example, just within 2B's and 3's or acro ss 9 categories. Could you clarify that, please? 10 MR. LOVELACE: Yes. And my expectation is thi s is 11 going to take more follow-up. The basic point is t hat 12 a company like us plays outside the regulation. An d so 13 we are looking for additional flexibility and basic ally 14 credit opportunities that would allow a company like 15 ours to play within the regulation. You don't get to 16 take advantage of the fuel and emissions savings 17 products that we are putting out there. And neithe r do 18 the major OEMs the way it is currently structured. So 19 that was the major point that I was trying to get a t 20 there. 21 MR. SILVERMAN: Thank you. 22 And one further question to you and also to Mr .Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 272 1 Rodriguez, if you could. Any preliminary position on 2 certification mechanisms for hybrids, either the on es 3 we have proposed or ones required by other 4 jurisdictions? 5 MR. LOVELACE: Yes. I mean, I think that is 6 probably going to take some further thought and 7 probably discussion with my NGO friends at the vari ous 8 other organizations that have testified today. 9 MR. SILVERMAN: Okay. 10 MR. D. RODRIGUEZ: I have got, I think, the se cond 11 question. 12 MR. SILVERMAN: Yes. 13 MR. D. RODRIGUEZ: So I would kind of echo tha t 14 sentiment. I think we would want to kind of put some 15 deeper thought into that and maybe offer up some, 16 suggestions. We are going to submit some more deta iled 17 comments coming up next month. So we can add that to 18 our commentary. 19 MR. SILVERMAN: Okay. We would be quite 20 interested. 21 And one final question to the gentleman from 22 Honeywell. With regard to vocational engine standa rds,Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 273 1 you probably realize that we proposed some 2 improvements, but we had it in the vehicle part of the 3 standard, rather than the engine standard. So if y ou 4 could address that in your comments as well, please ? 5 MS. AMERLING: I think that wraps up this pane l. 6 Many thanks to the members of this panel. And we w ill 7 move to panel 11. 8 MR. GRUNDLER: Thank you, panel 10. 9 Panel 11 consists of Joe McLaughlin from the 10 Sierra Club; Jeffrey Grossman from STEMCO; a citize n 11 testifier, Gordon Taylor; from Achates Power, Larry 12 Fromm; from Advanced Engine Systems Institute, Mona 13 Sheth; from U.S. Hybrid, Abas Goodarzi; from Effenc o, 14 Benoit Lacroix; and Bill Dale, representing himself . 15 Welcome, everyone. Mr. McLaughlin, ready when you are. 16 MR. McLAUGHLIN: Yes. I would like to thank y ou 17 for the opportunity to testify here today. And I w ould 18 also like to thank your staff for allowing me to mo ve 19 to the head of the line because I have an engagemen t I 20 have to get to and get on the freeway right away. 21 My name is Joe McLaughlin. I am a retired tea cher 22 from Huntington Park High School. I worked there f orPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 274 1 42 years. Huntington Park High School is situated 2 about one mile from the Alameda corridor and sits e qual 3 distance between the Harbor Freeway and the Long Be ach 4 Freeway. So we got a highly concentrated dose of L os 5 Angeles air. 6 I would like to thank you for bringing in some 7 regulations that have improved that quality. I wis h 8 you could do something with the Farmer John 9 Slaughterhouse that is right in the neighborhood al so 10 because that certainly affects the air quality in t he 11 area. 12 Being a lay person, I am a little in awe of th e 13 expert testimony that has been presented to you today, 14 especially from the Union of Concerned Scientists. The 15 facts and figures that I would have brought are pal e in 16 comparison. So, instead of making that type of a c ase, 17 I would like to bring to the floor the duty that yo u 18 have as the Environmental Protection Agency. And t he 19 environment that you protect is what I live in, wha t my 20 children live in, and what my grandchildren live in . 21 And I can tell from some of the testimony here thatyou 22 are certainly aware of the threat that our environmentPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 275 1 is under, posed by the global warming that is takin g 2 place. 3 So what I would like to do is just encourage y ou 4 to take the leadership and responsibilities that yo u 5 have to protect the environment for all of us, to move 6 as swiftly and as courageously as you can to put inthe 7 strongest regulations possible because an awful lotis 8 depending on that. 9 And I know that you are on the forefront, righ t on 10 the battle lines of this because the fossil fuels h ave 11 built the world's civilization and economy. And weare 12 still committed to that. But it is in the long run 13 going to kill us. So we have to make a transition as 14 quickly as possible. And you, ladies and gentlemen , 15 are in a position to do something. I can come hereand 16 talk and talk and talk, but you actually have the p ower 17 to do some things. So I encourage you to take thatto 18 heart and know that you are protecting a lot of people. 19 So thank you very much. And I am sorry to exc use 20 myself, but I do need to go. Thank you very much. 21 MR. GRUNDLER: Thank you and no worries. 22 Mr. Grossman, welcome.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 276 1 MR. GROSSMAN: Yes. Thank you. 2 I am with STEMCO, which is a company that 3 manufactures many components for trucks and trailer s, 4 including trailer tails, which are aerodynamic devi ces 5 at the rear of the trailers. 6 I would like to thank the EPA and NHTSA for 7 recognizing the help that trailer aerodynamics can play 8 in achieving these phase 2 goals and especially for 9 including device manufacturers as one of the many 10 groups sought out in the proposal process. 11 We will submit written comments next month, bu t I 12 would like to share three comments with everyone to day. 13 Number one, we support alternative 4 for the traile rs, 14 which accelerates the 2027 standards up by 3 years to 15 2024. 16 Number two, we support the aerodynamic device 17 testing alternative, which allows device manufactur ers, 18 like STEMCO, to conduct their own third party 19 aerodynamics testing and achieve EPA preapproval. We 20 believe that this is important to minimize the 21 accounting testing and reporting burden placed on t he 22 trailer manufacturers. And we see this as a greatPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 277 1 example of that. 2 I would encourage the EPA and NHTSA to spend 3 additional time investigating ways to further reduc e 4 the work placed on the trailer manufacturers as par t of 5 this phase 2. For example, the EPA could provide a 6 preapproved list of aerodynamic devices, similar to 7 those shown on the SmartWay website, and allow the 8 trailer manufacturers to choose from that list and, 9 therefore, avoid having to calculate delta CDA 10 calculations to determine the equivalent. 11 Number three, there are multiple aerodynamic 12 testing methods mentioned in the proposal, such as wind 13 tunnels, CFD, and on-road SAE type 2 testing. I 14 recommend that the EPA and NHTSA investigate requir ing 15 an aerodynamic device to pass more than one of thos e 16 testing methods before it is recognized as preappro ved. 17 We have seen great advances over the past deca de 18 in testing facilities and protocols, and I would li ke 19 to particularly applaud the 2014 EPA SmartWay progr am, 20 which recognizes the multiple testing methods that are 21 out there, but I still believe that any individual 22 testing method has its pros and cons and that the b estPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 278 1 picture is told when an aerodynamic device can 2 demonstrate fuel savings across multiple methods. This 3 will certainly increase the testing cost burden on 4 companies like STEMCO, but I believe having aerodyn amic 5 devices certified at their appropriate and accurate 6 level is paramount to the environment and fuel savi ngs 7 success of phase 2. 8 Thank you. 9 MR. GRUNDLER: Thank you, sir. 10 Mr. Taylor, welcome. 11 MR. TAYLOR: Thank you. I appreciate having t he 12 title of "Citizen." I guess we are all citizens, 13 aren't we? Thank you for the opportunity to make 14 comments. I live here in Southern California. I h ave 15 for a long time. I will not say anything new to yo u, 16 but I do have some thoughts that I would like to 17 express. 18 First of all, I would just like to say that I have 19 tremendous respect for all the members of these pan els. 20 There is a tremendous amount of ingenuity and intel lect 21 and capability that is represented here. And I am sure 22 you folks recognize that. So listen closely to wha tPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 279 1 they say. You don't have to listen closely to whatI 2 say. 3 There is something that came up a couple of ti mes 4 about history when we were not able here to walk ou t 5 our front door without tearing and not being able t o 6 breathe. So what happened? How do we get where weare 7 here today? 8 So the EPA established standards. And the 9 standards were implemented, and the air became clea ner 10 but not clean enough. So as time went by, we had t o 11 implement more standards. They were implemented. And 12 the air became cleaner. So here we are today. If we 13 put a percentage on the increase of cleanliness, itis 14 probably 1,000 percent maybe. 15 We still have areas of concern. We still havea 16 lot of pollution here. But it is so much cleaner 17 because of our history and the actions we have take n. 18 So we look at that and say, "What do we do now?" And 19 that is where we are today. 20 I am in the food industry. And we have plants all 21 over the United States. We use a lot of trucks. We 22 have a lot of our own trucks, but we also utilizePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 280 1 mostly commercial trucks through brokers. And we h ave 2 a lot of trucks on the road. 3 The food industry is probably when you -- foodand 4 beverage. When you consider food and beverage 5 industries, it is probably the largest business in the 6 United States and possibly the world when you give it 7 some thought. The gentleman talked earlier about t he 8 food service trucks. The food service industry whe n 9 you think about it, a truck delivers to every 10 restaurant in the United States every week, sometimes 11 every day. How many restaurants do we have in this 12 country? So I don't want to beat that, but I do wa nt 13 to recognize that. 14 Part of that -- and I want to talk about it a 15 little bit -- is the perishable food piece of this 16 business. Whenever a truck has perishable food in it, 17 that air conditioner has to go constantly. Otherwi se, 18 the food will spoil. So I had the opportunity to t alk 19 to Mr. Curl over lunch. And we talked about a coup le 20 of things, but there is like a 20-gallon, 20- or 30

- 21 gallon, tank of fuel that has to operate that. Some 22 truckers have recognized that and have an electrica lPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 281 1 component where they can operate it. But most of t he 2 trucks that I see coming into our docks that are 3 refrigerator trucks do not utilize electricity to keep 4 that running. 5 So I think it is something. I am sure you have 6 thought about it. Like I said, I don't think I am 7 going to tell you anything new, but I think that is 8 something that needs more emphasis. 9 The previous discussion right here with this 10 gentleman about aerodynamics is another thing that we 11 are trying to do with our trucks. We have panels o n 12 the bottom which help. And then, of course, you se e 13 the bulbs on the front of the trailers and the hood s on 14 top of the trucks. 15 The other night, I was having this discussion with 16 my daughter. A couple of years ago, two or three years 17 ago, she bought a hybrid. And she asked me a quest ion. 18 And it is a combination electrical and gas. She sa id, 19 "Dad, you know when the last time I filled up my ta nk 20 with gas?" 21 And I said, "No." 22 And she said, "Three months ago." Okay? And thenPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 282 1 she says, "Do you know what my gas mileage is?" 2 And I said, "No." She said, "It's approximate ly 3 100 miles per gallon." 4 Now, if we can do that with cars, what can we do 5 with trucks? 6 I am disappointed that this phase 1 was, what, 7 recommended in 2010 and then actually implemented i n 8 2011. Where have we been? Okay. We need to exped ite 9 this phase. But, as the gentleman from PepsiCola 10 mentioned earlier -- he used a word that I liked. It 11 is called "balance." You have a responsibility to get 12 on this and get it done as soon as you possibly can , 13 but you need to understand the capabilities of the 14 folks you are trying to get to implement this progr am. 15 So there is a balance there. So let's expedite, 16 considering what the industry is going to have to do to 17 get us there. 18 Another comment about Mr. Curl. He brought up 19 this issue of trucks being down. We have trucks th at 20 are down a lot mechanically. And when they go down , it 21 costs you money and time. So a big part of what hewas 22 saying as an individual owner is that a big part ofwhyPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 283 1 his truck goes down is the new technology is not 2 durable. 3 Now, I know you have heard this. It came up 4 earlier. But I guess I would like to reemphasize t 5 hat. If you are going to have someone create new 6 technology, make it durable so it doesn't break down in 7 a year or two and the guy's truck is out of commiss ion 8 and it costs him a bunch of money. He doesn't havea 9 retirement program because of that. 10 You heard him. And I am listening to him over 11 lunch. We are chatting over lunch. And I am going , 12 you know, I am feeling sorry for him. But, on the 13 other hand, he is an individual businessman. He is 14 fighting it. And he is working hard and trying to 15 provide for his family, but he has no retirement 16 program because he has to put all of his money intohis 17 truck. You heard the costs. So a big part of thatis 18 durability. 19 We have the same issue. We have trucks going down 20 all of the time. And if they are going down, they are 21 not delivering product to the restaurants, then it 22 costs everybody money.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 284 1 So, with that, I wanted to comment, I guess. I 2 don't know if my time is up or not, but -- 3 MR. GRUNDLER: It is. 4 MR. TAYLOR: It is? Okay. I am sorry. Then I 5 will -- 6 MR. GRUNDLER: One final comment. 7 MR. TAYLOR: Thank you very much for the 8 opportunity. Thank you for being here. And I am s ure 9 you are going to expedite your job. 10 MR. GRUNDLER: Thank you, Citizen Taylor. 11 Mr. Fromm? 12 MR. FROMM: Thank you. 13 I am Larry Fromm, Vice President of Business a nd 14 Strategy Development for Achates Power. We were fo rmed 15 in 2004 to modernize the efficient opposed-piston 16 engine architecture using modern engineering tools and 17 modern engine components to make it clean and durab le 18 for today's markets requirements while optimizing i ts 19 inherent engines efficiencies. 20 Achates Power works with established engine 21 companies to apply our technology to engines for th eir 22 applications, primarily for trucks and cars. We havePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 285 1 programs underway today to develop engines for lead ing 2 global OEMs that together account for 40 percent ofthe 3 worldwide volume of cars and trucks sold every year . 4 These programs are subject to nondisclosure agreeme nts. 5 So I can't share those details with you, but we do have 6 three publicly announced programs where we are 7 developing engines that I can describe. 8 The Next-Generation Combat Engine program was 9 completed with record-setting results for the U.S. 10 Army. After that program, the U.S. Army awarded us a 11 contract to develop the Advanced Combat Engine. Ou r 12 partner on that project is Cummins. And, then, 13 finally, Fairbanks Morse has licensed our technolog y 14 and employed our technology to improve their oppose d15 piston engine for stationary power and marine powerto 16 improve the emissions, efficiencies, and durabilityof 17 their engines all at the same time. 18 Achates Power has raised over $100 million in 19 private capital to fund our efforts. We now have 8 0 20 employees, mostly technical, and offices in San Die go 21 and also near Detroit, Michigan. We have been runn ing 22 prototype engines on our dynamometers in San DiegoPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 286 1 since 2005 and have over 6,000 hours of testing to 2 validate our claims. We have published and present ed 3 our test results around the world in a series of mo re 4 than 30 technical papers since 2011. Some are 5 available at a table just outside the conference ro om 6 right now. 7 The five-liter prototype engine that we are 8 testing in San Diego as we speak is the most effici ent 9 engine of its power and torque among any we know 10 anywhere in the world. Based on measured results, fuel 11 in, torque out, it is 20 percent more efficient tha n 12 the new Ford power stroke 6.7-liter engine. With 13 identified design improvements, it will be 32 perce nt 14 more efficient than the power stroke engine. This 15 relatively small engine, a medium-duty engine, will 16 easily exceed the proposed phase 2 efficiency standards 17 for heavy-duty engines. We expect a heavy-duty ver sion 18 of the engine to exceed the phase 1 standards by 15 19 percent with known technology. That is, without 20 applying any of the advanced engine technologies be ing 21 developed for conventional engines, those technolog ies 22 can be applied to our engine to make it more effici entPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 287 1 still. 2 I want to make three points. First, we suppor t 3 the separate engine efficiency standards for the 4 reasons well-articulated in the proposed rule. Sec ond, 5 we support the agencies' intent, as stated in the 6 proposed rule, that the standards are meant to be s et 7 based not only on currently available technologies but 8 also on utilization of technologies now under 9 development or not yet widely deployed by providing 10 significant lead time to assure adequate time to 11 develop, test, and phase in these technologies. 12 My final point is that proposed rules require only 13 a 4 percent reduction in heavy-duty engine fuel 14 consumption from the phase 1 requirements and only 15 require this to be implemented by 2027. Our view i s 16 that this requirement is far too modest, so modest it 17 may not achieve the agencies' explicit objective by 18 spurring deployment of advanced technology. A 5 19 percent reduction in cycle average fuel consumptionis 20 not only obtainable with the technology we are 21 demonstrating today, but it is, in fact, our plan. 22 Thank you for the opportunity to comment.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 288 1 MR. GRUNDLER: Thank you very much. 2 Ms. Sheth, you are up. 3 MS. SHETH: Good afternoon, everyone. My nameis 4 Mona Sheth. I am here on behalf of the Advanced En gine 5 Systems Institute to provide comments on the agenci es' 6 proposal to set more stringent greenhouse gas standards 7 for medium- and heavy-duty vehicles. 8 AESI represents several emissions control and 9 efficiency technology manufacturers in an industry 10 employing more than 65,000 people in the United Sta tes. 11 For more than 40 years, our industry has been worki ng 12 with vehicle manufacturers, our primary customers; and 13 the regulators to develop technologies to reduce 14 harmful pollution in the most cost-effective ways 15 possible. 16 The industry's many innovations developed and 17 deployed in the United States in response to scienc e18 driven air quality regulations have reduced polluti on 19 from cars and trucks by more than 75 percent since 20 1975. This has occurred, even while vehicle miles 21 traveled increased 300 percent. We commend the age ncy 22 and the President for going beyond public health an dPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 289 1 environmental impacts of criteria pollutants, like 2 particulate matter, and nitrogen oxides to tackle t he 3 grave risks associated with greenhouse gas and blac k 4 carbon emissions. 5 Carbon pollution from the U.S. transportation 6 sector, especially medium- and heavy-duty vehicles, is 7 a very significant contributor to global atmospheri c 8 concentrations and will rise through 2040 without p hase 9 2 or similar limits. 10 AESI is pleased that the agency has proposed t o 11 retain the basic regulatory structure used in phase1, 12 including a separate engine standard and similar 13 testing and certification procedures. Our industryhas 14 invested heavily in research and systems to deliver 15 cost-effective greenhouse gas reductions to meet th e 16 phase 1 schedule while meeting the 2010 standards f or 17 NOx and PM. Retaining a separate engine standard a nd 18 enhancing compliance enforcement will help ensure t he 19 long-term environmental integrity of the program. 20 AESI supports a final phase 2 greenhouse gas 21 standard that will strongly encourage innovative 22 companies to develop new technologies and systems t hatPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 290 1 can help vehicle and engine makers to quickly, cost

2 effectively, and reliably reduce or eliminate carbo n 3 pollution and still over-perform on criteria 4 pollutants. 5 We appreciate the delicate balance that the 6 agencies must consider between setting an engine 7 standard that appears feasible now versus setting a 8 slightly more stringent technology-driving standard 9 that will prompt faster evolution, more reductions, and 10 greater consumer savings in the long run. 11 There appears to be ample evidence to indicate 12 that alternative force timeline comes closest to 13 striking the right balance, though it does seem tha t 14 greater reductions in the 4.2 percent target in the 15 proposal could well be technically feasible and sti ll 16 quite cost-effective. 17 There is now a multitude of technologies, 18 including waste heat recovery, turbo compounding, 19 advanced downspeeding, hybridization that be ready to 20 deploy in that timeframe or sooner at still-reasonable 21 cost provided the right policy, market signals, or 22 incentives and credits are available.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 291 1 The agencies may want to consider incentives o r 2 credits, particularly in an era of low fuel prices, to 3 expedite the commercialization of these technologie s 4 and earlier and more cost-effective achievement of the 5 program goals. 6 Our members have been working with the DOE's 7 SuperTruck program to demonstrate the magnitude of CO2 8 reductions that engine and vehicle technologies can 9 deliver while improving criteria pollution control 10 systems through that program and the investment our 11 companies are making with the EPA, CARB at the 12 Southwest Research Institute Project. We are 13 increasingly confident that there is a fuel economyGHG 14 gas optimization bonus that can be realized by 15 integrating rapidly emerging and cost-effective NOx 16 control strategies into heavy-duty manufacturers' 17 engines and power train designs. However, without 18 clear policy signals, those NOx controls may langui sh 19 and leave significant fuel economy gains on the tab le. 20 California is seriously considering an additio nal 21 90 percent reduction in NOx emissions beyond the 20 10 22 standards for medium- and heavy-duty vehicles. Sho uldPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 292 1 California, the Ozone Transport Commission states, or 2 EPA choose to adopt such a standard, AESI members w ill 3 work with our customers to ensure that standard canbe 4 achieved and to realize the optimization bonus and make 5 fuel economy GHG targets easier to achieve. 6 And, finally, AESI supports the agencies' effo rts 7 to tighten the nitrous oxide cap to ensure that 8 efficiency enhancements made by engine manufacturer s to 9 reduce CO2 pollution do not lead to unintended 10 increases of this potent greenhouse gas. Meeting t he 11 proposed cap will be challenging, but our members a re 12 already working on the cutting-edge materials neces sary 13 to limit nitrous oxide formation. 14 Thank you for the opportunity to provide comme nts 15 today. We will supplement these remarks with 16 additional written material before the end of the 17 comment period. Thank you. 18 MR. GRUNDLER: Thank you. 19 Mr. Lacroix? 20 MR. LACROIX: Thank you. Hello. Thank you ve ry 21 much for this opportunity today. My name is Benoit 22 Lacroix. I am co-founder and VP-Sales at Effenco,Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 293 1 based in Montreal, Canada. That will explain my ac cent 2 today. 3 First, thank you very much. I am very excited 4 about being here, taking part in this experience. I am 5 both excited from a personal and professional 6 perspective. 7 So Effenco has been around for ten years now 8 working on trucks' fuel efficiency. And we current ly 9 market our Active Stop-Start Technology in heavy-du ty 10 vocational truck. In a nutshell, very quickly, it is a 11 bolt-on solution that we install on conventional 12 transmission. It allows complete transparency and an 13 automatic engine operation in traffic and stop-and- go 14 as well as on work sites operating mode. Very quic kly, 15 we use 144-volt ultra-capacitors to supply vehicle 16 accessories; power the trucks; equipment; and, of 17 course, restart the engine upon driver demand. 18 We have successful deployments in North Americ a 19 and in Europe and refuse and terminal tractor 20 applications so far. We are working on other 21 applications. And we reduce basically engine hours by 22 40-45 percent and fuel consumption by 15-30 percentonPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 294 1 the fuel measured. We just completed test sessions at 2 the VTAF laboratory at the Department of Sanitationof 3 New York City that support these performances that were 4 measured on the field. 5 So, very quickly, with comments, a) technology 6 availability and feasibility for alternative 4, whi ch I 7 strongly support. So yes, as far as Stop-Start 8 Technology is concerned, our technology is on the r oad 9 performing, delivering, performance, and payback as we 10 speak. And we are also in the process of negotiati ng 11 with OEMs here and in Europe to become a standard 12 option on their offering. 13 One thing that we do a lot also, over the last 14 years, we measured more than 10,000 -- I wish -- 1, 000 15 routes over more than 3 million miles and gathered 16 terabytes of data in real application for refuse, 17 terminal tractors, dump trucks, delivery, buses in 18 U.S., Canada, and Europe. That brings me to the 19 following comments on the proposed duty cycles and the 20 weightings for idling. 21 So, of course, duty cycle, we observed indeed 22 variations in speed profile. That is true, but onePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 295 1 thing that holds true for all vocational applicatio n is 2 that idling accounts for a very, very large proport ion 3 of the operation time. We have seen anything betwe en 4 25 and 60 percent, nothing less for sure. Sixty 5 percent, of course, is more urban utilization. I w ould 6 say that the bulk is between 40 and 50 percent of a ll 7 the data that we gathered so far. 8 So the three different duty cycles that you us ed, 9 the approach is great. I think it is a very good i dea. 10 However, of course, we strongly recommend and hope that 11 the weightings for idling for the composite test cy cles 12 would be reviewed for higher values. At least I th ink 13 it would be at least twofold. I am really glad to hear 14 that I think presently the NREL is working on that to 15 propose other numbers and to share their observatio ns. 16 I would be glad to help them. Actually, I am goingto 17 contact them. 18 Also, average speed is very much higher than what 19 we see on the field, especially for urban, the urba n 20 part of the cycles. 21 Yes. I mean, about the idea that the manufact urer 22 could request different duty cycles, I recognize itPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 296 1 would be a very big challenge to administrate, but I 2 think it is a very, very good idea given the wide r ange 3 of application for vocational truck. 4 Also, a quick note on partnership and 5 collaboration between manufacturers. Mr. Lovelace 6 addressed this very quickly earlier and I want to 7 emphasize it. Also, I believe that any sort of 8 incentive to collaborate between manufacturers coul d be 9 beneficial in achieving progress and bring better, 10 integrated, and more efficient technologies. For 11 example, it is currently very difficult for a non12 vertically chassis manufacturer specializing in 13 vocational application to deal with engine supplies who 14 can have other business to take care of. And 15 vocational so very often is a small proportion of t heir 16 business. And it helps a third, more secondary tie r 17 manufacturer, such as us, also to maybe get the 18 attention span, to include technologies. 19 And, very quickly, ABD provisions and credits, of 20 course, any credits for technology like ours will d rive 21 the adoption of advanced technologies. I don't kno w, 22 though, if phase 1 will allow this because hybrid a ndPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 297 1 stop-start, for example, were not included in the p hase 2 1. And I think there was much less idling, for 3 example, to take examples to what I do every day. So I 4 might have some concerns there. 5 And the last thing -- I think my time if off - - 6 are already provisions an impediment to adoption of 7 hybrid system? Yes. We experienced that so far inour 8 experience. So, of course, OBD didn't help so far to 9 deploy GHG reduction technologies. 10 Thank you. 11 MR. GRUNDLER: Merci. 12 Ms. Ungar, you are up. 13 MS. UNGAR: Good afternoon, ladies and gentlemen. 14 Thank you for the opportunity to testify in supportof 15 the EPA's newly proposed fuel efficiency standards for 16 medium- and heavy-duty trucks. My name is Lola Ung ar, 17 First Vice President and Action/Advocacy Director o f 18 the League of Women Voters of Los Angeles County an d 19 also a retired planning director of a nearby city. 20 Both the national, LVWUS, and state, LWVC, Lea gue 21 of Women Voters support measures to establish air 22 quality standards that will protect the public heal thPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 298 1 and welfare and the development of effective 2 enforcement and implementation procedures at each l evel 3 of government to attain these standards. 4 As we continue to learn that climate change is 5 expected to increase to dangerous ozone levels in many 6 areas and that the poorest people live within the a reas 7 closest to Los Angeles County's main port areas of Los 8 Angeles and Long Beach and along the related freewa y 9 truck routes, it is abundantly clear that unless we 10 adopt the proposed truck standards, air pollution w ill 11 worsen asthma symptoms and trigger higher rates of 12 asthma attacks among children and adults, along wit h 13 other dire impacts on the health of citizens of Los 14 Angeles County. 15 Therefore, the League of Women Voters of Los 16 Angeles County urges you to support the EPA's newly 17 proposed fuel economy and global warming emissions for 18 trucks standards for 2018 through 2029. 19 MR. GRUNDLER: Thank you very much. 20 Our last panel member is Mr. Dale. 21 MR. DALE: Thank you. 22 MR. GRUNDLER: Welcome.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 299 1 MR. DALE: Good afternoon. Thank you, ladies and 2 gentlemen. 3 I am proud to say that I am not merely an obse rver 4 on the sidelines taking notes, listening to those i n 5 ivory towers hoping to glean a bit of wisdom to sha re. 6 We are talking trucks today and now to increase the ir 7 average fleet MPG. There is no better way to do 8 exactly that than how some friends and I have been 9 doing so for a few years now. I have been driving a 10 fully electric Chevy pickup truck conversion that 11 produces zero emissions, is reliable, satisfying, a nd 12 fully capable of serving as an example of how truck 13 makers can make significant gains in the average tr uck 14 MPG you seek. And it is not just me, dozens of oth ers 15 in this area and others all over the country, frank ly. 16 Many of my friends have been doing so for years now 17 without regret. 18 My truck only has a range of perhaps 100 miles or 19 so before needing recharge. Some drivers cover mor e 20 ground in a day than I do, but there are many thous ands 21 of drivers here in this area and every other large city 22 who could reduce their fuel consumption if they onl yPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 300 1 had the option of driving a vehicle similar to mine . I 2 call it the electruck. You will see the pictures o f it 3 here, electruck. They could save significant expen ses 4 as well, but such electric and hybrid trucks have t o be 5 available for them to buy. 6 My electruck is a one-of-a-kind conversion. S o 7 auto manufacturers, Ford, Chevy, Peterbilt, Mack, 8 whoever, need to be willing to make that effort to 9 provide haulers and movers for local use. Strong 10 standards that improve efficiency by 40 percent by 2025 11 will be just the impetus they need to get serious about 12 making more efficient trucks available to all. 13 Vehicle emissions and national security would seem 14 to be totally independent matters, but they are not . 15 Every time we buy a tank of gas, we are potentially 16 funding terrorists and desperate, despotic regimes. It 17 is a cruel fact we have been addicted to the oil of 18 some very bad people, and they have been addicted t o 19 our money. We desperately need to break these 20 addictions. And it is best addressed by getting 21 serious about driving with electricity, rather than 22 fuel-burning engines.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 301 1 I have seen so many exciting signs that we have 2 reached a tipping point in EV acceptance or soon wi ll. 3 All we need to do is to not stand in the way of 4 progress and to nudge it forward in every way we mi ght, 5 including electric and hybrid trucks. 6 I have a hybrid I rarely drive anymore and ano ther 7 very popular little car that you will see in a minu te. 8 If I had found EVs to be impractical, problematical , I 9 would have stopped after my first EV conversion bef ore 10 Teslas and Leafs were available. Poll those that h ave 11 EVs. You will find very high satisfaction among owners 12 and drivers. And nearly all my friends and neighbo rs 13 are bitten with a bug to drive electric, including 14 those who presently drive trucks costing them dearl y at 15 the pump and who realize the national security aspe ct. 16 This is why they call me Electric Bill. And I am 17 wholly proud of that fact. 18 Adomani, a company in the nearby City of Orang e, 19 California, is one of several that have quietly bee n 20 converting trucks and buses to run either electrica lly 21 or as hybrids. Another is Balqon in Harbor City, who 22 has been quietly -- a third is Left Coast Electric, whoPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 302 1 has converted a wide variety of trucks and other 2 vehicles to electric. These companies you need to be 3 consulting at this point as they are already provid ing, 4 quietly providing, wonderful, powerful EVs to those 5 such as myself. I am so grateful to them to be abl e to 6 drive guilt-free. 7 I urge you to finalize the strongest standards 8 possible, not just for the sake of using less oil b ut 9 for our most precious national security. Thank you 10 sincerely. 11 Here are some of the -- this is fully electric . 12 This is a school bus that is on the road today. 13 Imagine kids not having to have the pollution as th ey 14 get into their buses. This is a fully electric tru ck. 15 That is fully electric. He drives between Corona a nd 16 Long Beach or Orange, California every day, same tr uck. 17 This is my truck here. As you can see, I haveit 18 tricked up a bit so that it really gets people's 19 attention. And as soon as they, "Wow. Wait a minu te. 20 What is going on here?" that is the hook. 21 It gives me the opportunity to say, "Oh, you c an 22 be driving electric, too. And this is how." And IPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 303 1 will simply talk to them about it. 2 This is what the battery pack looks like in my 3 truck. 4 And to finish off, here is my little electric 5 runabout. Every time I get on the freeway with thi s, 6 people just go crazy. They are coming up alongside . 7 But they will follow me off the freeway. And it gi ves 8 me the opportunity to say, "Hey, you don't want 9 anything like this. This is not practical. I can only 10 take me in this. But you can go buy a Leaf. You c an 11 go buy a Tesla," whatever. Yes. 12 These are the license plates for my vehicles: 13 ELECQUICK and ELECTRUCK. 14 MR. GRUNDLER: Thank you very much, Electric B ill, 15 for your energetic testimony. 16 (Laughter.) 17 MR. DALE: Thank you. 18 MR. GRUNDLER: Any questions for this panel? 19 (No response.) 20 MR. GRUNDLER: Thank you so much, everyone, fo r 21 your time. 22 Now I would like to invite panel 12. You havethePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 304 1 table to yourself. Welcome, Mr. Goodarzi, from U.S . 2 Hybrid. We are ready when you are, sir. 3 MR. GOODARZI: Yes, sir. Thank you very much. I 4 don't have my pictures with me. 5 Good afternoon. My name is Abas Goodarzi. I am 6 president of U.S. Hybrid Corporation. We are a sma ll 7 business located in Torrance, California, which is 8 right next to the Port of L.A. and Port of Long Bea ch. 9 U.S. Hybrid develops and produces electric and fuel 10 cell power train for medium-duty and heavy-duty 11 vehicles. 12 As a resident of Southern California, my famil y 13 and I are exposed to the high pollution caused by t he 14 trucks serving the local ports that support the 15 California and national economy. 16 I thank you for your leadership and initiativefor 17 the medium-duty and heavy-duty phase 2 regulations. 18 While I strongly support the phase 2 regulations, I 19 believe they missed the major goal of achieving a 20 stringent NOx reduction required to meet our future 21 environmental target. These rules will not drive t he 22 NOx level down low enough to improve the health ofPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 305 1 residents in nonattainment areas. 2 We urge you to further support zero-emission 3 technologies, especially fuel cell. The impact of fuel 4 cell and hydrogen is often overlooked. Recently ou r 5 fuel cell power plant running, driving an a/c trans it 6 fleet up in Oakland exceeded 20,000 hours with zero 7 stack failure, which putting the fuel cell on par w ith 8 diesel and CNG engine. 9 Combustion engine technologies have improved alot 10 and can make a major contribution to vehicle fuel 11 economy and emission for long-haul applications. 12 However, they do little for operation in congested 13 traffic. And traffic is not getting any better. 14 For decades, the industries has tried various 15 controller strategies, such as EGO and other method s. 16 And now it is all of the last couple of decades we have 17 been working on after treatments. After all of thi s 18 effort and time and time again shows that combustio n 19 engine has reached a level of technology limit thatis 20 financially prohibitive to improve. 21 As has been published and as stated by engine 22 manufacturers, the NOx reduction and fuel economyPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 306 1 improvement contradicts the engine controller strat egy. 2 In contrast, fuel cell not only provides better fue l 3 economy and the zero tailpipe emission, but also th ey 4 are not sensitive or as sensitive to drive cycles, 5 traffic congestions, and emission test method, stea dy6 state versus cycle average, et cetera. 7 Therefore, on behalf of U.S. Hybrid, I urge yo u to 8 further support zero-emission fuel cell medium9 duty/heavy-duty vehicle, especially in urban settin gs. 10 We really need this technology to achieve the 11 California target of 90 percent NOx reduction, and your 12 recommendations cannot get us there. 13 While regulation is the main driver for techno logy 14 and clean transportation, incentives are also neede d to 15 ensure that transition to a sustainable commercial 16 deployment. Thus, we urge you to establish more 17 incentive or zero and near-zero emission technologi es. 18 And this way, you can provide a path for companies that 19 work hard to develop a product that enables us to r each 20 our goal of 90 percent NOx reduction. By working 21 together, we can create jobs and clean air. 22 I thank you again for your time and thisPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 307 1 opportunity to provide testimony. 2 MR. GRUNDLER: Thank you very much. 3 Mr. Reed? 4 MR. REED: Great. Thank you for having me. 5 My name is Dr. John Reed. I am an 6 anesthesiologist and a critical care physician by 7 training. In a previous life, I worked for the Sur geon 8 General C. Everett Koop doing health risk assessmen ts 9 of different technologies, primarily biotechnology. 10 This was after I had sold my biotech company that I had 11 started as an undergraduate in Berkeley. I since went 12 on to do a few other things. And, like Mr. Curl he re, 13 I also had a commercial driver's license at one time so 14 that I can actually drive class 5 to 8 trucks. 15 So I am here. I am going to be submitting wri tten 16 testimony that I hope your staff, someone like Alan 17 Stout, will be reviewing. He is a great guy. I am 18 very impressed with his comprehensive and very 19 thoughtful comments on things that have come through 20 other dockets. 21 I am here today as the CEO of North American 22 Repower. What my company does is we take the veryPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 308 1 dirtiest heavy-duty and medium-duty diesels and 2 modernize them with modern technology so that they 3 become the lowest carbon footprint, cleanest heavy- duty 4 vehicles available in the world. 5 This technology directly addresses the legacy 6 fleet. You say, why do you address the legacy flee t? 7 Well, they asked John Dillinger, "Why do you rob 8 banks?" Well, that is where the money was. Well, this 9 is where the pollution is. This is where we can ma ke a 10 real difference. 11 You have asked very specifically about .2 vers us 12 .02 grams per horsepower hour NOx. There are 13 disclosures in place that I can't say exactly who we 14 are working with. We have the technology. We have 15 already shown it in the test cell, to our satisfact ion. 16 We can get to .02 NOx with natural gas engines withour 17 technology. Do I push for that? No. Why? Becaus e we 18 have seen where we have pushed too quickly with new 19 technologies and it has adversely affected the 20 population. 21 What I am talking about is Navistar nearly goi ng 22 under because of EGR, lots of jobs lost. I am talk ingPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 309 1 about Caterpillar leaving the on-road heavy-duty wo rld, 2 20,000 jobs lost in Peoria. 3 When I was with the surgeon general, one of th e 4 things that came to the light every time is that th e 5 number one determinant of health outcomes is 6 socioeconomic status. So the things that you decide, 7 the things that you do have other impacts. My conc ern 8 is about those other impacts. 9 You have asked specifically about the glider k its. 10 In your preamble, you say that people are going to 11 glider kits to circumvent the Clean Air Act. That is 12 not why they are doing it. Maybe you have more 13 information than I do. Maybe there is somebody 14 specifically trying to do that. I can see Mr. Curl 15 would say to you, "No. It is someone trying to fee d 16 their family and put a roof over their head and getthe 17 best darn truck that they can get with the capital 18 access that they have." The independent owner19 operators that are out there, they know that takingthe 20 engine transmission and differential that they alre ady 21 have and use and they maintain primarily themselves , if 22 they can put that into a new chassis, they have gotaPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 310 1 more aerodynamic truck. They have got a safer truc k. 2 And they can continue to provide for their families . 3 So I am just going to say throw these folks a 4 bone. When you are going and saying that they haveto 5 be current-year emissions standard, you are elimina ting 6 that program. It disappears because no OEM 7 manufacturer is going to support retrofitting a bra nd 8 new engine into a new chassis with a used transmiss ion 9 and used differential. 10 So how about we go about what President Obama has 11 pushed and put forward and I worked with the folks at 12 OTAQ to create, which are the alternative fuel 13 conversion regulations? Why not allow folks to have a 14 glider kit if they go to 100 percent alternative fu el 15 use? I think that sends the right message. It 16 addresses the folks who would love to participate i n 17 bringing down our emissions but they can't afford t o. 18 They don't have the access to capital. They can't 19 issue a bond, issue a corporate bond, like UPS. Th ey 20 can't do it. So give those folks the benefit of th e 21 doubt. Give them opportunities. 22 Along those opportunities, let's talk about th ePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 311 1 legacy fleet. Here in California, Erik White and Mary 2 Nichols took a very bold step and said: If you have 3 got an old dirty diesel, the clock is ticking, and you 4 are going to have to get rid of it. Well, Californ ia 5 has the luxury of being able to push those trucks i nto 6 the other 49 states. EPA doesn't have that luxury. 7 Somehow I don't think Canada and Mexico can absorb, you 8 know, 17 million heavy-duty and medium-duty trucks. It 9 is not going to happen. Besides, we don't want to move 10 our pollution. We want to eliminate it. 11 But EPA needs to look at, how do we involve th e 12 fleet owners? What lessons can we learn from the t ruck 13 and bus regulations that California has put in plac e so 14 that we make all of these regulations we are talkin g 15 about effect the end-user directly so they particip ate 16 and have a stake in this? Because right now, the w ay 17 the regulations work, you can keep on remanning and 18 rebuilding your old diesel and keep it along just a s 19 long as you want to. All right? That is not reall y a 20 bad thing for these guys because, you know what, di esel 21 engine remanufacturing creates jobs in the United 22 States. It is what Caterpillar does more of thanPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 312 1 anything else. It is what SRC, the largest employe e2 owned company in the world. 3 So I am asking you to look at what CARB has do ne. 4 What lessons can we learn there? How can we create 5 credits for companies that take and modernize faste r? 6 How can we credit those folks that move to alternat ive 7 fuels? 8 The idea is to get greenhouse gas changes now, to 9 get PM changes now. We provide that technology right 10 now, not just for trucks but for APUs and for TRUs. So 11 all of those trailers you are talking about right n ow 12 that run refrigerated regional routes, they could a ll 13 be running on natural gas, renewable natural gas. How 14 do you credit a fleet who says, "You know what? I 15 could buy regular old CNG, but, instead, I am goingto 16 buy RNG. It is more expensive. But it actually br ings 17 down our carbon footprint"? It really does make --it 18 takes the impact that human activity has and turns it 19 into a fuel. How do you credit those people? How do 20 you incentivize them? 21 I think you have the opportunity to do that. You 22 have the power to do it. I think you have thePublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 313 1 directive from the President to do it. 2 So I am going to be submitting much more detai led 3 comments as I get through the 600 pages of the hard 4 work you have all done. And I appreciate that hard 5 work that you have all done. We have a lot of hard 6 work ahead of us. 7 Putting the onus completely on the manufacture rs, 8 well, like you said, there is the good and there is the 9 bad of that. We run the risk of putting technologyout 10 in the field that isn't ready. And the person who 11 bears the cost of that is the end-user. So we needto 12 protect those folks because those are Americans. 13 Thank you. 14 MR. GRUNDLER: Thank you very much. 15 Mr. Rabin, welcome. 16 MR. RABIN: Good afternoon. I am Jeff Rabin. I 17 am a 27-year resident of the City of Long Beach. I am 18 a longtime, now former Los Angeles Times transporta tion 19 reporter, who found himself becoming an endangered 20 species as a print journalist and went back to scho ol 21 recently and got a Master's degree in urban plannin g 22 and environmental policy from UCLA, where I work. I amPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 314 1 working on greenhouse gas reduction measures in 2 California. 3 As you know, California has the nation's only 4 economy-wide cap and trade system. And it is fitti ng 5 that you are sitting today in California because to day 6 is California's quarterly auction of carbon allowan ces. 7 We have an international carbon market now. We have 8 the Province of Quebec in our North American carbon 9 market. And for three hours today, we were trading 10 emission allowances in North America. 11 The byproduct of that has been on January 1st of 12 this year, California extended the cap on emissions to 13 transportation fuels, including gasoline, including 14 diesel fuel, including propane, including natural g as, 15 for transportation purposes. This is a critically 16 important step in California because California, 37 17 percent of our greenhouse gas emissions come from o ur 18 transportation sector, much more than the national 19 average, because our electricity is greener in 20 California. We don't burn coal in California. 21 So our cap and trade system is now producing o ver 22 $2 billion a year for the State of California toPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 315 1 reinvest in further strategies that reduce greenhou se 2 gas emissions. And the California Air Resources Bo ard 3 is anticipating receiving $350 million in the curre nt 4 fiscal year that began July 1st for its light-duty, 5 medium-duty, and heavy-duty programs to further reduce 6 GHG emissions from vehicles in California. This 7 includes heavy-duty trucks. 8 And you are at the epicenter of the efforts to 9 reduce GHG emissions because the Ports of L.A. and Long 10 Beach are the source for over 40 percent of everyth ing 11 imported into the United States in a cargo containe r. 12 So you couldn't pick a better place to be today to be 13 discussing this topic. And we appreciate you comin g to 14 hear us. 15 I want to focus on the issue of fuel economy i n 16 heavy-duty trucks. And the hew and cry by the indu stry 17 that it can't be done without causing a great 18 dislocation reminds me of the decades of hew and cr y 19 from Detroit that we can't tighten the emissions 20 controls on internal combustion engines. Of course , it 21 was California under the Clean Air Act that was dri ving 22 the emission reductions to address our very severe airPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 316 1 quality problems. 2 You are also sitting in one of the two extreme 3 nonattainment areas in the United States for ozone, the 4 other being the San Joaquin Valley, central valley, of 5 California. 6 So in order to address the twin problems of ai r 7 quality and micro fine particulate emissions, we have 8 to address diesel trucks. We have to address diese l 9 trains. We have to address ships. We have to addr ess 10 those portions of the transportation industry, 11 particularly the global goods movement industry tha t is 12 leaving a toxic trail across California that is 13 creating environmental justice issues in low-income 14 communities, predominantly minority communities, al ong 15 our goods movement trade corridors to the east and to 16 the north. 17 So back to our cap and trade system. You are 18 sitting in the very center of some of the most 19 progressive efforts to address emissions from diese l 20 trucks in the entire United States with the Ports o f 21 L.A. and Long Beach and their clean truck programs, 22 which have been significantly beneficial to this ar eaPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 317 1 in terms of reduction of micro fine particulates. 2 Now, my wife grew up in Southern California inthe 3 smog siege of the '60s. She has asthma. Many chil dren 4 in this Community of Long Beach have asthma. It is the 5 number one source of hospital admissions in this en tire 6 area. 7 Miller's Children's Hospital has a fundraising 8 benefit that is a bicycle ride every year to raise 9 funds for their services to low-income people whose 10 kids need to be able to breathe. 11 So the Air Resources Board of California has a 12 number of pilot projects that are being funded by o ur 13 cap and trade system. One is the hybrid and zero14 emission truck and bus voucher incentive program, which 15 provides the equivalent of a purchased voucher to b uy a 16 cleaner truck. This is designed to incentivize 17 manufacturers to produce cleaner vehicles. The 18 incentives can be up to as much as $110,000 per tru ck. 19 It is a hybrid program, much like California's clea n 20 vehicle rebate project, which incentivizes Californ ians 21 to buy electric vehicles. 22 We have in California invested over $200 milli onPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 318 1 in rebates to people who buy electric vehicles and 2 plug-in hybrid electric vehicles or fuel cell vehic les. 3 We have 120,000 such vehicles on the road after a 4 4-year program in this state. We believe there are 5 150,000 vehicles, electric vehicles, registered. 6 Come back to your principal issue. Yes. Anyt hing 7 that can be done at the federal level to reduce the 8 emissions from diesel trucks by increasing their fu el 9 efficiency, much as the CAFE standards have been se t 10 for cars and light-duty vehicles. The car standard s, 11 the CAFE standards, were fought tooth and nail, but 12 California is making progress and the U.S. is makin g 13 progress in dramatically improving the fuel efficie ncy 14 of the auto fleet with the very ambitious target by 15 2025. 16 EPA should act in the interest of both public 17 health, national security, and reducing our importe d 18 oil consumption and to create a more healthful 19 environmentally and produce less greenhouse gas. I t 20 can be done, but it requires leadership. It is not 21 going to come from the industry by itself. 22 I would encourage you to look closely atPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 319 1 California's model. California is making significa nt 2 progress and will reduce its greenhouse gas emissio ns 3 by 10 percent by 2020 to the same level as 1990, 4 despite the addition of 6 million more people and 9 5 million more vehicles. 6 MR. GRUNDLER: Thank you very much, sir. 7 Any questions for our final panel? 8 MR. SILVERMAN: Just one question to Dr. Reed. We 9 will certainly read your written comments with 10 interest. Remember that we are creatures of statut e. 11 We can only do what the Clean Air Act allows. And that 12 has no authority over existing mobile sources. So 13 please take that into account. 14 MR. CHARMLEY: I also had one question for Dr. 15 Reed. You said that one of the things that your fi rm 16 does is repower engines that can be used in glider 17 kits. And so the proposal, what we have proposed t o 18 do, is require that beginning in 2018, that glider kit 19 engines would meet the most recent emissions standa rds, 20 so like the 2010 standards, as well as the model ye ar 21 greenhouse gas. 22 Your suggestion was that we should considerPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 320 1 allowing CNG conversion kits to be used. And I wou ld 2 suspect that, if done properly, a CNG-converted eng ine 3 probably would meet the 2010 emission standards and , in 4 all likelihood, could meet the current model year 5 greenhouse gas standards. Is that also sort of you r 6 assumption that a -- is that why you are suggestinga 7 CNG glider kit should be allowed, because it could 8 actually meet the current standards that we had 9 proposed? 10 MR. REED: No. Actually, what I am suggestingis 11 that we can have a large incremental improvement, b oth 12 in NOx, PM, and in greenhouse gases, and at a price 13 point that is affordable so that there is actual 14 adoption. 15 If we have got a 2010 standard and it starts i n 16 2018, if it is a current model year standard, then you 17 have got all the OBD as well. You have got a lot t hat 18 falls into place there. It puts a huge burden on b oth 19 the person who is doing the conversion and on the f leet 20 owner. And you are not going to have adoption. You 21 will have killed that program. And you will have n o 22 alternative for the folks who don't have large capi talPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 321 1 to try and participate in bringing down our greenho use 2 gases. 3 What I am suggesting is that technology exists for 4 us to make an improvement now. And it is maybe not 5 ideal. And yes, there is still development to be done. 6 The technology that we are working on to get down t o 7 .02 grams NOx doesn't work for diesels, absolutely 8 won't, not applicable. So I could push for an 9 advantage here, but I don't think that is really wh at 10 we are looking at. I think what we are looking at is 11 trying to make a significant improvement today. Th at 12 is what everyone up here asked for. That is what t he 13 EDF asked for. 14 You know, I guess one of the more specific thi ngs 15 I can talk about is TRUs and APUs. We can take tho se 16 engines right now that put seven to eight grams of NOx 17 per horsepower hour out right now, and they put out 18 horrible PM. And yes, you could put a DPF on it. It 19 does nothing for NOx. It does nothing for greenhou se 20 gases. For the cost of that DPF installation, we c an 21 convert that to run on natural gas. It doesn't acc ount 22 for the cost of the tanks. That is the biggest pri ce.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 322 1 But if you are already running a natural gas tracto r, 2 now you can run a natural gas TRU and you can bring 3 down your total greenhouse gas. 4 So I am thinking maybe off-cycle stuff. Maybewe 5 will be allowed to use TRUs and APUs that are now 6 natural gas. And, you know, memo 1-A guides us the re 7 because there are no alternative fuel conversion 8 regulations for non-road. So, you know, are we wil ling 9 to take the chance? Yes, my company is. 10 We were EPA-compliant over a year and a half a go 11 with our first engines. Have we sold a single one? 12 No. Why? Because we haven't marked a single one 13 because until I have 485,000 miles on a unit and itis 14 trouble-free, I am not going to put that in somebody's 15 unit, not going to do it. My investor won't let medo 16 it. 17 I am very fortunate that I have got a great te am. 18 I have got folks from McLaren. I have got folks fr om 19 Ferrari. I have got the ex-head of global engineer ing 20 for GM. All of these people came out of retirement 21 because they want to see this happen now. 22 I am not making any money off of this. Neithe rPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 323 1 are my investors. But hopefully we can make this 2 sustainable. Hopefully we can keep this alive. 3 You know, Don Feitz talked to me. One time I 4 asked him. "Don, what about Caterpillar and natura l 5 gas on-road engines?" 6 He said, "John, Cat makes diesels. End of sto ry." 7 Well, Cat doesn't make on-road diesels anymore. So 8 think about your actions. Think about what you are 9 really asking people to do. And let's look at whatis 10 actually possible. 11 One of the things you have is .1 grams for met hane 12 emissions right now. There is no catalyst manufact urer 13 out there that will tell us that we can get there. As 14 a matter of fact, they look at us and go, "We are n ot 15 even going to invest in it. It is such a low numbe r. 16 And there is such a small market that we are not 17 willing to put the money up to try and get you a 18 methane-specific catalyst that is going to get you from 19 .5 down to .1. It is not going to happen." So, 20 instead, you have got to use up credits and do math . 21 Well, I don't think that is really what we want to do. 22 What we really want to do is get it down to .1.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 324 1 So I ask that, instead, maybe you look at thos e 2 numbers, put out a realistic number because that is 3 what you say you are doing. You are saying you are 4 using proven technology to get there. 5 You know, the bottom line is if you got 40 per cent 6 reduction, 40 percent improvement in fuel economy, you 7 wouldn't need these regulations. Every truck ownerin 8 the world would say, "Sign me up right now. That i s my 9 number one cost of operation." If I can knock 40 10 percent off, this thing pays for itself. What happ ens 11 when it doesn't? Who pays that guy for his investment 12 that didn't turn out? How are you going to prove t o 13 this person up front that, yes, you are actually go ing 14 to realize that? 15 The bottom line is, with all the bad things th at 16 have happened, with all of the people who have been 17 early adopters and gotten burned, you are going to have 18 a hard sell. And so what is going to happen is people 19 are going to hang onto their legacy trucks, and we are 20 going to continue to spew out at five and six grams NOx 21 heavy PM. That is what is going to happen. Peopleare 22 going to keep these things alive.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 325 1 You say you don't have the authority on outside 2 useful life. What is useful life? The average ageof 3 a heavy-duty truck in the United States is almost 2 0 4 years of age. That is registered. That is Polk da ta. 5 That is real data. So what are we going to do to s hift 6 that? I think you have the opportunity. 7 MR. CHARMLEY: Thank you. 8 MR. GRUNDLER: Thank you very much, panel. At 9 this point, we will pause this hearing and see if a ny 10 other citizens or other testifiers show up. So tha nk 11 you very much for your time. 12 (Recess taken.) 13 MR. GRUNDLER: Mr. Litvak, you may take a seat 14 here at the table in front of a microphone. Welcome. 15 Proceed when you are ready. 16 MR. LITVAK: Thank you. 17 My name is Lawrence Litvak. And I live in Mil l 18 Valley, California. I am here today to testify as a 19 private citizen. For the past 11 years, I have bee n 20 teaching as a lecturer at Stanford in public policyin 21 urban studies. And prior to that, I had a career i n 22 business, government, and the nonprofit sector. Al so,Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 326 1 I have a Master's degree in public policy from the 2 Kennedy School and a B.A. in economics. 3 And let me digress briefly just to apologize f or 4 my lateness, but the plane was delayed for two hour s 5 from San Francisco. 6 MR. GRUNDLER: No apology necessary. 7 MR. LITVAK: I am glad that I was able to makeit 8 in. 9 I am primarily going to be testifying today fr om 10 the point of view of someone whose community is 11 threatened by climate change, and I am also going t o be 12 encouraging you to support strengthening the phase 2 13 standards. But before I kind of get into my direct 14 personal testimony, I just want to make a brief comment 15 from a perspective as someone who teaches public 16 policy. I think that good policy-making is explici t 17 about its values and evaluative criteria, considers 18 alternative approaches to the problem, and relies 19 strongly on evidence as a basis for making its 20 recommendations. 21 So I have reviewed your notice of proposed 22 rulemaking and several of the accompanying document s.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 327 1 And I think that the process that you are followingin 2 developing the phase 2 truck standards meets those 3 principles of good policy analysis. And I would be 4 very comfortable in holding it out as an example of 5 good policy-making process to the students that I 6 teach. 7 More generally, I think that the history of fu el 8 efficiency standards has been a solid example of 9 government successfully intervening to enhance the 10 general welfare. So I think you are continuing in that 11 vein. 12 Now to turn to my observations as someone whos e 13 community is threatened by the effects of climate 14 change, I live just north of San Francisco; and 15 already we are experiencing the predicted drier 16 conditions that are supposed to even intensify as t he 17 decades progress and specifically dairy farmers in our 18 county. Much of the western part of Marin County i s 19 dairy farmers. And they are already suffering from 20 reduced grazing. And the grape growers that we have to 21 the north are already facing water shortages. So i t is 22 something that we are experiencing today.Public Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 328 1 Also, I live only one mile from San Francisco Bay, 2 from the edge of the bay. And I am personally luck y 3 because my house is 170 feet above sea level, even 4 though it is only a mile away. But in our town, mi les 5 of roads, thousands of homes, and many schools, 6 including the ones where my children went to primar y 7 school, middle school, and high school, are very cl ose 8 to sea level. And depending on how high carbon levels 9 go and how high sea level goes, the sea level goes, as 10 a result, these will have to be protected by dikes, 11 moved, or abandoned. So whether measures like the 12 phase 2 truck standards are set aggressively will h ave 13 an impact on the community that I live in. 14 Across the bay from where I live is Richmond, 15 California, which is a largely low-income community 16 that is home to a lot of industry that is serviced by 17 heavy-duty trucks, including a very large Chevron o il 18 refinery. So for that community, these standards a re 19 also important because they will reduce the health risk 20 that they face in Richmond by reducing toxic air 21 pollution from idling trucks and from oil refinerie s. 22 So because there is so much at stake, I think thatPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 329 1 your two agencies need to take full advantage of th e 2 feasible and cost-effective approaches to reducing 3 emissions. And based on my reading of the proposed 4 rulemaking, I want to urge you to go beyond the cur rent 5 proposal for phase 2 to adopt the standard recommen ded 6 by the Union of Concerned Scientists, which is very 7 similar to what you show as alternative 4 in your 8 proposal. 9 And I think, importantly, that adopting their 10 proposals will result in a 40 percent savings, 40 11 percent by 2025, so that by 2035, it will avoid an 12 additional 40 million metric tons of global warming 13 emissions annually, the equivalent to shutting down12 14 coal-fired power plants. 15 Thank you for the opportunity to testify today . 16 And I encourage you to strengthen the proposed 17 standard. Thank you very much. 18 MR. GRUNDLER: Thank you, Professor. And than k 19 you for traveling all the way down from San Francis co 20 to share your thoughts. 21 Any questions for Mr. Litvak? 22 MR. CHARMLEY: So does that mean that we wouldPublic Hearing August 18, 2015 Long Beach, CA

1-800-FOR-DEPO Alderson Reporting Company Page 330 1 receive full credit for your class at Stanford? I am a 2 Michigan grad, but I wouldn't mind getting another four 3 credits in public policy. 4 MR. LITVAK: Yes, yes. I could say with 5 confidence that if you were a project -- one of the 6 classes I teach is called the senior practicum. Th e 7 students in teams of four do a consulting project f or 8 an outside government or nonprofit client. So if t his 9 were a project for that class, it would definitely -- 10 actually probably get an A+. 11 MR. CHARMLEY: I am going to pass that on to a ll 12 of the EPA and NHTSA staff back in Ann Arbor and D. C. 13 Thank you. 14 MR. LITVAK: Okay. 15 MR. GRUNDLER: I think, on that note, we will 16 adjourn. 17 MR. LITVAK: Okay. 18 MR. GRUNDLER: Thank you so much. 19 MR. LITVAK: Thank you very much. 20 MR. GRUNDLER: Thank you very much. 21 (Whereupon, at 4:43 p.m., the hearing was 22 adjourned.)CERTlFlCATE

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