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1 ENVIRONMENTAL PROTECTION AGENCY and 

2 NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

3 NATIONAL PUBLIC HEARING ON GREENHOUSE GAS EMISSIONS AND 

4 FUEL EFFICIENCY STANDARDS FOR MEDIUM- AND HEAVY-DUTY 

5 ENGINES AND VEHICLES - PHASE 2 

6

7

8

9

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11 Tuesday, August 18, 2015 

12 9:04 a.m. 

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18 Westin Hotel, Long Beach 

19 333 East Ocean Boulevard 

20 Salon C and D 

21 Long Beach, California 

22 
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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 Management 

19 District 

20 BEN SHARPE, International Council of Clean 

21 Transportation 

22 MIKE O'CONNELL, PepsiCo 
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1 PARTICIPANTS (CONTINUED) 

2 PANEL 3 (CONTINUED): 

3 BRIAN MORMINO, Cummins, Inc. 

4 HENRY HOGO, NACAA 

5 NICK JILES, Office of California Senator Ricardo Lara 

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 KIEFFER, 

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 Scientists 
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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 California 

9

10 PANEL 7: 

11 BILL VAN AMBURG, CALSTART 

12 CYNTHIA WILLIAMS, Ford Motor Company 

13 MICHELLE KINMAN, Environment California Research and 

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 Association 

21 JOSHUA GOLDMAN, TransPower 

22 TILDEN CURL, Tecco Trucking, Inc. 
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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 Cleaner 

14 Freight Coalition 

15 PAUL McNAMARA, Utility Trailer Manufacturing Company 

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 America 
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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 

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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

22
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1 PARTICIPANTS (CONTINUED) 

2 PANEL 12: 

3 ABAS GOODARZI, U.S. Hybrid Corporation 

4 JOHN REED, North American Repower 

5 JEFFREY RABIN, Citizen 

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7 PANEL 13: 

8 LAWRENCE LITVAK, Citizen 

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1 P R O C E E D I N G S 

2 MS. ZIMPFER: Good morning. Thank you very much 

3 for being here. My name is Amy Zimpfer. I am an 

4 associate director of the U.S. Environmental Protection 

5 Agency's Southwest region, region 9. And I have 

6 responsibilities for clean energy and climate change. 

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 and 

11 fuel efficiency standards for medium- and heavy-duty 

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 and 

21 the Department of Transportation's National Highway

22 Traffic Safety Administration's joint program to 
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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 opportunity to 

4 spur the development and deployment of cost-effective 

5 technologies that will help to reduce heavy-duty on6 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 joined us 

13 from Washington, D.C. to hear your comments firsthand. 

14 Mr. Grundler is the director of the U.S. EPA's Office 

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 introductory 

20 remarks. Thank you. 

21 MR. GRUNDLER: Thank you very much, Amy. 

22 We are delighted to be here in Long Beach. Let me 
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1 add my welcome. We are thrilled that so many people 

2 from very different organizations and citizens have

3 taken time today to come, tell us what they think of 

4 our proposal. 

5 Chairing these public hearings is I consider one 

6 of the most important parts of my job. It is an honor 

7 to do these hearings and to hear directly from people 

8 what they think of decisions that their government is 

9 making. So this is a very important responsibility and 

10 very humbling responsibility. We are here to listen, 

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 proposed 

17 under the Energy Independence and Security Act, is an 

18 important part of the President's kind of action plan 

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 build 

22 a single fleet that complies with both standards. For 
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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 this 

9 proposal are substantial. The standards, as proposed, 

10 would cut greenhouse gas emissions by a billion metric 

11 tons, conserve up to 1.8 billion barrels of oil, and 

12 save vehicle owners fuel costs of about $170 billion 

13 over the lifetime of the vehicles sold. 

14 This proposal will also represent an opportunity 

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 State 

22 of California's Air Resources Board from day one in
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1 developing the proposed standards. 

2 This second phase of our program is designed to 

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 decade. 

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 final 

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 of our 

16 transportation sector. 

17 Today's hearing is being held to allow interested 

18 parties to provide us with comments on this proposal in 

19 person. There is also an opportunity for anyone to

20 send us written comments. And we encouraged you to do 

21 so. The written comment period will close September 

22 17th. To find out how to submit these written 
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1 comments, you should go to our websites. And copies of 

2 those instructions are also available outside at the 

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 Division, 

9 sitting to my left; Steve Silverman from our Office of 

10 General Counsel and sitting next to Amy; Amy, who has 

11 introduced herself, from our Air Division in San 

12 Francisco. Representing the Department of 

13 Transportation is Kristin Amerling, the Deputy General 

14 Counsel; Ryan Posten, the Associate Administrator for 

15 Rulemaking, at the end of the table; and Ryan Hagen, 

16 sitting next to Ryan, from NHTSA's Office of the Chief 

17 Counsel. 

18 We will be conducting this hearing informally, and 

19 formal rules of evidence do not apply. The presiding 

20 officers, however, are authorized to strike statements 

21 from the record that are deemed irrelevant or 

22 needlessly repetitious and to enforce reasonable limits 
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1 on the duration of the statement of any witness. 

2 Today's hearing is scheduled to run until about 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 will 

5 be using panels to speed up the process. The list of 

6 preregistered panel members and their order is provided 

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 testify has 

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 through 

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, please 

22 submit those corrections to EPA or NHTSA within 30 
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1 days. 

2 I have one final announcement before turning it 

3 over to my colleague from DOT. We would like to 

4 provide additional notice regarding a proposed change 

5 to the engine testing regulations in 40 CFR 1036.501(g) 

6 that would require the exclusion of any work performed 

7 by the engine during any idle portion of the duty cycle 

8 when calculating total engine work. This proposed 

9 change was included in the proposed regulatory text but 

10 not highlighted in the preamble. This change has the 

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 change to 

15 the numerical stringency of the gasoline engine 

16 standard. So to ensure that commenters have adequate 

17 opportunity to comment on this issue, we are placing 

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 provide 
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1 comments on the change along with other comments on the 

2 rule. 

3 At this time, I would like to ask Ms. Amerling to 

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, the 

8 National Highway Traffic Safety Administration, or 

9 NHTSA, I want to thank you for taking the time today 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 August 6 

13 in Chicago, where we heard from dozens of commenters. 

14 And we welcome continued public input today and 

15 throughout the comment period. 

16 NHTSA and the Department of Transportation, we are 

17 proud to work with our partners at EPA to develop a

18 joint proposal for the second phase of greenhouse gas 

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 proposed 

22 phase 2 fuel efficiency and greenhouse gas emissions 
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1 standards would cover model years 2021 through 2027 and 

2 beyond and apply to semi trucks, large pickup trucks 

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 would 

6 start in model year 2018 while NHTSA trailer standards 

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 payback 

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 draft 

19 environmental impact statement for the proposed NHTSA 

20 fuel efficiency regulations. The draft EIS compares 

21 the environmental impacts of the proposed fuel 

22 efficiency regulations with those of a number of 
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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 impact 

8 statement will close on August 31st. Feedback from

9 stakeholders and the public helps us best craft a final 

10 program for the country. Your input is important to 

11 us, and we look forward to hearing what you have to

12 say. 

13 A few procedural notes before we call the first 

14 panel. I would like to ask that each panelist please 

15 state his or her name and affiliation and please speak 

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 are 

20 asking commenters to limit comments to five minutes so 

21 that everyone has the opportunity to speak. The green 

22 light will turn on when you begin your testimony. The 
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1 yellow light will come on at four minutes. And the red 

2 light will turn on after five minutes. 

3 To get people smoothly to the front table during 

4 panel changes, we have arranged a staging area for the 

5 second panel after announcing the first panel, we will 

6 invite the second panelists to come over to the staging 

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 welcome 

11 our first speaker: the Honorable Mary Nichols, chair 

12 of the California Air Resources Board and distinguished 

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 want 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 appreciate 

22 the opportunity to present California's input on the 
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1 proposed phase 2 greenhouse gas rules for medium and 

2 heavy-duty vehicles. As you know, ARB staff 

3 coordinated closely with both EPA and NHTSA for nearly 

4 two years to help develop the technical analyses that 

5 inform this proposal. We have much appreciated these 

6 opportunities to work with our federal agency partners 

7 to establish strong national standards to drive down 

8 greenhouse gas emissions and position the United States 

9 at the forefront of efforts to address global climate 

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 and 

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 evaluating 

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 through a 

22 deep technical dive. And we will be submitting more 
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1 comprehensive final comments by the mid September 

2 deadline. So my comments here today are based on our 

3 assessment to date. 

4 First of all, California commends the significant 

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 opportunities 

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 global 

14 leadership in addressing climate change with the 

15 announcement of the clean power plan. My hope is that 

16 the phase 2 standards can be strengthened as the final 

17 rule is put forward to stand as another shining example 

18 of U.S. leadership in the fight against climate change. 

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 emissions 

22 standard should be strengthened or accelerated. First, 
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1 we think you should adopt alternative 4 in order to

2 deliver carbon dioxide reductions earlier. California 

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 fuel7 efficient technologies, alternative 4 accelerates full 

8 program phase-in by 3 years, from 2027 to 2024. With 

9 an earlier phase-in of the final standards, the program 

10 will deliver emissions reductions sooner and will 

11 accelerate the development of carbon-reducing 

12 technologies, including moving us more rapidly towards 

13 zero-emissions technologies that will be needed to meet 

14 mid- and long-term climate targets. In addition, an 

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 10 
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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 benefit by 

5 2030 than alternative 3. And phase 1 and phase 2 

6 together would reduce petroleum use from the medium and 

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 on to 

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 corresponding 

22 increase in the whole vehicle standards to levels that 
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1 capitalize on the full emissions reduction potential of 

2 efficiency-improving technologies. Recent work by the 

3 Southwest Research Institute and others, including 

4 Cummins, the largest manufacturer of heavy-duty truck 

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 because I 

13 can see I am taking longer than I probably should. 

14 So our third main point is we would like for you 

15 to include a greater reliance on advanced technologies, 

16 like fuel cells and electric vehicles. Deployment of 

17 low and zero-emission and other advanced technologies 

18 is the foundation of California's pathway to achieving 

19 our climate and air quality goals. And we believe it 

20 should be a part of the national strategy to meet mid 

21 and long-term greenhouse gas reduction targets. 

22 Unfortunately, the phase 2 proposal is not sufficiently 
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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 or 

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 significant 

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 levels. 

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 engines 

22 and vehicles. 
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1 So I am just going to close by saying that 

2 California is fully committed to working with you to 

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 effective 

7 as possible at rapidly slashing climate pollution in 

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 is 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 greenhouse 

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 elements 

17 as we look to the future. 

18 So, once again, thank you very much for your work. 

19 We look forward to continuing this effort. And I will 

20 be happy to answer any questions if you have any. 

21 MR. GRUNDLER: Thank you so much, Chairwoman 

22 Nichols. 
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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 those 

5 technologies in this timeframe? 

6 MS. NICHOLS: We do believe that you have 

7 overlooked the opportunity to recognize the advances 

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 comments 

12 can pin down how that is feasible. 

13 MS. NICHOLS: We will further address this more 

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 noted 

18 in your testimony the work going on at Southwest on the 

19 low NOx engine technology. If the technical staff 

20 could provide the results of that work to date as part 

21 of the comments, that would be very useful for us in 

22 considering further action on NOx. 
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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 the 

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 going to 

22 be here until everybody is heard from. That is 
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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 truck 

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 of the 

8 state, federal, county agencies to reduce the emissions 

9 because whatever happens here at the ports or anywhere 

10 in California creates an environment sometimes that is 

11 hazardous to elderly and to children and those who have 

12 health problems. Sometimes I think I am included in 

13 that. 

14 But I want to be sure that I let you know that I 

15 have been on this issue with truck emissions back since 

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 critically in 

21 mind. I will work with my colleagues. I will work

22 with all of the agencies that I need to. But I would 
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1 like to make a couple of comments in listening to your 

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 by 40 

6 percent by the year 2025. 

7 You know, we in Washington have fought the idea 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 are 

11 going to have to continue to address. And one of them, 

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 findings 

15 that researchers have done? 

16 And one of the concerns that I have had in water, 

17 which is my other big issue, is, how are we not opening 

18 the door for information that will help us maybe look 

19 at new technology? And how do we help those that are 

20 unable financially to be able to convert or to purchase 

21 the new trucks? When I visited a truck company in my 

22 district, it was about a $40,000 difference in the 
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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 do it? 

4 So there are other areas that we need to actually be 

5 more -- how would I say? -- verbal on so that people 

6 understand we are just not trying to put in new regs 

7 but also that we are trying to help them achieve the 

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 be 

11 through September -- that we will continue to address, 

12 my colleagues in other states that sometimes look to 

13 California. California has been the leader for many, 

14 many years. And we want to continue to ensure that we 

15 help other states understand that it is their problem, 

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 is a 

20 partnership that we must enter into totally and that we 

21 are able to recognize what that means to the air we

22 breathe and the environment that we all live in and
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1 what our future for our children, our grandchildren, 

2 our great-grandchildren -- I already have five -- is, 

3 what are we leaving for them. 

4 So, with that, I look forward to maybe connecting 

5 a little later with you and finding out what some of 

6 these comments have brought forth and how we can help 

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. But I 

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, Congresswoman. 

17 And thank you for your time and reminding us why we are 

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 to 
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1 the stage. Panel 3 is comprised of the Honorable Dr. 

2 Barry Wallerstein from the South Coast Air Quality 

3 Management District, the executive officer; from the 

4 International Council of Clean Transportation, Ben 

5 Sharpe; from PepsiCo, Mike O'Connell; Brian Mormino

6 from Cummins; Henry Hogo, who is representing NACAA in 

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 Southern 

14 Californians, about 5 percent of all Americans, or if 

15 you took our geographic area and you ranked it with the 

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 worst 

19 air pollution problems, especially relative to ozone or 

20 summertime smog and particulates. Our district, for 

21 example, has already exceeded the current federal ozone 

22 standard 59 days this year. And by the time our smog 
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1 season ends, it will probably be 90 to 100 days. 

2 It is well-established that climate change will 

3 cause immense environmental and public health impacts. 

4 And we applaud the administration for pursuing a 

5 variety of initiatives to help address greenhouse gas 

6 emissions. But it is also well-established that 

7 climate change would actually exacerbate, make worse, 

8 our local air quality problems, such as surface-level 

9 ozone and particulate. 

10 Therefore, looking at the whole of what you are 

11 doing here in this rulemaking, we are very supportive 

12 of the effort to establish new phase 2 greenhouse gas 

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 noted, 

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 comments 

22 of NACAA and the California Air Resources Board. In 
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1 essence, our agency is in complete technical agreement 

2 that the package can be strengthened in its final form 

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. And 

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 point 

9 that Chairman Nichols made -- it is very important to 

10 note that this rulemaking missed a major opportunity to 

11 help with clean air in Southern California and 

12 elsewhere around the nation, specifically establishing 

13 a formal tightening of the federal heavy-duty engine 

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, as 

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 in the 

21 region and that technology exists today that would 

22 allow a tightening of the standard. And, frankly, as 
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1 we all meet here today, there are improvements being 

2 made to that technology that we believe would allow EPA 

3 to establish a standard at least at the near zero4 emission level of 0.02 grams per brake horsepower hour. 

5 Given that the greater Los Angeles area must 

6 reduce NOx emissions by more than 50 percent beyond all 

7 federal, state, and local regulations within the next 7 

8 to 8 years to meet several federal clean air standards, 

9 we think it is an absolute must that EPA do its fair 

10 share of this effort if attainment is to be achieved. 

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 also 

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-duty 

18 truck NOx standard and that EPA commit to such action 

19 in the final regulatory package for this proceeding. 

20 Such action will help save literally thousands of lives 

21 annually in the South Coast district and will save 

22 thousands of lives elsewhere in the nation. It would 
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1 also give Southern California a chance at compliance 

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 today 

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 the 

10 opportunity to provide remarks on this very important 

11 rulemaking. 

12 I am Ben Sharpe with the International Council on 

13 Clean Transportation. We are a research organization 

14 that is focused on providing technical information to 

15 support government decision-making on policies, write 

16 these phase 2 regulations for leading vehicle markets 

17 around the globe. I will make brief comments for the 

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 all 
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1 available cost-effective technologies. There are 

2 substantial market barriers that impede the uptake of 

3 efficiency technology. And this regulation would help 

4 solve such problems. 

5 Regarding the agency's analysis on available and 

6 emergency efficiency technologies, we continue to be 

7 very grateful for the extensive information sharing and 

8 dedicated time from EPA and NHTSA staff. The agency's 

9 work ethic, transparency, and public process are 

10 exemplary. The agencies have undoubtedly made a rule 

11 based on rigorous state-of-the-art technology inputs 

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 of the 

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 on 

18 well-understood, highly cost-effective technologies. 

19 The technologies in the engine, power train, 

20 aerodynamic, and tire areas are exactly the ones that 

21 suppliers and vehicle manufacturers have been 

22 discussing for the rules timeframe. 
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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 greenhouse 

4 gas regulation. Due to the agency's decision to rely 

5 primarily on proven, available, and cost-effective 

6 technologies, the agencies can shift the standards 

7 three years earlier from 2027, as proposed, forward to 

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 their 

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 use 

16 by 4 percent from 2017 to 2027. Available technologies 

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 go
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1 further yet. In addition, the proposed heavy-duty 

2 pickup and van in the proposed heavy-duty pickup and 

3 van as well as gasoline efficiency, standards appear 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 feasible 

7 technology potential and advancing the timing of the 

8 rule, there is a lot at stake. Based on our analysis, 

9 incrementally advancing the timing and modestly 

10 increasing the efficiency technology could result in 30 

11 percent greater climate benefits and over 300,000 

12 barrels worth of oil savings per day by 2040. Making 

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 establishing 

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 their 

19 next policy actions to similarly ensure greater 

20 efficiency technology deployment for trucks. The world 

21 is watching and potentially looking to adopt similar 

22 policy. 
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1 We provide references to the leading technical

2 research that supports these statements. And we will, 

3 of course, elaborate on the points and submit all new 

4 analysis in our detailed comments to the docket. 

5 Again, we thank the agencies for their exemplary 

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 first 

13 thank the EPA and NHTSA for the opportunity to testify 

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 embed 

22 sustainable business practices into the fabric of their 
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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 our 

5 operating costs. The phase 2 standards are in line

6 with this mission. And when combined with a holistic 

7 approach to fleet management, almost certainly we will 

8 have a positive impact on the fuel efficiency of our 

9 fleet. 

10 That said, we do not believe there is a silver

11 bullet or one simple solution in the quest for overall 

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 components in 

19 helping drive better fuel performance. Driver training 

20 and better maintenance programs also help make our 

21 fleet more fuel-efficient. 

22 In our opinion, the standards are balanced. The 
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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, these 

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 current 

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 facts 

13 and grounded in logic. 

14 As in the past, PepsiCo believes that it is 

15 important to complement these standards with financial 

16 incentives to help organizations implement new 

17 technologies and alternate fuel strategies. 

18 For example, previous incentives help our Frito 

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 spur 

22 future opportunities and increase implementation and 
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1 innovation of fuel-saving technologies. For the past 

2 ten years, we have been an early adopter of alternate 

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 fuels, 

8 Alternative Clean Transportation, the National Clean 

9 Fleets Partnership, and the North American Council for 

10 Freight Efficiency. We expect to continue to build on 

11 these partnerships to further collaboration, learn and 

12 support shared goals of reducing greenhouse gas fuel 

13 consumption. 

14 Overall, we recognize and understand that 

15 sustainable business practices can lead to innovation, 

16 operational excellence, and business growth. Further, 

17 we view sustainability as a strength and competitive 

18 advantage by aligning these initiatives were greater 

19 efficiency, productivity, and cost savings that can be 

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 the 
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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 director 

8 of Worldwide Environmental Strategy and Compliance at 

9 Cummins. 

10 Cummins thanks EPA and NHTSA for leading an open 

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 efficiency 

16 leadership group, which Mike and Pepsi are also a part 

17 of. It is in that spirit of collaboration that I speak 

18 today on key aspects of the proposal. 

19 Cummins supports the goal of the phase 2 proposal 

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 from
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1 heavy-duty engines and vehicles means fuel savings. 

2 The proposed regulatory structure of separate engine 

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 compliance 

7 program, requires manufacturers to optimize CO2 and

8 criteria pollutants together and provides the only 

9 measure of engine fuel consumption and CO2 emissions 

10 under transient conditions. The agencies declare these 

11 and other advantages of separate engine standards as 

12 "fundamental to the success of the program." Cummins 

13 wholeheartedly agrees, and, as you heard in Chicago and 

14 will hear today, so do many others. 

15 Although the phase 1 regulatory structure of 

16 separate engine and vehicle standards is retained for 

17 phase 2, a change in how the engine is characterized 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 provide 

22 the fuel map to vehicle manufacturers for use in the 
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1 GEM vehicle certification process. This approach is 

2 very concerning because it requires Cummins to release 

3 proprietary and confidential business information into 

4 the public domain. 

5 Additionally, the steady-state fuel map is unable 

6 to accurately represent engine performance today, and 

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 draft 

10 regulatory impact analysis. 

11 The cycle average map process is being evaluated 

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 support 

15 of these efforts. We urge the agencies to finalize the 

16 cycle average map approach in the final rule. 

17 Another area of concern related to interactions 

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. Cummins 
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1 cautions the agencies against this approach. Implicit 

2 engine stringency in the vehicle program decouples 

3 engine CO2 improvements from compliance with NOx 

4 standards. This threatens the regulatory integrity of 

5 the rule by creating a structure in which in-use NOx 

6 emissions can be increased by operation outside 

7 expected NOx regulatory limits while in-use CO2 

8 emissions are reduced. Implied standards also lack the 

9 regulatory clarity required for focused and sustained 

10 innovation and engine technology. For these reasons, 

11 required engine CO2 reductions should be explicit in 

12 the engine standard. 

13 As we consider the explicit levels of the proposed 

14 engine standards, our ability to comply is informed by 

15 our experience with SuperTruck, a Cummins-Peterbilt

16 project in partnership with the Department of Energy. 

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 necessary to 
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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 supports 

7 retaining this timeline for the final rule. The long8 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 ultimately 

12 depend on them in the market. 

13 Finally, Cummins supports a consistent national 

14 program. One deviation from this area in the proposed 

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 are 

21 all aligned in addressing fuel efficiency and CO2 as 

22 well as NOx. EPA and ARB should work collaboratively 
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1 with the goal of maintaining a national, heavy-duty NOx 

2 and greenhouse gas program. Cummins is committed to 

3 working with both agencies to determine the best path 

4 for achieving real-world reductions. 

5 We still have more work to do to fully understand 

6 the phase 2 proposal and we intend to submit detailed 

7 written comments. Cummins will work with the agencies 

8 and other stakeholders to make sure both the 

9 environment and our customers benefit from the final 

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 addressing 

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 Henry 

18 Hogo, assistant deputy executive officer at the South 

19 Coast Air Quality Management District. I am here this 

20 morning on behalf of NACAA, the National Association of 

21 Clean Air Agencies, a national nonpartisan, nonprofit 

22 association of air pollution control agencies in 41
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1 states, the District of Columbia, 4 territories, and 

2 116 metropolitan areas. I appreciate this opportunity 

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 adopt 

6 the first phase of greenhouse gas and fuel efficiency 

7 standards for heavy-duty vehicles and engines. Now we 

8 are pleased to support your agency's efforts to advance 

9 this program by establishing phase 2 standards. We

10 believe your proposal holds great promise for achieving 

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 supports. 

19 First, we fully endorse the continued inclusion of 

20 separate but complementary standards for engines and 

21 full vehicles. This is a fundamental aspect of the

22 rule. 
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1 Second, the inclusion of standards for trailers, 

2 particularly box trailers, is critical given their 

3 significant contribution to fuel consumption by long4 haul trucks. 

5 Third, we are very much in favor of EPA's proposal 

6 to close the assisting loophole for glider kits, under 

7 which used pre-2013 engines may be installed into new 

8 glider kits without meeting applicable standards. We 

9 agree with EPA that its regulations should be revised 

10 to require that only engines that have been certified 

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 rule 

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 phase 2 

17 rule. We urge for a rule that would reduce greenhouse 

18 gas emissions and fuel consumption across the entire 

19 fleet by at least 40 percent on average compared to

20 2010. Unfortunately, we find the overall effectiveness 

21 of the phase 2 proposal to fall short of our 

22 recommendation and significantly short of what can and 
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1 should be achieved. Accordingly, we believe the 

2 overall stringency of the proposal should be enhanced 

3 to take advantage of missed opportunities that if 

4 incorporated into the final rule would drive technology 

5 and ensure that maximum benefits are gained. Toward 

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 nongovernmental 

10 organizations, have suggested engine efficiency can be 

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 it is 

16 imperative that EPA strengthen the engine standard in 

17 the final rule to reflect this. 

18 We respect the timing. NACAA strongly supports 

19 EPA proposal alternative 4, under which the standards 

20 would be fully implemented by 2024. This 

21 implementation deadline is entirely feasible and 

22 vitally important to spur much needed near-term 
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1 emission reductions and technologies innovation. 

2 Our March letter also included a recommendation 

3 that EPA articulate in the proposal the need for 

4 significantly lower national heavy-duty NOx standards. 

5 We are very disappointed that EPA has not included such 

6 a discussion in this proposal. Although there is the 

7 potential for ancillary NOx reduction from the phase 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 nearly 

11 sufficient given the challenges state and local 

12 agencies face in attaining and maintaining current and 

13 upcoming ozone and fine particulate matter standards 

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 for 

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 study of 

22 the phase 2 proposal and will offer additional comments 
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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 NHTSA 

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 actually 

9 in our district, Fighting 33rd, which runs from the

10 Port of Long Beach all the way to the southeast City of 

11 Vernon. 

12 My name is Nick Jiles. I am the district director 

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 challenges 

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 goal 

19 is one of our greatest priorities. Families living in 

20 the communities I represent can't wait any longer. 

21 My Senate district is a large bubble of soot and 

22 toxic air. It is home to refineries, the Port of Long 
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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 neighborhoods. 

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 communities 

8 of color. 

9 Cancer clusters, asthma, and low birth weight,

10 these are consequences of poor air quality. And they 

11 affect communities throughout California each day. For 

12 example, if you live in the City of Commerce, you are 

13 140 percent more likely to contract cancer from diesel 

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 incentivize 

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 proposed 
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1 standards that will reduce emissions and make trucks on 

2 our roads more fuel-efficient. And these proposed 

3 standards represent a significant step forward in our 

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 in 

10 greenhouse gases. We have made that commitment in 

11 California, investing millions of cap and trade dollars 

12 to the development of clean truck technology. However, 

13 we need an ambitious federal standard that complements 

14 and supports these efforts with stringent rules that 

15 will be implemented as soon as possible. 

16 Thank you for your time in allowing me to provide 

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 advanced 
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1 air pollution standards and regulations. And I think 

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 extent 

6 that your staff over the last several years had learned 

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 experience 

11 that you all have had with that, that would be very

12 helpful. 

13 And my question for you is, above and beyond the 

14 level of the standard, do you or the South Coast staff 

15 have any recommendations for EPA and NHTSA about, in 

16 addition to the standards themselves, other incentives 

17 that we can provide for spurring the very, very 

18 advanced technologies, like EVs and fuel cells? And 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 we 
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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 that 

4 are needed to address our local air quality problems, 

5 it is, in essence, the same technologies that are 

6 needed to address climate change and GHG from vehicles 

7 and engines. And so the programs really overlap. And 

8 that is an important concept for everyone to keep in 

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 of 

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 help 

22 fleet operators and individual vehicle owners and 
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1 independent truckers to get into a state-of-the-art

2 low-emission vehicle. And we think there are things 

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 with 

8 EPA what options you might have that could assist in 

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 and 

18 your colleagues at Eaton and at Navistar and at PACCAR 

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 phase 

22 2, the only reason we are in a position to ask for 
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1 detailed comment on it was because of the amount of

2 effort that you, your company, and Eaton and PACCAR and 

3 Navistar put into it. And it is something we want to 

4 continue to explore because it may very well have some 

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 Cummins 

8 and the OEMs and other stakeholders on that important 

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 something 

13 along the lines of that Cummins would support movement 

14 in the direction of real-world reductions, real-world 

15 reductions. Could you elaborate specifically? Are you 

16 supporting or is Cummins saying that you support EPA 

17 and CARB working on new national NOx standards beyond 

18 the current 2010 standards or did you mean that there 

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 the 
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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 in 

4 NOx in terms of the ambient air emissions. We believe 

5 that there is a host of ways to get at that reduction. 

6 And we want to collaborate on all of those ways. So 

7 certainly going from older technology to newer 

8 technology is a very significant step for replacing the 

9 older vehicles that are on the road. That will result 

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 that we 

14 can collaborate and make sure that it is a national

15 program to address that, Cummins is fully committed to 

16 that. And we think that that should also look at the 

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 because 

21 that is the ultimate goal. And so we are fully 

22 committed to working with the agencies and others to 
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1 make sure we maintain a national heavy-duty program. 

2 MR. CHARMLEY: So, to summarize for you, among the 

3 things that Cummins would support, Cummins would 

4 support new NOx standards at the national level beyond 

5 the current 2010 standards? 

6 MR. MORMINO: Yes, we commit to working with all 

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. You 

14 mentioned the importance of flexibility in achieving 

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 through 

18 the technology review and we have certainly got more 

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 iterations 

22 of change are critical, so staying aligned with model 
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1 year conversions and implementing the technology at a 

2 certainly aggressive enough pace to make a difference 

3 and an impact, but there is a realistic approach to how 

4 much you can absorb into a fleet operation at any one 

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 issue. 

9 MR. O'CONNELL: Yes. We can certainly comment on 

10 that. 

11 MR. SILVERMAN: And I have one further question 

12 for Mr. Hogo about glider kits. We proposed that those 

13 standards take effective January 1, 2018, but we also 

14 asked for comment if it could be done sooner. Do you 

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 this 

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. Wallerstein 

22 for bringing up the Diesel Emission Reduction Act work 
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1 of EPA. I am only sad that Congresswoman Napolitano 

2 was not here to hear that. Perhaps you should share 

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' table 

7 panel 4. Sitting on panel 4 is Tim Blubaugh of Engine 

8 Manufacturers Association, Jorge Rodriguez of the 

9 BlueGreen Alliance, Steve Berry with Volvo, David Kayes 

10 with Daimler, David Majors with Navistar, Dan Kieffer 

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 Association. 

15 EMA's members were instrumental in working with EPA, 

16 NHTSA, and other stakeholders on the historic phase 1 

17 rule. That rule was a success because the final rule 

18 was structured around certain key principles: adopting 

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 unintended 
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1 consequences. 

2 Similar principles should guide the development 

3 and implementation of phase 2. Given EPA's and NHTSA's 

4 stated intent to adopt a significantly more stringent 

5 program, one that forces the development of technology, 

6 the appropriate and necessary principles are somewhat 

7 modified. We still must maintain a single nationwide 

8 program. That not only means that the EPA and NHTSA 

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 indicated 

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 world's 

20 most stringent criteria emission control program. 

21 Full regulatory alignment was, similarly, critical 

22 to the success of phase 1 and, likewise, is critical to 
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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 program 

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 unintended 

11 consequences. To that end, the final rule must provide 

12 adequate lead time and stability; balance stringency 

13 costs and implementation dates; look to improvements 

14 beyond just those that are in control of the truck and 

15 engine manufacturers; account for impacts of trailer 

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. The 

21 proposal also demonstrates that the agencies have 

22 considered multiple options, are open to potential 
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1 changes before the rule is finished, and are committed 

2 to work with all stakeholders to finalize a rule that 

3 substantially reduces greenhouse gas emissions and 

4 improves fuel efficiency in a way that is cost5 effective and implementable, will be accepted by the 

6 customers, and will provide real-world improvements. 

7 While those goals are envisioned in the proposal, 

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 to 

11 work with EPA and NHTSA to assure a strong, effective, 

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 change 

17 the phase 1 rule. Manufacturers already have fully

18 committed their product development plans for phase 1 

19 compliance. EPA and NHTSA must not create uncertainty 

20 and eliminate essential regulatory stability by 

21 attempting to make retroactive changes to the phase 1 

22 rule. 
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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 that 

19 variability. Where they cannot fully do so, it is 

20 incumbent upon the agencies to provide test and audit 

21 margin to account for that variability. 

22 As with phase 1, EMA and its members are committed 
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1 to working with EPA and NHTSA to resolve the many 

2 important open issues. We will be providing our best 

3 technical assessment of the proposed rule and our 

4 recommendations for necessary improvements. Our 

5 customers have long demanded fuel efficiency. We have 

6 worked to continually improve it, even while achieving 

7 incredible reductions in criteria pollutant emissions. 

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 rule 

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. Thank 
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1 you for the opportunity to make comments on behalf of 

2 the BlueGreen Alliance on EPA's and NHTSA's proposed 

3 phase 2 standard for medium and heavy truck vehicles. 

4 These standards will increase fuel efficiency and 

5 greenhouse gas emissions from long-haul trucks along 

6 with full size pickup trucks, other trucks, buses, and 

7 vocational vehicles. These standards can also continue 

8 America's auto and manufacturing resurgence. 

9 The BlueGreen Alliance is a national partnership 

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 powerful 

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 and 

21 greenhouse gas emissions reduction rule. America's

22 economy depends on leadership in building the next 
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1 generation of clean globally competitive energy and

2 vehicle technology. These new standards can provide a 

3 critical opportunity to sustain jobs, further reduce 

4 the pollution driving climate change and foreign oil 

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 American 

9 workers, represented by the United Auto Workers, the 

10 United Steelworkers, and others, have been at the front 

11 lines when it comes to rebuilding manufacturing jobs 

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 that 

17 are manufacturing fuel-efficient medium- or heavy truck 

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 the 
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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 systematic 

7 process EPA and NHTSA have taken in developing this

8 proposal. It is critical that an effective rule works 

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. The 

12 auto industry and autoworkers have been at the 

13 forefront in proving that America can lead globally in 

14 combating climate change while rebuilding our 

15 manufacturing sector and creating and sustaining 

16 quality jobs. We urge the agencies to continue their 

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 heavy20 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 globally. 
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1 We thank EPA and NHTSA for their work to date and 

2 look forward to working with the agencies and all of 

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 worked 

8 with our colleagues at Daimler, Navistar, and PACCAR to 

9 prepare a joint statement. So we will defer our time 

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 for 

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 address 

22 this hearing. 
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1 This phase 2 greenhouse gas and fuel efficiency 

2 rule is historic in its scope and complexity. The 

3 proposed rule will regulate a wide array of customized 

4 vehicles, including a broad range of tractor 

5 applications, utility trucks, street sweepers, concrete 

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 their 

10 daily business. We must design each vehicle to meet 

11 the specifications of its intended application while 

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 mission 

16 more critical and more complex. We recognize the 

17 problem. And, just as we work closely with EPA, NHTSA, 

18 and other agencies to successfully implement phase 1 

19 reductions, so shall we strive to address the urgent 

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 Engine 
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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 closely 

4 with the agencies to resolve. EPA and NHTSA have set 

5 very ambitious goals for this industry, and we will do 

6 everything we can to ensure that this regulation will 

7 translate into significant real-world efficiency gains 

8 for our customers as well as major benefits for 

9 society. Our goal is a classic win-win scenario, and 

10 we are hopeful we can achieve it. 

11 We would like to emphasize that we fully support 

12 the complete vehicle approach proposed by the agencies. 

13 Measurement and modeling of the full vehicle, including 

14 the engine and all other components, is the best way 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 like to 
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1 make today in regard to engine testing and evaluation. 

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 vehicle 

6 approach. 

7 Second, we must also consider the installation

8 impact of the engine-related systems, including space 

9 requirements, weight, and cooling demand, all of which 

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 respect 

13 the simple fact that NOx emissions are proportional to 

14 engine work. Technology that reduces the engine work 

15 required to complete emissions, such as improving 

16 aerodynamics or reduced rolling resistance, inherently 

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 engine 

21 efficiency. Excessive demands on the standalone engine 

22 efficiency would limit the potential for NOx reduction, 
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1 especially in urban duty cycles, where NOx emissions 

2 are most critical. 

3 And, finally, the many American businesses that 

4 rely on our vehicles are concerned about the 

5 incremental investment and operating cost of complex 

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 or no 

9 benefit in many real-world applications. 

10 American businesses have already seen significant 

11 increases in vehicle cost, in more expensive 

12 maintenance associated with the increasingly complex 

13 engine and after-treatment systems. Unnecessarily 

14 stringent engine standards will only exacerbate today's 

15 trend of delaying new truck purchases and prolonging 

16 the use of higher-emitting vehicles. 

17 Summing up our points concerning the engine 

18 regulation, the fact is that the vehicle manufacturers 

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 vehicle 

22 ownership is at the top of the priority list for our 
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1 customers. 

2 Concerning aerodynamics, measurement and analysis 

3 of tractor-trailer aerodynamics is extremely complex. 

4 We recently provided detailed feedback to the agencies 

5 on improvements to these procedures and would 

6 appreciate careful consideration of these 

7 recommendations. For now, we would like to emphasize 

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 achieve 

11 the tractor aerodynamic performance targets if tested 

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 widely 
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1 variant applications we support today. Based on our 

2 current analysis, it is not clear that the proposed

3 alternative three targets, which include a number of 

4 unrealistic technology penetration rates, can be 

5 achieved. 

6 One thing we are certain of is that we could not 

7 achieve and, therefore, cannot support the pull-ahead 

8 of these standards according to the plan identified as 

9 alternative 4 in the proposed rule. 

10 We look forward to further discussions with the 

11 agencies and their technical experts on these important 

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 of 
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1 the Energy Climate Committee for Sierra Club California 

2 and also representing the Sierra Club as one of the

3 environmental advisers to the air quality management 

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. This 

8 morning, just like almost every morning, I got another 

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 Los 

14 Angeles are suffering from asthma. This is a crisis 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 emissions 

18 you are well aware are killing people. And we need the 

19 people from this trucking industry to do what it says 

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. 
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1 I am thrilled to be able to support the four 

2 points that Mary Nichols made on behalf of us suffering 

3 Californians and the same for Barry Wallerstein and

4 Henry Hogo, who are valiantly fighting. As you heard, 

5 we need a 90 percent reduction in NOx ambient emissions 

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 fact 

13 that this past year, 5,000 people died in Southern 

14 California from these unhealthy ambient air standards, 

15 primarily caused by these diesel trucks. So we really 

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. 
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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 phase 

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 you 

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 mentioned 

11 was specifically dealing with the changes to the phase 

12 1 program. So what we see is a retroactive or going 

13 back and modifying the phase 1 certification approach 

14 is something we are opposed to. The manufacturers have 

15 already set their product lines and their production 

16 plans to meet the phase 1 program. And we do not feel 

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 you 
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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, will 

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 is 

10 very, very important from the OEM's perspective that 

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 benefits 

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 compared to 

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 vehicle 

21 simulation. So do you think, again, that the engine 

22 cycle, average cycle, map approach versus our steady-
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1 state has more opportunity to meet one of your four

2 recommendations for engines, that it be best evaluated 

3 and over how it will actually be used? 

4 MR. KIEFFER: PACCAR has been actively involved 

5 with the group developing the cycle average approach. 

6 And I would say at this point, we are still assessing 

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 seem 

10 to show some advantages, but that is just at the first 

11 step. So we need to dive in to determine what the 

12 implication is on the broader range, rather than single 

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 average 

17 map over all of the duty cycles. I think it is very 

18 early in the stage to make a comment that it is more 

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 and 
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1 progress it. But right now there is still much more 

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 for 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. And we 

11 understand that situation. And Volvo has been 

12 supporting a movement toward evaluating NOx emissions 

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 stringent 

18 engine standards that are proposed, which only further 

19 challenges our ability to support future NOx reductions 

20 that we understand are so valued in California and 

21 across the country. 

22 MS. AMERLING: Any other thoughts from the panel? 
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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 just 

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 greenhouse 

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 those 

22 and implementation of those approaches. 
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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 from the 

8 Pew Charitable Trusts, Jason Wynne; Doug Corcoran from 

9 Waste Management; Allis Druffel from the California

10 Interfaith Power and Light; Tom Fulks from the Diesel 

11 Technology Forum; and Don Anair from the Union of 

12 Concerned Scientists. Welcome. Ms. Sinnamon, when you 

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 going 

18 again with panel 6. 

19 MS. SINNAMON: Thanks. Good morning. On behalf 

20 of the Environmental Defense Fund and our more than 1 

21 million members nationwide and nearly 200,000 here in 

22 California, I thank you sincerely for the opportunity 
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1 to testify today in support of a timely and rigorous 

2 phase 2 program to reduce climate pollution and fuel 

3 consumption for the nation's fleet of heavy-duty trucks 

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 standards 

9 for the heavy-duty sector. The success of the first 

10 phase of the program is already being demonstrated by 

11 the demand for more efficient trucks. Model year 2014 

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 emissions 

17 and oil reductions while spurring technological 

18 innovation and saving businesses and consumers money. 

19 Heavy trucks are critical to our economy but also 

20 consume more than 135 million gallons of fuel every day 

21 and emit more than 450 million metric tons of climate 

22 pollution annually. As mentioned, Southern California 
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1 has the worst air quality in the country. And in Los 

2 Angeles County alone, nearly 400,000 children suffer 

3 from asthma while living in an area that fails the 

4 health-based standards for both ozone and particulate 

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 can 

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 and 

12 buses, actions that have spurred critical progress,

13 both statewide and nationally. For example, 

14 California's trailer efficiency standards have yielded 

15 strong benefits and are now an important feature of the 

16 agencies' proposed rule. And just recently, Governor 

17 Brown announced an initiative to further strengthen the 

18 environmental and economic performance of California's 

19 transportation sector. The phase 2 heavy-duty 

20 greenhouse gas and fuel economy standards are one of 

21 the single most important opportunities to protect 

22 public health and the environment in California and the 
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1 nation. 

2 While the proposals by EPA and DOT are an 

3 important step forward, there are many opportunities 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 strengthen our 

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 engine 

12 standard, a separate, rigorous engine standard is 

13 essential to deliver permanent, real-world emissions 

14 reductions. It also allows EPA and manufacturers to 

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 engine 

18 efficiency improvement over 10 years falls woefully

19 short of what manufacturers and leading analyses have 

20 indicated is viable. Existing technologies have the 

21 potential to cost-effectively increase the engine 

22 efficiency by at least 15 percent beyond the 2017 
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1 levels. A weak engine standard undermines the overall 

2 tractor-trailer standard and fails to drive a wide 

3 array of important engine technologies that can deliver 

4 real-world reductions. The agencies must finalize a 

5 protective engine standard that reflects the innovative 

6 path of today's technologies and carries out its legal 

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 needed 

10 emission reductions and technological innovation in the 

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 eminently 

14 feasible and cost-effective. Speeding the transition 

15 to cleaner trucks would save an additional 200,000 

16 barrels of oil per day in 2035 and avoid an additional 

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 California 

21 would certainly benefit from. 

22 Number three, promulgate protective emissions 
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1 standards for particulate pollution from APUs. 

2 Auxiliary power units are among the technologies 

3 available to reduce fuel use from sleeper cab tractors 

4 due to idling. However, the particulate standards for 

5 diesel APUs, established under the non-road rule, are 

6 not nearly as protective as the truck engine standards 

7 for model year 2007 and later, which require the use 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 the 

11 trucks they are relieving. This increase in 

12 particulate emissions will be especially significant at 

13 idling hotspots, like diesel truck stops; distribution 

14 centers; and ports, like here in Long Beach. 

15 California has already established more protective 

16 standards for APUs and has concluded that technologies 

17 are available and highly cost-effective. We request 

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 important 
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1 opportunity to protect Americans' health, strengthen 

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 for 

12 medium- and heavy-duty engines and vehicles. My name 

13 is Jason Wynne, and I am a senior associate with the 

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 initiative 

18 has supported prior fuel economy standards promulgated 

19 by the Environmental Protection Agency and the National 

20 Highway Traffic Safety Administration for passenger and 

21 light-duty vehicles. We commend the agencies' latest 

22 efforts to set ambitious and achievable efficiency 
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1 standards for medium- and heavy-duty trucks. Improving 

2 the efficiency of America's transportation vehicles is 

3 good for our economy, our national security, and our 

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 rely 

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 energy 

22 use. Establishing smart and affordable standards will 
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1 facilitate a more sustainable trajectory for this 

2 expanding industry. The standards under consideration 

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 reducing 

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 standards 

9 for these vehicles also will help spur new technology 

10 innovations in this sector. The Department of Energy's 

11 SuperTruck program demonstrates that dramatic changes 

12 in fuel economy are possible for class 8 tractor13 trailers. These SuperTrucks can achieve over ten miles 

14 per gallon under real-world conditions—up from today's 

15 six miles per gallon rating for heavy-duty trucks. 

16 Through public-private partnerships as well as research 

17 and development, we can help bring new advanced vehicle 

18 technologies to the marketplace in a cost-competitive 

19 way. 

20 The International Council on Clean Transportation 

21 reports that other countries, including China and 

22 Japan, are looking to strengthen efficiency standards 
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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 countries 

4 to meet their next policy goals. 

5 While collectively the proposed phase 2 standards 

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 the EPA 

11 and NHTSA to consider the information provided by these 

12 experts and look for opportunities to strengthen the 

13 proposed standards. Furthermore, we ask that EPA and 

14 NHTSA continue working with the Department of Energy 

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. 
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1 Good morning. I am Doug Corcoran. I am Director 

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 North 

8 America. Headquartered in Houston, Waste Management 

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 significant 

13 impact on our operations. 

14 Before discussing our views on particular aspects 

15 of the proposal, we want to commend the Environmental 

16 Protection Agency and the National Highway Traffic 

17 Safety Administration for the very collaborative 

18 process you used to develop this proposal. You were 

19 open, transparent. You sought stakeholder information. 

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 gas 
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1 fleet. 

2 We believe the resulting proposal reflects careful 

3 consideration of our views, providing a regulatory 

4 framework that can build upon the initial success of 

5 phase 1, allowing us to continue to grow our natural 

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 goal 

14 in 2011 and have reduced our fleet emissions by over 20 

15 percent. We did so by steadily converting our fleet to 

16 cleaner burning, natural gas-fueled vehicles. 

17 Here in Southern California, we have converted 85 

18 percent of our fleet -- that is over 1,100 heavy-duty 

19 vehicles -- to natural gas, while nationwide nearly 25 

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. 
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1 The natural gas trucks have been good for our 

2 customers and communities where we operate, good for 

3 the environment, and good for our business. Each truck 

4 eliminates the use of 8,000 gallons of diesel fuel a 

5 year, which is replaced by the cleaner burning natural 

6 gas. Natural gas trucks have nearly zero particulate 

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 -- they 

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 fueling 

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 can be 

20 a barrier to local governments that wish to increase 

21 their own public natural gas fleets. That is why 

22 nearly 40 percent of our stations are open to the 
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1 public and/or city access. 

2 Working with our manufacturing partners and with 

3 our regulators, such as the South Coast Air Quality

4 Management District, we have seen steady improvements 

5 in heavy-duty natural gas engine technology. For 

6 example, in future model years, enclosed crank cases 

7 will enable significant reduction in fugitive methane 

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 the 

11 future, a bridge to even cleaner running vehicles. 

12 As a next step towards further reductions in our 

13 greenhouse gas footprint, we are using gas produced by 

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 from 

17 our Altamont Landfill. We plan to fuel several hundred 

18 more vehicles with new renewable natural gas production 

19 at our landfill in Milam, Illinois. And we are working 

20 with other landfill owners to purchase renewable 

21 natural gas to fuel even more vehicles. 

22 On a lifecycle basis, renewable natural gas 
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1 reduces greenhouse gas emissions by upwards of 90 

2 percent. Therefore, phase 1 and phase 2 truck rules 

3 can work in a very complementary way with the EPA's

4 renewable fuel standard. The transition of our fleet 

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 phase 

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 the 

18 opportunity to make comments. 

19 My name is Allis Druffel. And I am South 

20 California Outreach Director for California Interfaith 

21 Power and Light. We work with 650 member congregations 

22 in the state to address global warming through energy 
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1 efficiency, renewable energy, education, and advocacy. 

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 an 

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 lessening the 

11 threat of climate change while building a renewable

12 energy future and creating jobs, especially for those 

13 persons in areas that are hard hit by high 

14 unemployment. 

15 Just recently, Pope Francis released an encyclical 

16 on ecology, exhorting that any efforts to stave off the 

17 worst effects of climate change and regional pollution 

18 must naturally integrate efforts to alleviate poverty, 

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, it 
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1 is communities of color and lower-income communities 

2 that are affected disproportionately by local sources 

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 EPA 

12 and NHTSA to adopt standards that will achieve a 40

13 percent target by 2025. 

14 With existing technologies and future innovation 

15 in the works, especially here in California, we can

16 surely reach much better than an average of six miles 

17 per gallon for most heavy-duty vehicles. We also 

18 support other organizations, such as the South Coast 

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 deliberately 

22 as a site for this hearing because of the proximity of 
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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, especially 

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 in 

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 heard, 

12 these will have benefits for companies in fuel savings 

13 and energy efficiency. 

14 Personally, I still remember the fact that I had 

15 extreme asthma when I was growing up in the '70s and 

16 '80s in Pasadena. I still remember the almost 

17 desperate gasping for breath and being forced to lie 

18 down quietly inside while other friends played outside. 

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, has 
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1 extreme asthma, brought on by growing up close to the 

2 134 freeway, which is very heavily congested. While it 

3 is very uncomfortable for her to experience asthma, it 

4 actually pains me when I hear her wheezing and seeing 

5 her use her inhaler constantly. And I know that many 

6 in this room can relate to that feeling. 

7 I am praying that these standards, especially the 

8 stronger standards, are accepted, preventing millions 

9 of cases of respiratory illnesses as well as cancer

10 exacerbated by pollution. 

11 The faith community, especially in the hard-hit 

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 California 

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 ongoing 

21 efforts to improve public health to protect our climate 

22 and to build healthier communities. 
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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. The 

7 DTC represents the leaders in clean diesel technology, 

8 including engine makers; vehicle manufacturers; 

9 equipment manufacturers; and affiliated organizations, 

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 time. 

13 And so we will get through this hopefully within the 

14 timeframe. 

15 Today, manufacturers of commercial truck engines 

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 and 
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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 on 

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 today 

12 are significant and growing. And, three, the framework 

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. Manufacturers 

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 near-
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1 zero emissions environmental performance, along with an 

2 ability to utilize a variety of low-carbon renewable 

3 diesel fuels, solidifies diesel's rule for commercial 

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, with 

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 diesel 

14 engines, reducing emissions by as much as 98 percent 

15 from previous levels. In fact, last year, the American 

16 Lung Association in its annual state of the air report 

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 standards. 

20 New technology clean diesel engines are being 

21 widely embraced by customers, as evidenced by the 

22 increasing penetration of the vehicle population. 
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1 According to vehicle registration data for 2014, about 

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-zero PM. 

5 Of these, 22 percent of the vehicles on the road today 

6 meet the most stringent 2010 and later emissions 

7 milestones that require near-zero levels of both PM and 

8 NOx. 

9 By comparison, there are 120,429 model year 2010 

10 or newer vehicles or, I should say, medium-duty 

11 vehicles in operation in California, making California 

12 the third nationwide in terms of total number of new 

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 the 

17 DTF, between 2010 and 2014, technologies developed to 

18 meet strict diesel emissions standards, beginning for 

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-year
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1 period. 

2 I am moving on because I am running out of time. 

3 Based on the industry experience over the last decade, 

4 we strongly urge EPA and NHTSA to finalize these rules 

5 to ensure a national program uniform to all 50 states, 

6 including California, that ample lead time and 

7 stability are provided, and that it is compatible with 

8 the diversity of the commercial trucking marketplace. 

9 In addition, we strongly urge the EPA and NHTSA to 

10 ensure that the final phase 2 program be fuel-neutral 

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 proposal, 

17 particularly for light-duty commercial vehicles as well 

18 as vocational trucks, may be skewed to favor one fuel 

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 allows 
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1 manufacturers and/or customers to select the technology 

2 that makes the most sense for their specific needs. 

3 While this proposed rule focuses on vehicle and engine 

4 standards in the context of efficiency and reducing

5 greenhouse gas emissions, we believe it is important to 

6 also note the benefits from changes to fuels. 

7 So, recently and in closing, I will mention that 

8 City of San Francisco recently went to a 100 percent 

9 renewable diesel fuel mix for its entire diesel fleet. 

10 UPS has adopted a renewable diesel fuel mandate for its 

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 and 

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 opportunity 

19 to comment today. 

20 My name is Don Anair. I am the research and 

21 deputy director of the clean vehicles program at the 

22 Union of Concerned Scientists. UCS is a leading 
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1 science-based nonprofit with over 450,000 members 

2 nationwide and a network of nearly 17,000 scientists, 

3 engineers, and public health professionals. 

4 Reducing oil consumption and pollution from heavy5 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 successful 

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 proposing 

19 the new standards for these vehicles. The proposal

20 represents a significant step forward from the phase 1 

21 standards, particularly with the inclusion of trailers 

22 in the standards. 
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1 However, there are additional opportunities to

2 increase emissions reductions and oil savings from 

3 heavy-duty trucks while continuing to provide strong 

4 overall economic benefits from the program. And we

5 urge the agencies to strengthen the rule. 

6 First and foremost, the agencies should accelerate 

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, which 

11 moves the final implementation date from 2027 to 2024, 

12 is much more consistent with the analysis of UCS and 

13 other independent organizations as well as the 

14 technical capabilities of the industry. 

15 In addition, the stringency of the engine standard 

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 potential 

21 improvements over this timeframe. 

22 Third, we applaud the agencies for including 
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1 hybrid technology when setting the overall stringency 

2 of vocational vehicles. Hybrid technology is 

3 commercially available today and should be expected to 

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 the GEM 

8 and not real-world duty cycles and also be excluding 

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 total 

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 growth 

20 in cost-effective applications over the timeframe of 

21 the rule and increase the stringency of the vocational 

22 vehicle standards to reflect this. 
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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 class 7 

9 and 8 tractors. These are all technologies that are in 

10 early stages of development or deployment. 

11 States like California as well as early adopter 

12 fleets are investing millions of dollars in these more 

13 advanced truck technologies, moving them toward full 

14 commercialization. Even today, there are hundreds of 

15 advanced electric trucks that are already operating on 

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 that 

20 the number of these vehicles will increase 

21 significantly over the next several years as well as 

22 California's investment of the greenhouse gas reduction 
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1 funds in these technologies will also be supporting

2 this technology development over the timeframe of the 

3 regulation. 

4 EPA and NHTSA can support advanced technology 

5 truck development by both increasing the stringency of 

6 the requirements for vocational vehicles as well as

7 restoring advanced technology credits or some similar 

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 of the 

13 truck manufacturing sector and set a path to even 

14 greater emissions reductions and fuel savings in the 

15 future. Strong standards will help to keep America's 

16 truck manufacturing sector competitive, spur economic 

17 growth, and improve the nation's energy security and 

18 our environment while saving the nation's truck fleets 

19 and their customers billions of dollars in fuel costs. 

20 Thank you very much. 

21 MR. GRUNDLER: Thank you, Don. 

22 Questions from the panel? Mr. Charmley? 
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1 MR. CHARMLEY: I just have one question for 

2 Hilary. Hilary, during your testimony from EDF, you 

3 mentioned that for the engine standards, you did give a 

4 specific recommendation of at least 15 percent or 15 

5 percent in 2024 based on existing engine technologies. 

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 more 

11 stringent standard including, but not limited to, a 15 

12 percent reduction by 2024, that would be very helpful. 

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. That 

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 Trailer 
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1 Manufacturing Association; Andrea Marr, Operation Free 

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 Andrea 

5 Marr from Operation Free Veteran, Matt Solomon from

6 NESCAUM, Diane Hart from Union of Concerned Scientists, 

7 and Will Barrett with American Lung Association in 

8 California. Welcome. We will just ask you to hold for 

9 one minute. 

10 (Pause.) 

11 MS. AMERLING: Okay. We are going to get started 

12 now. Thank you for joining us. Ms. Kiss, would you 

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 speak 

17 to you today regarding the EPA and NHTSA notice of 

18 proposed rulemaking to address greenhouse gas and fuel 

19 efficiency for medium and heavy-duty trucks. 

20 General Motors is a major manufacturer of these 

21 vehicles. And we want to thank NHTSA and EPA for 

22 providing the opportunity to comment on this 
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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 standard 

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 penalize 

10 both consumers and manufacturers in providing products 

11 that continue to serve the purposes, functions, and

12 utilities that are needed. 

13 General Motors is supportive of the approach used 

14 during phase 1 of this initiative and encourages the 

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 recognize the 

21 unique functionality and utility needs of the trucking 

22 industry and that we provide vehicles that preserve the 
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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 continue 

5 to align with the industry and business needs of this 

6 demographic. 

7 Third, we have been gaining valuable experience 

8 concerning the importance of real-world flexible 

9 mechanisms contained in the light-duty vehicle 

10 greenhouse gas and fuel economy regulations. And these 

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 not 

14 comprehended on the standard fuel economy tests, such 

15 as colder weather, higher speeds, or extended idle 

16 time. 

17 GM intends to provide detailed written comments 

18 and data to support the inclusion of similar mechanisms 

19 for the heavy-duty regulation. We have also had some 

20 favorable experiences with the extended carryforward 

21 time allowed in the light-duty regulations, which has 

22 resulted in GM achieving fuel efficiency improvements 
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1 sooner than required, thereby providing us greater 

2 latitude to manage our product cadence in these very 

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 standards 

6 based on alternative 3 in the notice of proposed 

7 rulemaking will continue to drive innovation and cause 

8 GM to invest in and refine new technologies that both 

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 plan 

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 changes 

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 for 
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1 the consumer. The heavy-duty fleet does not benefit 

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 cycle 

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, would be 

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 first 

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 form the 

16 basis for both phase 1 and the proposed phase 2 

17 regulations. 

18 As mentioned, we will be providing more extensive 

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 and EPA 

22 to assure the program created is national in scope and 
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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 Development of 

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 appreciates 

11 the opportunity to comment on EPA's phase 2 greenhouse 

12 gas emissions proposed trailer regulations. For over 

13 100 years, utility trailer manufacturing has 

14 manufactured truck trailers. Every day we strive to 

15 improve the standard of living by providing safe, high16 quality transportation products and other services to 

17 the transportation industry. Being good stewards of 

18 the Earth is a major part of our mission. 

19 Truck trailers must perform reliably and safely 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 concern
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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 footprint. 

9 These trailer aero devices are typically constructed 

10 from metal and plastic that require extreme heat and 

11 significant quantities of petrochemicals to produce. 

12 And once attached to the trailer, they are unlikely to 

13 survive more than a fraction of the trailer's expected 

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 year 

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 day
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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 devices 

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 of 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 measured 

12 and recorded the percentage amount of time that their 

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 less 

16 than 1.3 percent of the time at or above 65 miles per 

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 graph 

21 to you guys so you can review it further -- 

22 demonstrates all the speeds, percentages of all the
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1 speeds, for this study. This study clearly contradicts 

2 the speeds that the agency used in its GEM 2 analysis, 

3 which they used 86 percent of the time at 65 miles per 

4 hour cruise speed and they ignored entirely the 0 miles 

5 per hour speed. 

6 For a proper fuel savings estimate, the 

7 aerodynamics fuel savings measured at each speed must 

8 be multiplied by the actual percentage of time the 

9 truck travels at that speed and summed to an expected 

10 average savings. The agency has failed to provide such 

11 a study. In addition, the agency has proposed trailer 

12 speeds in their analysis that are dramatically greater 

13 than what has been measured in the field. 

14 We have performed and included here a study based 

15 on an EPA SmartWay-approved trailer side skirt that

16 measured a 7.5 percent fuel savings per the SAE 1321 

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 then 

21 multiplied by the actual measured fleet percentage of 

22 time at that speed and summed up to arrive at a total 
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1 cruising speed fuel savings of 1.7 percent across the 

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 uphill. 

6 Thus, the total fuel savings is actually less than the 

7 1.7 percent of the total fuel used and not the 7 and 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 justify 

11 the greenhouse gas output required to manufacture, 

12 install, and later replace when damaged this trailer 

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 allow any 

21 yaw angle effects to measure efficiencies from trailer 

22 aero devices. From our experience from track testing 
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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 must 

4 not ignore the effect of yaw angle on trailer 

5 aerodynamics devices. 

6 The agencies' impact analysis failed to account 

7 for the substantial reduction in tire life associated 

8 with the type 2 low-rolling resistance tires and from 

9 using tire inflation systems. This increase in tire 

10 degradation requires additional tire replacement during 

11 the life of the trailer, which increases the greenhouse 

12 gas output. The agency failed to demonstrate how these 

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 be 

20 unmanageable in the trailer manufacturing industry. 

21 Trailers are highly customized to specific customer

22 specifications. And no two orders are alike. 
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1 MS. AMERLING: Excuse me, Mr. Bennett. I just

2 want to remind you we are trying to ask panelists to 

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 the 

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 customers 

11 welcome any technology that truly reduces the total net 

12 greenhouse gas output and costs associated with a safe, 

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 greenhouse 

17 gas output and not achieve the goal of a cleaner, safer 

18 environment. 

19 Thank you. 

20 MS. AMERLING: Thank you so much. 

21 Next we have Gary Oshnock with Fiat/Chrysler. 

22 Welcome. 
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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 through 

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 and 

11 the 5.7-liter and 6.4-liter HEMI V8 engines. And our 

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 today 

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 vehicle 

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 rule. 

22 FCA US remains committed to the proliferation of clean 
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1 technology and reducing vehicle operating costs while 

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 program, 

6 a single national program "holds out the promise of

7 delivering environmental and energy benefits, cost 

8 savings, and administrative efficiencies that might not 

9 be available under a less coordinated approach." FCA 

10 US unequivocally agrees. While we are still analyzing 

11 the proposed rule, I have a few initial comments and 

12 suggestions. 

13 We support EPA's and NHTSA's attribute-based 

14 standards that recognize the utility and functionality 

15 of these work trucks. Payload and towing capacity are 

16 important to the owners of these work trucks. These 

17 work factor-based standards acknowledge the inherently 

18 higher greenhouse gas emissions and fuel consumption 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 early 

22 in the heavy-duty program. We formally have one full 
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1 model year of industry data under our belt. 

2 Given this limited baseline of real data, it is 

3 concerning that there have been calls for even greater 

4 stringency beyond the aggressive standards proposed by 

5 EPA and NHTSA for phase 2. Comments regarding 

6 stringency need to address many contributing factors, 

7 both explicit and implicit. 

8 These factors include, but are not limited to -- I 

9 have noted five here. Number one, these work trucks 

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 LEV 

18 III criteria emission requirements and how to manage 

19 the increased thermal loads and after-treatment 

20 systems; number 4, the impact of changing test fuels 

21 and the test procedure adjustments that will be needed 

22 going into the future. And, number 5, additional 
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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 national 

7 fuel consumption and greenhouse gas program will place 

8 more clean and efficient vehicles on the road quickly 

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 greenhouse 

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 is an 

18 additional opportunity to further harmonize with the 

19 light-duty program and recognize the added greenhouse 

20 gas emission benefit beyond leak reduction that 

21 switching to a lower global warming potential 

22 refrigerant can provide. 
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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 as 

9 part of the formal rulemaking process. We will work 

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 transportation 

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, New 

22 Jersey, New York, Rhode Island, and Vermont. My 
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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 NESCAUM 

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 maintaining 

9 in their proposal a separate engine standard, which we 

10 see as critical to the integrity of the proposed rule. 

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 concerned 

15 about NOx emissions from this sector and urge EPA to 

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 areas 

20 in which the rule can and should be strengthened. 

21 First, the agencies should adopt the timeline proposed 

22 in alternative 4. Given that the proposed technologies 
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1 are already mature or have been successfully 

2 demonstrated and given our states' need for significant 

3 greenhouse gas reductions in the near term, the 

4 timeline proposed in alternative 4 is both reasonable 

5 and appropriate. Based on the assessments of the 

6 California Air Resources Board and the International 

7 Council on Clean Transportation, a full phase-in of the 

8 rules by 2024 is technologically feasible. Given the 

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 too 

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 date. 

16 Heavy-duty trucks represent the second largest source 

17 of NOx emissions in the NESCAUM region, and our states 

18 remain very concerned about the need to further control 

19 NOx emissions from this sector. We thank the agencies 

20 for acknowledging the challenge that states continue to 

21 face in this regard, and we urge EPA to begin a 

22 rulemaking without delay to ensure that the next 
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1 generation of trucks is not only more fuel-efficient 

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 potential 

9 engine efficiency improvements of 15 percent or more 

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 the 

19 full suite of appropriate complementary technologies, 

20 in addition to engine improvements. The agencies also 

21 should consider strengthening the provisions for 

22 vocational vehicles, including the use of aerodynamic 
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1 controls. 

2 There should be no backsliding on PM from 

3 increased APU use. We also urge the agencies to ensure 

4 that there are no increases in emissions from either 

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 savings, 

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 and 

12 currently required by CARB. EPA should adopt similar 

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 other 

19 new trucks. This common-sense measure will prevent

20 gaming and will avoid significant amounts of 

21 unnecessary emissions of greenhouse gases, NOx, and PM. 

22 The agencies request comment on the appropriate 
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1 magnitude of the exemption. While we agree that some 

2 minimal exemption opportunity is probably appropriate 

3 in limited cases, we urge the agencies to set this 

4 number as low as is practical without impeding small 

5 businesses with legitimate claims. 

6 In conclusion, the NESCAUM states commend the 

7 agencies for a diligent and thorough analysis and for 

8 proposing a rule which is appropriate in structure and 

9 scope. However, the agencies should also strengthen 

10 certain provisions to maximize the benefits from this 

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 to 

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 in 
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1 Hollywood, and I grew up in Van Nuys in the San 

2 Fernando Valley. I can remember as a young girl how 

3 smoggy it would get and how hard it was some days to 

4 breathe. On the really bad days, your eyes would 

5 water. The sky would actually get yellow. And while 

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 would 

14 cut oil by a million barrels every two days. By not 

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. So I 

18 am asking you to strengthen the standard to achieve 40 

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 improve at 

22 least the breathing part. 
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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 the 

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 health 

10 opportunity. 

11 Earlier this year, we launched a public awareness 

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 of the 

15 standards to mesh the scientific understanding of the 

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, but 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 found 
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1 that the Los Angeles metropolitan area is among the

2 most polluted in the nation for both ozone and particle 

3 pollution. Transportation sector emissions are the

4 leading reason for this. And that pollution from our 

5 transportation sector threatens the health of all 

6 residents of this region but especially our children, 

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 pollution 

11 sources, including refineries, ports, rail yards, and 

12 the many freeways that carry the nation's goods through 

13 these communities first and the most. 

14 The residents of Southern California and the San 

15 Joaquin Valley here in California have perhaps the most 

16 to gain from a strong rule of any area in the nation. 

17 In the past month, we have seen record temperatures, 

18 raging wildfires, torrential flooding, and a persistent 

19 drought that has really grown over the last four years 

20 into a major threat to air quality. 

21 So the American Lung Association offers the 

22 following recommendations to strengthen the stringency 
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1 and the timing of the proposal and to address several 

2 key elements of California's ongoing commitment to 

3 protecting public health, which I know is shared by eh 

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 under 

13 alternative 4 will help drive down emissions sooner and 

14 help move us faster down the road to clean and healthy 

15 air. 

16 Secondly, we urge EPA to immediately begin a low17 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 across 

20 the nation are held to the standards we need to really 

21 protect our citizens from ozone pollution. 

22 California's clean air progress must be protected 
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1 against ongoing interstate truck traffic with higher 

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 South 

9 Coast and San Joaquin Valley that many have discussed 

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 will 

16 miss a critical tool that California needs to protect 

17 public health. In particular, we view battery 

18 electric, fuel cell, hybrid, and other advanced 

19 technologies as vital to achieving the major reductions 

20 needed here in California. Retaining the focus on 

21 advanced technologies will also allow for a stronger 

22 overall standard and greater health and fuel saving
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1 benefits to be achieved. 

2 Lastly, as has been stated by several others as 

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 allow 

10 for increased carcinogenic soot or climate-forcing 

11 black carbon emissions to increase. 

12 In closing, the American Lung Association urges 

13 you to continue on with the rulemaking by strengthening 

14 the proposal with the more rapid implementation of a 

15 stronger standard, beginning a low-NOx standard process 

16 immediately, maintaining a greater focus on advanced 

17 technologies and zero-emission technologies, and 

18 preventing any increase in particle or other pollutants 

19 through the implementation of the rule. 

20 We appreciate the opportunity to speak with you 

21 today and look forward to continuing to work together 

22 with you with our Air Resources Board here in 
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1 California, the local air districts to really continue 

2 the fight that we are all in to protect public health. 

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 continue 

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 or was 

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 also. 

18 The comments I have here were my own. 

19 MR. CHARMLEY: Okay. Thank you. 

20 And I had one question for you. You mentioned I 

21 think you said the agencies appropriately consider if 

22 lower-rolling resistance tires have faster -- you had 
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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 would 

10 have faster replacement requirements, but when they had 

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 that 

16 Utility has information or data that they could share 

17 and submit during the written comment period on that 

18 very issue, either your own experience or the 

19 experience of your customers, on that issue, any data 

20 that you could submit would be very helpful. 

21 Thank you. 

22 MR. BENNETT: Sure. 
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1 MS. AMERLING: Other questions? 

2 MR. SILVERMAN: I have a couple of questions for 

3 Mr. Solomon. If I heard you right, you were suggesting 

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 not 

7 proposing that. So if you could comment to the 

8 specifics of why we indicated we didn't think there was 

9 a basis for that, we would appreciate that, those 

10 specific comments. 

11 MR. SOLOMON: Sure. Yes. We are obviously still 

12 continuing to pore over the details of the rule, but we 

13 will make sure to touch on that specifically in our

14 detailed written comments. 

15 MR. SILVERMAN: In particular, you know, we looked 

16 at average speeds and did not see that there would be 

17 commensurate improvements given the average speed of 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 that 

22 standard should be implemented. We proposed 2018, but 
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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 your 

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, Michelle 

13 Kinman from Environment California, Urvi Nagrani from 

14 Motiv Power, and Jonathan Fleck from Deflecktor Aero 

15 Wheel Covers. Welcome. When you are ready, Bill. 

16 MR. VAN AMBURG: Very good. And I realize that we 

17 are the panel keeping you from lunch. So we will move 

18 with alacrity. 

19 First of all, CALSTART appreciates the opportunity 

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 staffs. 
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1 You have been open in the process as you work with 

2 industry. And we look forward to continuing our work 

3 with you as well as with our stakeholders to finalize 

4 these regulations by next spring, which is a critical 

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 to 

10 grow a clean transportation industry. So that 

11 obviously is our bias. But we definitely support 

12 developing strong, effective fuel economy regulations. 

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 sensitive 

18 to the climate change imperative, but we are also very 

19 focused on the strong fuel efficiency regulations as a 

20 driver of American technology and economic 

21 opportunities that go with it. Many of the advanced 

22 efficient technologies that will be needed will be 
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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 comments 

5 to you -- it is a very thoughtful and, therefore, long 

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 completed 

9 and then some preliminary high-level observations on 

10 the rule. 

11 The new report is titled "Higher Fuel Efficiency 

12 Working for Fleets," and it was built around assessing 

13 what the real business case is from the fleet level for 

14 higher-efficiency trucks that might be driven by a new 

15 high-efficiency rule. We worked with a cross-section 

16 of fleets representing various applications and truck 

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 interesting. 

21 We surveyed fleets for their support for and concerns 

22 about fuel efficiency regulations. And we found, 
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1 interestingly, 87 percent of the fleet managers who did 

2 respond to our survey -- and I am not going to pretend 

3 this was a scientific survey, but of those we worked 

4 with, 87 percent support stronger rules for fuel 

5 efficiency. And their primary concern around it was 

6 cost. They are worried, can we afford to get the 

7 higher fuel efficiency and the benefits that go with 

8 it? 

9 And 89 percent said they would be willing to pay 

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, next13 tier concerns. 

14 Now, using the lifecycle cost model that we 

15 validated with these fleets through this survey and in16 depth conversations we had, we assessed business cases 

17 in seven specific truck use profiles, class 8 tractors 

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 proposing 

22 and generally which we do support. 
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1 We looked at different technology packages that 

2 were most applicable to each use profile. And they are 

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 cost 

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 based 

11 on fleet-validated assessment tools for higher fuel12 efficiency trucks at the levels proposed in your rules. 

13 Indeed, the stringency levels that we modeled in our 

14 report in most cases were actually higher than those 

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 your own 

21 document, were certainly around utilization, mileage, 

22 and fuel used, and the up-front cost of the technology 
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1 being the key variables. And fleets have suggested to 

2 us that they would like to see us model payback 

3 sensitivity to maintenance costs since that is still an 

4 unknown as we go forward. 

5 Now, in shaping the final rule, we believe your 

6 payback projections are actually reasonable and real. 

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 technology 

10 that can provide this efficiency, such as hybrid and 

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 to 

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. Your 

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 a 
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1 market around advanced credits and a streamlining of a 

2 clear off-cycle credit process to make sure that 

3 affordable and achievable efficiency gains do not get 

4 left off the table. 

5 Those are our observations at this time. We will 

6 have much more detail in our written comments, but we 

7 do very much look forward to working with the agencies 

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 the 

14 Vehicle Environmental Regulatory Strategy and Planning 

15 Department at Ford Motor Company. It is a pleasure to 

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 second 

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 working 
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1 closely with the California Air Resources Board in 

2 developing these proposed standards. We are committed 

3 to working with EPA, CARB, and NHTSA to finalize these 

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 truck 

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 very 

12 important to our commercial truck customers. And Ford 

13 has invested in technologies to maintain or even exceed 

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 this 

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 emissions 
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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 greenhouse 

5 gas proposal beyond what the numerical value of the

6 standards alone would suggest. In fact, Ford projects 

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 external 

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 range of 

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. 
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1 That would account for CO2 improvements for 

2 technologies providing on-road fuel consumption 

3 benefits that are not captured by emissions test cycles 

4 or models. 

5 Ford supports the establishment of standards that 

6 recognize the needs of the trucking industry and other 

7 commercial users, increase the use of known technology 

8 found to be feasible and effective in this market 

9 segment, preserve the utility and functionality of 

10 these commercial vehicles while maintaining separate 

11 gasoline and engines targets are compatible with 

12 complexities of the marketplace and avoid unintended 

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 train and 

17 chassis improvements. That being said, Ford does have 

18 concerns with the accuracy of the model for vocational 

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 the 
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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 fully 

4 evaluate the model and will continue to work with EPA 

5 and NHTSA to provide data to support the refinement of 

6 the GEM model. 

7 Finally, Ford recognizes the benefit of the 

8 country for continuing a uniform national program to 

9 address greenhouse gas and fuel efficiency from medium10 duty vehicles and engines. The EPA and NHTSA phase 1 

11 proposal was the first step in providing clarity, 

12 certainty, and flexibility necessary to achieve 

13 greenhouse gas emission reductions that we all share. 

14 The phase 2 proposal builds and expands on this 

15 progress, setting challenging targets for the industry 

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. 
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1 Ms. Kinman, welcome. 

2 MS. KINMAN: Good afternoon. My name is Michelle 

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 America 

7 Research and Policy Center. And, last but not least, I 

8 am a mother living here in Torrance. And I am deeply 

9 concerned about climate change, air pollution, and the 

10 resulting health impacts on our children, especially 

11 those who live, play, and breathe in close proximity 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 gallon 

16 of fuel can curb pollution, help save our planet, and 

17 save money. 

18 We applaud the Obama administration for proposing 

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 step 

22 in the right direction, we urge you to strengthen these 
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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 would 

6 save an additional 200,000 barrels of oil per day in 

7 2035 and avoid an additional 40 million metric tons of 

8 global warming emissions annually according to analysis 

9 by our colleagues at the Union of Concerned Scientists. 

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 improved 

16 aerodynamics on trailers; improvements in heavy-duty 

17 pickup trucks; and more efficient engines and tractor18 trailers; as well as integrating new technology, such 

19 as hybrid and electric drive trains in the heavy-duty 

20 vehicle market. 

21 It is critical that the proposal be expanded to 

22 capture the full suite of cost-effective solutions 
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1 available for each type of heavy-duty vehicle. This 

2 stronger proposal would mean a triple win for clean

3 air, the climate, and consumers. And I urge you to go 

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 comment. 

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. You 

11 are having to listen to a lot of us. And that on its 

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 the 

15 stringency and going towards unnecessary versus 

16 appropriate or inadequate. And there has been a lot of 

17 oscillation depending on whether you are talking to a 

18 business or whether you are talking to an environmental 

19 advocate. I think it is very important to recognize 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 than 
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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 air 

4 quality here. What is considered good today and what 

5 has been considered progressed to date has allowed one 

6 in five children in the San Joaquin Valley to use an 

7 inhaler. 

8 Now, if we consider that a problem, what we have 

9 to face today, then these standards should err towards 

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 way 

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' work, 

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 will 
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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 on 

8 multisource and drayage. Those are meant to address 

9 some of the concerns here about areas like Long Beach, 

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 it 

14 all electric, you would still have port air quality

15 because of these trucks, which don't have a national 

16 standard. 

17 So I urge you to not only go with the standards 

18 being proposed but strengthen them, as many 

19 environmental organizations have supported, because if 

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 not 
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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 garbage 

4 truck. I don't own a work truck. But I breathe the 

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 is on 

15 the streets in Chicago. The first all-electric school 

16 bus in California is on the roads in King's Canyon 

17 taking kids to school today. And all-electric shuttle 

18 buses are driving Google employees around Mountainview. 

19 It is possible for us to do better. And it is

20 possible to make it more costly and expensive to do the 

21 things that are hurting our air today. 

22 Thank you for your time. And I also want to say 
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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 Minnesota. 

7 My company, ADF Limited, brought the Deflecktor 

8 Aerodynamic Wheel Cover, made of fabric, to the market. 

9 Our product is standard equipment on the Freightliner 

10 Cascadia Evolution model long-haul truck, which 

11 receives credits from EPA under the phase I framework. 

12 The smart folks at Freightliner made a series of 

13 tweaks, many, like ours, in the area of aerodynamics, 

14 to their existing 2010 EPA-certified Cascadia, and 

15 created the 2014 Cascadia Evolution, which is a full 7 

16 percent more efficient. 

17 Our product on that truck is visually quite 

18 impactful, as it covers approximately 10 square feet 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, innovative 
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1 technologies that ultimately add value in the big 

2 picture. 

3 A lot of times, we underestimate the incremental. 

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 12 

8 times an hour on trucks in freight lanes across America 

9 on any given day. That number will more than double by 

10 this time next year based on deliveries. 

11 Our first customer, Schneider National, a charter 

12 member of EPA's SmartWay transport partnership, has

13 deployed our product fleet-wide. In a press release, 

14 in March of 2010, Schneider National announced fleet15 wide use of our product on their 12,000 trucks, stating 

16 fuel savings of 150 gallons per truck per year based on 

17 their average fleet speed of 47 miles an hour. This 

18 savings, approximately 1 percent, equates to 40 million 

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 long22 haul segment. Regardless of how we monetize things, I 
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1 am quite proud of that fact as a true measure of value. 

2 Schneider did extensive fuel economy testing over 

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 both 

10 tractor and trailer are equipped on all 8 wheel ends. 

11 Schneider knows the fuel savings are double for a 

12 combination tractor-trailer. Yet, given the ratio of 

13 trailers to tractors, the actual return on investment 

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 efficiency of 

17 long-haul tractor-trailer combinations through this new 

18 phase 2 as it will bring further fuel savings through 

19 trailer efficiency. 

20 EPA, it appears, took the approach to carve up the 

21 combination tractor-trailer into two regulatory phases. 

22 In the first phase, a tractor manufacturer offers a
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1 coefficient of drag for their tractor, which in the

2 case of our product is buried within that number and 

3 not quantified. Yet, it is known to be a significant 

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 coefficient of 

12 drag from the manufacturer for their tractor and then 

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 of 

17 each other, the fuel savings get lost in the margin of 

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 that 

21 would permit testing of both tractor and trailer in

22 combination for the purposes of aerodynamic components 
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1 that can be fitted to both. We believe current testing 

2 methodology is sufficient, albeit misapplied to either 

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 aerodynamic 

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 tractor 

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 found 

14 on both would be helpful to permit aerodynamic wheel 

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 reference 

22 tractor, reference trailer approach, that it is not
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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 trailer. 

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 between the 

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 are 

16 splitting tractor from trailer. We would like to see a 

17 single sentence that would permit tractor and trailer 

18 for this particular aerodynamic component be allowed to 

19 be tested in that way. 

20 MR. CHARMLEY: One question for Mr. Van Amburg. 

21 Bill, a couple of different stakeholders today already 

22 have suggested that the agencies consider bringing back 
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1 or including the phase 2 final rulemaking and credit 

2 multipliers for advanced technologies. And you said 

3 that was something that your organization, presumably 

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 second 

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-term 

11 goal of incentivizing technology but in the very near12 term, you are basically giving up CO2 reductions. Now 

13 that we have had, as I said, two years of experience, 

14 it would be really helpful if members have specific

15 recommendations of did we get it right in the phase 1 

16 rule? Were the multipliers that we proposed there for 

17 EVs and PHEVs and fuel cell vehicles or should it be 

18 some other number? Rather than only just saying, "Hey, 

19 bring them back," if you have any recommendations based 

20 on experience about the appropriate value, that would 

21 be very much appreciated. Thanks. 

22 MR. VAN AMBURG: We would be very happy to do 
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1 that. I think one of the tradeoffs -- and this is why 

2 we talked about stringency. I don't think the credits 

3 have value in the absence of higher stringency. And 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 on 

8 point. It was really great to see all of the thinking 

9 that went into it. I think you have a strong feeling 

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 small 

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 data 

20 with respect to the costs, both near- and longer-term 

21 costs, of some of the advanced technologies, that would 

22 be also very helpful for the agencies. 
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1 Another request to Ms. Williams from Ford, which 

2 mentioned the GEM model accuracy. Obviously that is 

3 crucial for us to get that right. So any information 

4 you have with respect to your products and how they are 

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, panel 

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 

22 
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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 with 

7 MEMA; Daryl Gale with the Union of Concerned 

8 Scientists; and Kirsten James, representing both Ceres 

9 and Dignity Health. So, Mr. Williams, welcome. 

10 MR. R. WILLIAMS: Thank you, I guess. Obviously 

11 people are still coming back from lunch. So we will 

12 get this started here. 

13 Thank you very much for providing this opportunity 

14 to speak today on phase 2: greenhouse gas emissions 

15 standards for fuel efficiency standards for medium- and 

16 heavy-duty engines and vehicles. 

17 I am Raymond C. Williams, here today on behalf of 

18 professional fleet managers of NAFA Fleet Management 

19 Association. I am a NAFA member and the fleet manager 

20 for Gothic Landscape, where I am responsible for 

21 vehicles in California, Arizona, Nevada. Previously, 

22 for 30 years, I was fleet manager for Verizon with 
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1 responsibility for vehicles in California, Texas, and 

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 who 

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 drive 

12 approximately 50 billion miles a year. NAFA members 

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 and 

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, 
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1 emphasizes the economic and environmental benefits of 

2 overall influences of sustainability. 

3 As a fleet manager, I am not opposed to increased 

4 innovation of complexity relative to the fleet industry 

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 with 

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 cost of 

13 phase 2 along with the expected costs of other current 

14 federal requirements. Phase 2 standards are not the 

15 only federal proposal that will add costs to the 

16 complexity of vehicles. A case in point is NHTSA has 

17 proposed for underwriting crash protection of single18 unit trucks. They estimate that it would cost about 

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, must not 
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1 compromise performance, and must recognize the diverse 

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 annual 

8 exercise and depends upon the organization's resources. 

9 When deciding to purchase or lease a vehicle, a 

10 fleet manager first looks at the cost of the vehicle 

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 factor 

14 into making the business case for a vehicle. And no 

15 variable cost is more important than fuel. The 

16 projected payback periods of the proposal are based on 

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 many 

22 have seen, the maintenance costs have increased triple 
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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 system 

4 repair costs from the 2010-2014-related engine emission 

5 complexity. 

6 NAFA urges the EPA and NHTSA to undertake more

7 robust, sensitive analysis with respect to maintenance 

8 and potential scenarios. The proposal and regulatory 

9 impact analysis do not go far enough to looking at 

10 potential maintenance costs. Fleet needs are diverse. 

11 Payback periods of fuel savings vary by use. A case in 

12 point, the duty cycle requirement for a tree-trimming 

13 company may differ from a requirement for an electric 

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 proposed 

18 that a vocational chassis would be presumed to certify 

19 using the multipurpose duty cycle unless certain 

20 criteria are met that indicate that another duty cycle 

21 would be more appropriate. The agency acknowledged

22 that, even within certain vocational vehicle times,
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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 operator 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 Development 

15 for TransPower, based in San Diego County, California. 

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 these 
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1 regulations that has any effect towards the increasing 

2 supply of electric vehicles or zero-emission trucks. 

3 And so we ask that you revisit this rule similar 

4 to work that you have done in the phase 1 regulations 

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 million 

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 back 
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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 Peterbilt, I 

7 invested just short of $95,000 into maintenance and

8 repairs, including an engine rebuild and a transmission 

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 Kenworth 

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. And 

18 that does not include the $6,000 for the warranty or 

19 any of the repairs covered under that warranty, not to 

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 this
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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 the 

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 technology was 

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 few 

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 new 

15 replacement truck, a 2016-model Kenworth of lack 

16 features, cost $167,000. 

17 I had originally planned to pay the 2009 off and 

18 apply the payment amount toward my retirement for the 

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 to 
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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 dealing 

5 with unplanned maintenance and repairs, such as those 

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 provide 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 will 

13 truly benefit them. While the agencies' proposal of 

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, thrusting 

18 unproven technology into the marketplace. This would 

19 result in more truckers choosing to keep their current 

20 trucks on the road even longer. I want to stress the 

21 agencies' approach must allow for ample time for the 

22 OEMs to develop the new technology. 
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1 There are other unmandated alternatives to achieve 

2 good fuel economy. My pre-emissions truck worked more 

3 efficiently, partly due to my driving skills. If those 

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 burned an 

8 extra ten gallons of fuel due to congestion, the point 

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 if 

14 this regulation proceeds without a reality check. The 

15 agencies are seemingly using facts they prefer, with 

16 little regard for the actual burdens it places on small 

17 business operations. 

18 The technology must have durability. That is 

19 crucial for success. We all want a clean environment. 

20 But the question is, is your focus in the right place? 

21 I welcome any questions you may have. And thank 

22 you very much. 
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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 afternoon. 

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 meet 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 agencies 

17 had done tremendous work in setting historic standards 

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 important 
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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 by 

5 2030, global emissions from freight trucks are expected 

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 reductions 

18 in carbon pollution and oil use. 

19 As many have talked about, we support alternative 

20 4. Not only would this alternative reduce oil 

21 consumption and carbon pollution by an additional 13 

22 percent. It would increase net benefits by more than 
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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 only 4.2 

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 it is 

9 critical that the engine standard drive technology 

10 adoption, instead of locking in mediocre improvements. 

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 advanced 

18 technology credits and utilize real-world duty-cycle 

19 data to fully account for the benefits of hybrid 

20 technology. Across the country, manufacturers, fleets, 

21 and states are investing in advanced technologies to 

22 dramatically reduce pollution from freight shipping. 
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1 These technologies, strong hybrids to electric power 

2 takeoff, can significantly reduce fuel consumption and 

3 improve air quality. The agencies should support the 

4 development of these advanced technologies with the

5 phase 2 standards. 

6 Lastly, I would like to applaud the agencies for 

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 engines 

11 used on these vehicles emit substantially greater 

12 amounts of NOx and particulate matter than current 

13 emissions standards allow. Under the proposal, glider 

14 kit manufacturers will no longer be able to exploit a 

15 loophole, leading to more health-threatening pollution. 

16 These proposed phase 2 standards are the result of 

17 years of tireless work by you and your staff. And I 

18 thank the agencies for your work and for all of your 

19 outreach efforts. Once again I applaud EPA and NHTSA 

20 for proposing standards that will lead to cleaner and 

21 more efficient trucks in the years to come. And, as 

22 you move forward, I urge you to strengthen these 
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1 standards to ensure the greatest possible reductions 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 proposed 

13 rule. MEMA and our heavy vehicle supplier member 

14 companies appreciate the engagement with the U.S. EPA 

15 and NHTSA and commend the agencies for their open and 

16 collaborative approach and their receptiveness to 

17 stakeholder suggestions. Collaboration between the

18 government and a wide variety of stakeholders is key to 

19 the success of such a significant and complex technical 

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 and 
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1 efficiency of engines and vehicles. Further 

2 improvements present a set of considerable challenges, 

3 challenges that suppliers are prepared to tackle. 

4 MEMA would like to present the following 

5 preliminary comments and five points. First, comment 

6 period. MEMA recognizes and respects how important it 

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 complex 

11 rule and to provide substantive, useful feedback to the 

12 agencies. Any additional time the agencies can afford 

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 promulgation 

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 attainable 

19 and cost-effective for our customers. Continuation of 

20 a uniform program allows vehicle manufacturers to 

21 continue investing in the technologies vehicles will 

22 need to reach and exceed the phase 2 targets. MEMA
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1 strongly supports sustaining a single nationwide 

2 program. This approach provides regulatory clarity and 

3 is vital to its success. As such, federal and state 

4 agencies must avoid any potential inconsistencies in 

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 meet the 

12 standards, particularly during the middle and latter 

13 stages of the rule. 

14 Third, engine stringencies. Overall, we believe 

15 that the technologies available in the near term and 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 innovation 

19 and technology throughout the phase 2 timeframe. MEMA 

20 and some of our individual members are still evaluating 

21 and working on developing specific suggestions to be 

22 provided in our written comments. 
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1 Fourth, fuel neutrality. MEMA maintains that 

2 instituting performance-based standards is the best way 

3 to ensure that there are no unintended market shifts 

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 and 

7 vans, MEMA proposes an alternative to the proposed rule 

8 that would simply require a 16 percent fleet average 

9 CO2 emissions reduction. Consequently, the industry 

10 and customers pick the fuel and technology combination 

11 that offers the best value while also meeting the 

12 requirements. Moreover, this would make the regulatory 

13 approach similar to the CAFE standards already in place 

14 for light-duty vehicles and provide the attendant CO2 

15 reductions in the most cost-effective, customer16 friendly, and technology-neutral way. 

17 Additionally, MEMA is concerned with the proposal 

18 to exclude gasoline engines from the vocational portion 

19 of the rule and about the potential market impact, a 

20 possibility the agencies have acknowledged in the NPRM. 

21 We believe that regulations that continue to 

22 increase the technical complexity of diesel engines
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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 the 

4 agencies and will address this further in our written 

5 comments. 

6 Lastly, a wide array of technologies have been

7 recognized. MEMA reinforces our appreciation to the 

8 agencies for the scope and scale of their endeavors to 

9 conduct a significant amount of research and data and 

10 offer a proposal that is more representative of real11 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-world 

17 parameters to account for those technologies not 

18 natured under the greenhouse gas emissions model, or 

19 GEM. 

20 Regarding the GEM, MEMA appreciates the agencies' 

21 strategy to address a host of non-power train 

22 technologies in the proposed rule under the model as 
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1 well as in aspects of vehicle and trailer standards. 

2 The broader range of inputs more accurately exemplifies 

3 vehicle performance and provides compliance benefits 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 the 

12 details of the agencies' proposals to address and 

13 account for innovative, off-cycle technologies. And we 

14 will provide more commentary, although one quick point 

15 about the process, MEMA believes that suppliers should 

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 procedures 

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 our 
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1 members continue to closely evaluate the NPRM, and we 

2 are committed to provide more feedback to the agencies 

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 would 

10 like to represent the people who live, work, commute, 

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 grandparents. 

15 This goal can be problematic with the air quality here 

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 American 

19 public has developed this very voracious, commercially 

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, and 
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1 are trucked throughout America, mostly coming through 

2 the two ports here: the Port of Long Beach and the

3 Port of Los Angeles. All of us have the responsibility 

4 to think about our consumer behavior. Changing 

5 behavior and changing new products always costs more 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, and 

9 DVD players first came on the market, they were really, 

10 really expensive. But, as more and more people bought 

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 people 

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 know 
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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 bad it 

4 was. And, just recently, we found out how critical it 

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 truck 

9 effluent, complement the great strides, the Port of

10 Long Beach and the Port of L.A., have done in cutting 

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 organizations, 

17 Ceres and Dignity, and who will provide comments 

18 separately for each. 

19 MS. JAMES: Great. Good afternoon. My name is 

20 Kirsten James, and I am with Ceres' California office. 

21 Our organization's mission is to mobilize investors and 

22 business leaders to build a thriving, sustainable 
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1 global economy. 

2 Briefly, to just provide a little bit of context 

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 advocacy 

9 coalition of leading businesses committing to working 

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 action to 

15 address fuel efficiency and GHG emissions associated 

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 proposed 

19 phase 2 standard under consideration today by adopting 

20 a standard requiring a 40 percent reduction in fuel

21 consumption by 2025. Alternative 4 comes closest to 

22 that standard. Strict standards will catalyze 
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1 investment in high efficiency truck technologies, 

2 thereby serving to retain the U.S. leadership position 

3 in this sector, save businesses money, promote energy 

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 would 

13 reduce freight costs by 3 percent in 2030 and 7 percent 

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 that 

19 sector. We are currently the world leader in the 

20 development, production, and use of energy-efficient 

21 and hybrid trucks. Without strong standards in place, 

22 companies and investors will lack the requisite 
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1 certainty to invest in the development and production 

2 of new technologies that will allow us to retain our 

3 primary position and increase job growth. 

4 Ceres agrees with the California Air Resources

5 Board, which recommends the adoption of the Alternative 

6 4 standards at a minimum, stating this option is both 

7 technology forcing and technologically feasible. 

8 Companies in a variety of sectors are increasingly 

9 interested in tracking scope 3 emissions, including GHG 

10 emissions associated with transportation and freight 

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 that 

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 products 

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 standards 

22 requiring a 40 percent reduction in fuel use by 2025. 
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1 Such technology-forcing standards would drive 

2 innovation, catalyze investment in high-efficiency 

3 truck and supplier manufacturing, as well as promote 

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 speak 

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 behalf. 

15 On behalf of Dignity Health and over 400 care 

16 centers, including hospitals, urgent and occupational 

17 care centers, imaging centers, home health, and primary 

18 care clinics, we commend the agencies for taking action 

19 to address the fuel efficiency and GHG emissions for 

20 medium- and heavy-duty trucks. We strongly support the 

21 adoption of regulations requiring a 40 percent decrease 

22 in fuel consumption by 2025. 
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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. Strong 

4 phase 2 standards offer a rare opportunity to address 

5 serious health concerns associated with climate change 

6 and cut freight costs. Strict standards will provide 

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 poses 

11 significant health risks to Americans across the 

12 country. Freight trucks currently account for about 

13 half a billion tons of climate-forcing GHG emissions 

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 the 

17 opportunity to improve air quality and increase related 

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 in 
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1 heavy truck fuel consumption by 2025. 

2 Thank you for your leadership on this important 

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 stated 

8 that some of your members would like to be afforded the 

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 have 

14 it validated and certified by EPA through the public 

15 process. All we would like is the opportunity to also 

16 be able to do that. It is a repeat of a comment that 

17 we made under the phase 1 as well. 

18 MR. GRUNDLER: But with respect to a particular 

19 component, as opposed to a vehicle? 

20 MS. MERINO: Oh, I think it would probably depend. 

21 I think we are still vetting and going through all of 

22 the different aspects of the off-cycle innovative 
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1 section. 

2 MR. GRUNDLER: Okay. 

3 MS. MERINO: And so I wasn't prepared to express 

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 really 

15 matters in terms of its performance. So if when you 

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 back 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 there 
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1 are other things outside of standards that can result 

2 in improvements in CO2, including driver education,

3 driver training. And we have done some of those things 

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 Kenworth, 

7 they, must have both been manuals. 

8 MR. CURL: Oh, yes. 

9 MR. CHARMLEY: Yes, exactly. One of the things 

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 are 

14 performance-neutral, we have projected that AMTs may be 

15 a technology that more and more at least fleets might 

16 go to to help them with driver sort of making not-so17 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 con. 

21 So for every benefit, I can show you a down side. For 

22 every down side, I can show you a benefit. An 
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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 would 

6 be a large benefit to have any kind of thing you can to 

7 help avoid the mistakes. But the issue goes back to 

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 your 

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 experience. 

14 In my former job with Verizon, we had a lot of over15 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 driver 

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 just
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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 proven 

7 to run well over a million, you know, a million and a 

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 of 

12 technologies, how they have a benefit on one end, they 

13 are disadvantaged on the other end because they also 

14 create down time over the life span of the equipment. 

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 panel, I 

20 just want to make an announcement that those of you who 

21 were originally slated for panels 12 or later have now 

22 been moved up in the schedule to keep the panels full. 
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1 So please keep your eye on the board there, the screen, 

2 for updates to the schedule. Thank you. 

3 MR. GRUNDLER: Thank you. 

4 I would like to invite panel 9 up to the table and 

5 invite panel 10 to move over to the staging area. With 

6 us today from panel 9 is Rasto Brezny from MECA; Nidia 

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 Climate 

10 Resolve. Welcome, everybody. Rasto, when you are 

11 ready? Thank you. 

12 MR. BREZNY: Thank you. Good afternoon. My name 

13 is Rasto Brezny. I am the deputy director of the 

14 Manufacturers of Emission Controls Association. MECA 

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 technologies 

22 from mobile sources. The portfolio of products offered 
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1 by our members has expanded beyond exhaust catalysts 

2 and particulate filters, to include technologies that 

3 impact combustion efficiency and improve the overall 

4 CO2 emissions of the power train. 

5 We will submit detailed comments by the deadline. 

6 However, today I would like to focus on a few specific 

7 aspects of the proposal. MECA strongly supports the 

8 continued use of separate engine and vehicle standards. 

9 This framework, established under the phase 1 heavy10 duty standards, ensures the important testing linkage 

11 between engine criteria and greenhouse gas emissions 

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 alternative 

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 reductions. 

20 MECA supports EPA's proposal to lower the cap on 

21 N2O emissions by 50 percent. This titer N2O cap, at 50 

22 milligrams per brake horsepower hour, will be 
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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 N2O 

5 emissions at low levels. These include improved 

6 catalyst formulations, ammonia slip catalysts with high 

7 selectivity for nitrogen formation, and efficient use 

8 of urea dosing strategies. 

9 We also support the proposal to close the current 

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 power 

17 units should be controlled through the application of 

18 proven diesel particulate filter technology. There are 

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-effective 
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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 be 

5 possible through the combination of advanced diesel

6 engines and evolutionary, not revolutionary, 

7 improvements to the existing suite of diesel exhaust 

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 nearly 

12 15 years ago. The current technologies will continue 

13 to advance by including I-cell density; low thermal

14 mass substrates; improved SCR catalysts, coded directly 

15 on particulate filters; and next generation oxidation 

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 optimize 

20 for both low NOx emissions and improved fuel 

21 efficiency. And we believe that these optimizations 

22 can continue in the future to further reduce both CO2 
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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 technologies 

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 emission 

10 performance and low-temperature duty cycles. These

11 technologies will, in turn, facilitate the reduction 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-sponsored 

19 modeling study using MOVES2014 estimated the NOx 

20 reduction benefit of a national .02-gram federal heavy21 duty NOx standard. When fully implemented, such a 

22 program would deliver 266,000 tons per year, or 730
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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 will 

4 further reduce NOx emissions from heavy-duty engines 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 for the 

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 proposing 

20 standards that will make our freight trucks cleaner and 

21 more efficient. While the proposed standards are a

22 good first step, I urge you to strengthen these 
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1 standards to ensure the greatest reductions in oil and 

2 global warming emissions. I am not just a concerned 

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 million 

8 Americans, including 7 million children who currently 

9 suffer from asthma. Warmer temperatures promote the 

10 production of harmful ground-level ozone, a known 

11 asthma trigger. Climate change is expected to increase 

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 climate 

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 significant 

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 have 
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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 in 

7 standards. Despite reductions in toxic pollutants and 

8 strong standards, which are vital for California and 

9 the whole country, we have to invest in clean heavy10 duty trucks to achieve both greenhouse gas reductions 

11 and federal air quality standards attainments. They 

12 can give the same investment. And it doesn't make 

13 sense to do it twice. 

14 We cannot reach attainment of federal standards in 

15 Los Angeles region or the San Joaquin Valley without 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 in
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1 California. EPA should adopt this regulation 

2 expeditiously. And it should also initiate a separate 

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 stronger 

8 standards that reduce trucks' fuel use by 40 percent 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 general 

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 efficient, 

22 safer semitrailer, something completely consistent with 
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1 the phase 2 objectives, but most of what you hear today 

2 is about the truck, not the trailer. 

3 So, for that reason, we ask that you modify your 

4 proposal as published in four ways that reflect the

5 nature of the semitrailer industry. First, the trailer 

6 industry is an exceptionally competitive, low-margin 

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 needs 

12 in a reliable, cost-effective way, they won't purchase 

13 the trailer. This reality leads to the following three 

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 the 

18 trailer owner to have certain fuel-efficient equipment 

19 on its trailer. The customers then would demand that 

20 the manufacturers installed the equipment on the 

21 trailers they purchased. 

22 Next, the final rulemaking should encourage 
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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 bin 

5 and averaging approach in favor of requiring all van 

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 imposed by 

10 the bin and averaging approach. It will also avoid

11 large purchasers attempting to game the system by using 

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 trailer 

19 certifying that the trailer meets all relevant DOT 

20 requirements. We do that successfully every day, and 

21 it works. A similar approach would be useful here.

22 Second improvement, maintain flexibility in 
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1 out-year requirements. The proposed rulemaking 

2 regulations become increasingly stringent by 2027. We 

3 understand that it is impossible to forecast the state 

4 of the transportation industry a dozen years from now, 

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 meet 

8 those proposed for 2027. Of course, like you, we 

9 anticipate advances in technology, but we believe it 

10 appropriate to delay establishing standards so far in 

11 the future until the agency and industry have a better 

12 grasp on what the transportation industry looks like as 

13 it embarks on the second quarter of the Twenty-First 

14 Century and on what improvements can be made safely and 

15 economically and on a cost-justified basis. 

16 Third, adopt realistic exemptions for classes of 

17 equipment where there is no cost-benefit justification 

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. 
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1 These trailers spend most of their lives on local 

2 roads, obeying local speed limits. They may travel on 

3 the crowded urban freeways for short distances, but

4 most of their travel is well below 50 miles per hour. 

5 The benefit of aerodynamic devices on these trailers is 

6 negligible. And some of the devices are incompatible 

7 with specifications routinely and necessary in the 

8 industry and are likely to be damaged in use. There is 

9 no reason to impose the cost of these devices on these 

10 trailers. 

11 Additionally, some of the devices reduce 

12 productivity through increased weight and cost. This 

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 made 

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 in 

22 kits. To ensure maximum benefit from your regulations, 
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1 they must apply to all trailers. In its rules 

2 regulating ozone-depleting fluorocarbons used to 

3 manufacture insulating foam in refrigerated trailers, 

4 the EPA did not regulate foreign-manufactured trailers. 

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 in 

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 opportunity 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 citizen 

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 of 
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1 regulations to improve efficiency and reduce emissions 

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 about 

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 that is 

10 climate change caused by global warming. The science 

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 great 
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1 effort, but it will take an enormous and complex set of 

2 circumstances to do that. The proposed standards we 

3 are dealing with here are a small but very important 

4 part of a challenge like this. 

5 Administration's proposals are a good first step, 

6 but the UCS and other organizations, as I have heard 

7 today, have shown that they can be strengthened. They 

8 have analyzed this issue in detail and made specific 

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 faster 

13 than the administration's proposed goal to date, at any 

14 rate, of 36 percent reduction by 2027. 

15 Achieving the UCS target would mean an additional 

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 reduced. 

22 Truck owners insofar as the technology is successful, 
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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 cost5 effective. And in the UCS' recommended scenario, the 

6 reduction in fuel cost alone is likely to pay big rig 

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 strongly 

15 support strengthening these standards, achieve the 40 

16 percent fuel consumption reduction by 2025 that the UCS 

17 and others have shown to be possible. It can be done. 

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 am 
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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 the 

6 rule. I would like to express my support for the phase 

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 cost 

12 of ownership benefits for fleet operators over the life 

13 of the vehicles. My concern is that I do not believe 

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 regulations 

20 in combination with incentives for advanced technology 

21 adoption. The current stringency levels require a 25 

22 percent reduction in stringency levels over the 2010 
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1 baseline by 2027 for vocational vehicles, the category 

2 where most electric vehicles will be deployed. 

3 It is our belief that this stringency level in and 

4 of itself will not result in fleet operators investing 

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 consider 

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 that 

18 are committed to sustainability and are eager to adopt 

19 clean technologies. Incentives could include vouchers, 

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 early
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1 stage of technology development, both in generating

2 interest among fleets and improving the performance and 

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 already 

10 been made in the bus markets. And, as a result, 

11 current electric buses are priced at only a 60 percent 

12 premium over diesel buses, a premium at which the fuel 

13 and maintenance savings result in approximately a 3-

14 year payback and a favorable total cost of ownership. 

15 We believe a similar achievement is possible in 

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 during 

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 investing 

22 in large-scale manufacturing for batteries, inverters, 
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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 Fink, 

15 and I am the director of campaigns for Climate Resolve. 

16 We are L.A.'s climate advocacy organization based in 

17 downtown Los Angeles, and we are focused on creating 

18 real, practical solutions to meet the climate challenge 

19 while creating a better region for all Southern 

20 Californians today and in the future. 

21 First of all, we applaud the administration and 

22 EPA for proposing standards that will make our freight 
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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 that 

7 both prevent future climate change and help us prepare 

8 for expected impacts. Not only will more fuel9 efficient heavy-duty trucks directly reduce greenhouse 

10 gas emissions, leading to a reduction in long term 

11 atmospheric warming, but there are numerous benefits 

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 Southern 

16 California will warm four to five degrees in the middle 

17 part of this century and the number of extreme heat

18 days -- that is days of 95 degrees and above -- will 

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 Fahrenheit 

22 by the end of the century. However, with strong 
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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 weather 

9 events combined. There is also a strong correlation 

10 between heat and ground level ozone formation, meaning 

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 means 

19 roads, rooftops, playgrounds, et cetera; lack of 

20 vegetation; and exhaust from automobiles, trucks and 

21 manufacturing. Therefore, the standards being 

22 discussed today, which will drive down heavy-duty truck 
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1 emissions, can play a significant role in helping us 

2 cool our cities and make us more resilient in the face 

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 and 

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 written 

15 comments on the proposal -- and we hope that you would 

16 submit written comments -- that you could provide based 

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 the 
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1 gentleman from Utility. Mr. McNamara? 

2 MR. McNAMARA: Yes? 

3 MR. CHARMLEY: One question for clarity. Do you 

4 and Mr. Bennett, who testified earlier, both work for 

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 -- about 

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 get 

16 out to 2027, maybe it is not quite as certain. So I 

17 would certainly encourage the company in their written 

18 comments or if you can clarify now -- you know, the

19 proposal has 4 steps: '18, '21, '24, and '27. Were 

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 that 
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1 you wanted us to maintain flexibility? 

2 MR. McNAMARA: Well, first of all, I do not want 

3 you to confuse me with an engineer. All right? But 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 to 

8 where the crossover point is. 

9 I can tell you that from 2018, given the formula, 

10 the performance measurements that we have for the 

11 technologies, we believe we can do 2018. We know those 

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, though. 

15 MR. CHARMLEY: That would be very appreciative. 

16 Thank you. 

17 MR. GRUNDLER: Thank you, panel. You are excused. 

18 MS. AMERLING: I would like to invite the next

19 panel up to the table. This panel includes Jack Gillis 

20 with Consumer Federation of America, Edward Lovelace 

21 with XL Hybrids, Charles Irvin Drew with Union of 

22 Concerned Scientists, Brett Barry with Clean Energy
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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 expert. 

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 here 

14 today to participate because we are very concerned that 

15 consumer economic issues be fully considered when this 

16 standard is promulgated. 

17 When it comes to goods and services, the American 

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 big 
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1 truck fuel is almost as much as they spend for home

2 electricity and about half of what a typical household 

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 that the 

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 proposed 

14 standards. 

15 The bottom line, consumers get it. As our surveys 

16 show, they understand that they pay the freight when 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 industry. 
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1 With the average household spending over $1,100 on 

2 consumer goods and services to cover the costs of fuel3 inefficient trucks, we estimate that implementing these 

4 standards will put about $200 back into household 

5 budgets every year. This results in a national savings 

6 of a whopping $170 billion. And these billions 

7 represent money that will contribute to strengthening 

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, with an 

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 these 

21 standards are and want them to go into effect. 

22 In addition to the significant consumer benefits 
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1 of the proposed new standards, there are other strong 

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 big 

5 truck energy savings technology far outweigh the costs. 

6 In the first eight years, the payback for a typical

7 tractor-trailer will be five times the cost, and these 

8 vehicles are on the road substantially longer than 

9 eight years. We will be using this cost-benefit ratio 

10 to further refine the financial benefits to households. 

11 In addition, these standards will address the 

12 market imperfections that cause the underinvestment in 

13 energy savings technology. These market imperfections 

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. Performance 

18 standards are an excellent tool to reduce or eliminate 

19 these market imperfections. 

20 While others have made strong environmental and 

21 industry economic arguments regarding the benefits of 

22 the proposed rule, CFA believes that the consumer 
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1 economic benefits will be in the billions. And we look 

2 forward to demonstrating why these standards are needed 

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, EPA 

6 and NHTSA. Your proposal is considered, collaborative, 

7 thoughtful, and has great potential." Now, maybe it 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 great 

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 their 

16 chief technology officer. At XL Hybrids, we are very 

17 appreciative of the efforts of the federal government 

18 team in developing the phase 2 draft rules and agree 

19 with the basic principles and structures that have been 

20 proposed. And, as currently proposed, we support the 

21 preferred alternative. 

22 By way of introduction, XL Hybrids is currently a 
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1 leading fleet electrification company in the U.S. with 

2 as of May this year over 12 million fleet customer 

3 miles per year driving our products all across North 

4 America. Our core hybrid electric up-fit products for 

5 class 2 to 6 vehicles provide roughly 20 percent fuel 

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 the 

9 major OEM vehicle and power train. And so major fleets 

10 can buy and service the same major OEM vehicles with 

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 vehicles, 

15 which has an attractive payback today for fleets that 

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 apply to 

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 cost
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1 models in the regulatory impact analysis table 2-100 

2 for mild and strong hybrids does not appear to account 

3 adequately for the highly specialized manufacturing

4 cost and scaling that is unique to the lithium battery 

5 market. I have more detailed comments in the written 

6 portion. 

7 Moving on to number two, the projected incremental 

8 cost for the heavy-duty pickup and vans, strong and

9 mild hybrids, seem a little bit low. The heavy-duty 

10 pickup and van strong and mild hybrid cost projected in 

11 RIA tables 2-179 and 2-183 are based on weight scaling 

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 significant 

17 factor there. 

18 And, most importantly for us, item 3, we recommend 

19 expanding the trading compliance paths for additional 

20 flexibility to allow major OEMs to take advantage of 

21 the fuel and emissions savings technologies deployed by 

22 third party up-fitters, like ourselves. 
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1 After a complete road-worthy, heavy-duty vehicles 

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 which 

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 are 

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 agencies 

16 are prevented from measuring and assigning credits to 

17 third party products that produce measurable, robust, 

18 documentable savings that could then participate in a 

19 compliance credit marketplace. In XL Hybrids' current 

20 business model, our savings right now would primarily 

21 benefit just the end fleets when they could also be

22 contributing in the phase 2 regulation goals. The 
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1 benefits to the public would be a more market-driven 

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 such 

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 the 

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 fuels 

21 that we burn today have been buried underground for 200 

22 to 250 million years. And the energy from petroleum 
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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 changing 

9 the Earth dramatically and radically. 

10 Simple chemical mathematics shows that a gasoline 

11 engine that burns 110 gallons of fuel produces 1 ton of 

12 CO2. Because of a slight difference with diesel and 

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, goes 

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, increasing the 

20 ocean acidity. 

21 The molecules of CO2 that enter the atmosphere

22 will stay in the atmosphere and warm the Earth for 
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1 almost 500 years. That is 25 generations. The warming 

2 of our atmosphere is leading to a horrific consequence 

3 for humans. And as the sea levels rise, stronger 

4 storms and changes in the precipitation will lead to 

5 flooding in some areas and drought in others. 

6 The carbon dioxide that enters the ocean combines 

7 with water to form carbonic acid. This is increasing 

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 that 

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 that it 

16 goes down the road. Many rigs are driven 100,000 miles 

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 373 

20 tons of CO2 per year. That is over 9 times the weight 

21 of the loaded truck based on a 40-ton rig. 

22 Strengthening the fuel economy standards will 
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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 the 

7 standards leading to a 40 percent reduction of fuel use 

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 savings 

11 of both costs and carbon emissions that we must achieve 

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 standards 

16 for trucks. Every effort to slow the burning of carbon 

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 you 
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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 natural gas 

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 technology 

10 towards near-zero emissions performance. 

11 We applaud EPA's and NHTSA's development of the 

12 proposed rule, which continues the important work of 

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 ultimate 

17 objective. Specifically, we appreciate the continued 

18 allowance of cross-pollutant trading of CH4, N2O, and 

19 CO2. 

20 The rule also provides consistency. Continued

21 utilization of the 100-year global warming potential of 

22 25 for CH4 provides a standard metric across the full 
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1 array of light-, medium-, and heavy-duty vehicles as 

2 well as other agency rules governing greenhouse gas

3 emissions. New territory is being blazed as the rule 

4 proposes to regulate additional aspects of natural gas 

5 vehicles, which will ensure NGBs are providing their 

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 engine 

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 our 

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 engines 

21 within the final rulemaking, much like the one being 

22 proposed by the California Air Resources Board. 
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1 While Clean Energy does not currently have a 

2 formal position on this proposed addition to the rule, 

3 we are very proud of our industry's tradition in 

4 delivering optional low-NOx performance well in advance 

5 of competing combustion technologies. Specifically, 

6 Cummins Westport has recently announced its plans to 

7 deliver a nine-liter engine available to the market

8 that meets a .02-gram per brake horsepower hour limit 

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 product 

12 line as early as Q2 2017 if they receive onboard 

13 diagnostic flexibility from the Air Resources Board and 

14 additional R&D funding from local and state agencies. 

15 Of course, the natural gas industry is not only 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 emissions 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 incentive to 

22 produce renewable natural gas on par with other 
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1 cellulosic fuels. 

2 In conclusion, further greenhouse gas reductions 

3 from renewable natural gas, which is an ultra low4 carbon fuel, have proven to be the lowest carbon fuel 

5 source for heavy-duty class 7 and 8 trucks, 

6 outperforming both electric and fuel cell strategies. 

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 and 

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 handle 
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1 our company's municipal approach for the major markets 

2 in California. 

3 California is leading the U.S. in a transformation 

4 of the transportation sector. The results are 

5 encouraging on the passenger transport side, where a 

6 trend towards decreasing fuel consumption and emissions 

7 is visible. 

8 For freight transport, the picture is less clear. 

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 has 

13 been achieved for passenger transport. 

14 The challenge of freight emissions goes beyond the 

15 current consumption. The California Air Resources 

16 Board's most recent forecast showed GHG emissions from 

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. 
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1 Globally, GHG emissions from heavy-duty vehicles are 

2 growing rapidly and are expected to surpass emissions 

3 from passenger vehicles by 2030. 

4 Shifting freight to other modes, such as upgraded 

5 rail systems, may play a part of the solution. That 

6 said, road freight is anticipated to remain a large

7 part of the transport system. 

8 To achieve the general goals of cutting petroleum 

9 use and GHG reduction, it is imperative that freight 

10 trucks are put on the path toward zero emission. 

11 Strong zero-emission goals are also important in giving 

12 air quality-focused businesses the certainty that they 

13 need for long-term planning. This is necessary, both 

14 for technology users and also for companies developing 

15 solutions when they make investment decisions. 

16 Given the goal of California to generate 50 

17 percent of electricity from renewable sources as well 

18 as federal plans for decarbonizing power generation, it 

19 makes sense to find efficient ways to make this clear 

20 energy available to heavy-duty trucks. 

21 The electromobility offers a variety of benefits, 

22 including improved local air quality and the increased 
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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 storage 

4 of electrical energy. This problem can be solved by 

5 providing power to the truck as it is driving through 

6 an overhead catenary system. These catenary solutions 

7 are currently being built to be demonstrated on public 

8 roads. For example, the Swedish Transport Authority 

9 has recently announced two demonstration projects in 

10 June of this year, including an OCS system being built 

11 by Siemens. 

12 In Germany, Siemens is also operating a private 

13 road, 1.2-mile OCS, freight truck test track. This led 

14 German authorities to study the technical feasibility 

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 field 

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 with 
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1 Siemens near the Ports of Los Angeles, Long Beach, and 

2 the City of Carson, California. Construction of this 

3 project involves vehicles of several different trucks, 

4 one of which is being provided in collaboration with 

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 logistical 

9 centers. 

10 Much of California's road freight is concentrated 

11 on road freight corridors, whether it be the I-710, the 

12 I-5, highway 60, all of which help form the backbone of 

13 California's freight network. Instead of seeing 

14 freight emissions as a difficult challenge, we would 

15 like to view this as a golden opportunity. 

16 Siemens welcomes the focus by federal and local 

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 thank 
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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 considering 

12 multiple views across the industry. We also appreciate 

13 the 10-year timeline through 2027 and the 3-phased 

14 approach because it provides the industry with clear 

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 and 

22 medium-duty and vocational truck portions of the 
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1 proposal. 

2 We appreciate that revised weighting factors for 

3 the SET cycle CO2 emissions for the heavy-duty tractor 

4 engine standards have been included in the proposal. 

5 These revised weighting factors better represent real6 world operating conditions of long-haul trucks with

7 minimal additional complexity. However, the new 

8 weighting factors effectively represent a regulatory 

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 to the 

12 actual engine. This essentially means that 2021 model 

13 year engines only need to be .5 percent more efficient 

14 than the 2017 baseline, a .12 percent per year 

15 improvement over a 4-year time period. This is well 

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 emissions 

19 reduction levels. 

20 For this reason, we believe there is room to make 

21 the engine-level CO2 reduction larger than is reflected 

22 in the current proposal, without the need for 
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1 widespread adoption of advanced technologies like 

2 Rankine Cycle waste heat recovery. Honeywell can help 

3 provide data and work with the EPA to refine the inputs 

4 to models to better reflect the improvements that air 

5 systems technology can provide in order to enable this. 

6 Additionally, we believe the new regulation should 

7 be technology-neutral, setting standards that everyone 

8 must meet, without favoring one approach over another. 

9 Fuel neutrality is critical to ensure that the proposed 

10 rule could be met in the most cost-effective manner for 

11 industry and consumers. We are, therefore, concerned 

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 improve 

16 fuel efficiency by 16 percent from the 2017 baseline 

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 vehicles 

20 will be able to achieve their required decrease in fuel 

21 consumption at lower cost and complexity than diesel 

22 engine vehicles, resulting in a shared shift towards 
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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 industry 

5 and consumers to pick the fuel and technology 

6 combination that offers the best value while meeting 

7 this requirement. 

8 The current proposal also excludes gasoline 

9 engines from the medium-duty and heavy-duty vocational 

10 portion of the phase 2 regulation. The cost 

11 differential between diesel and gasoline engines has 

12 increased substantially over the past ten years as 

13 diesel engines have adopted advanced technologies to 

14 meet more stringent NOx and PM regulations. This has 

15 made diesel engines less competitive on initial cost, 

16 and the industry has seen a steady increase in the 

17 market share of gasoline engines in class 3 through 5 

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 for 
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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 in 

5 our written comments and will provide further 

6 supporting documents. 

7 Honeywell supports continued efforts to keep the 

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 feasible 

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. 
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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 automotive 

6 and 5 of the 6 largest global heavy vehicle original 

7 equipment manufacturers to support product development 

8 in the area of aerodynamics, thermal management, and 

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 simulation 

17 capabilities exclusively for aerodynamic and cooling 

18 designs without the use of physical prototypes, such 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 that 

22 computational fluid dynamics, also known as CFD, will 
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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 other 

5 test methods, including the full- and reduced-scale

6 wind tunnel testing, SAE type II fuel economy testing, 

7 coast-down testing, constant speed aerodynamic testing, 

8 and full-scale drag meter testing. Thus, the decision 

9 to certify the use of CFD for the regulation of 

10 greenhouse gas and fuel efficiency will fit well within 

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 allowed 

17 methods, coast-down, wind tunnel, and simulation, but 

18 also within these tools themselves. For example, wind 

19 tunnel drag coefficients are highly dependent on the 

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 tunnel 
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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 simulated 

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 factor 

11 for alternate tools, will alleviate these challenges 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-road 

16 physical testing requires accounting for many specific 

17 details of the test setup that are not representative 

18 of the on-road conditions. CFD offers the advantage 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 the 
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1 open road, including a moving ground, rotating tires, 

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 for 

9 producing results that are representative of on-the10 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 to 

15 less aerodynamic day cabs. In the proposed program, 

16 the coast-down method is a proposed standard to measure 

17 the vehicle aerodynamic performance. However, we feel 

18 this test procedure does not relate closely to real19 world fuel efficiency. 

20 Since these types of vehicles experience 

21 significant changes in aerodynamic drag with relatively 

22 small changes in wind, a better predictor of real-world 
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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 it is 

7 imperative that wind effects be part of the standard 

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 truck 

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 adjusting the 

18 coast-down results through the use of alternate tools 

19 for when they have the drag. We feel, as stated above, 

20 that the variations of wind average drag between the 

21 tools and facilities themselves is too significant and 

22 it would be an adverse consequence to allowing 
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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 important 

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 world 

14 are watching this rulemaking in other governments to 

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 regard. 

18 The agencies have done a great deal of excellent 

19 work in exploring how standards for medium- and heavy20 duty vehicles could operate in preparing this program 

21 for public review. We believe that the proposal can 

22 and should address standards that promote real-world 
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1 fuel savings. Our nation has the opportunity with 

2 these regulations not only to reduce the greenhouse gas 

3 emissions but also stimulate the engineering innovation 

4 and, thus, job growth. This can be achieved by making 

5 sure that the regulations are providing accurate means 

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 to 

11 example of other nations. And this would help reduce 

12 global greenhouse gas emissions. 

13 We are excited to actually help this effort with 

14 the unique technology we developed over the last two 

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 partners 

18 in industry to helping them design vehicles with better 

19 aerodynamic performance and considerably reduce the

20 emissions. We also look forward to helping the EPA and 

21 NHTSA achieve these goals. 

22 Thank you. 
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1 MS. AMERLING: Thank you very much. 

2 We will turn now to Dorothy Kelty. 

3 MS. KELTY: Good afternoon. I am Dorothy Kelty. 

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 standards 

8 available to you for trucks serving our local harbors. 

9 These two ports receive half of all the cargo shipped 

10 from Asia into the United States. Most of this cargo 

11 leaves our ports on trucks headed all over the United 

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 inch 

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 from 

20 idling trucks and refineries that produce the fuel. 

21 The result will be $37 billion in public health and

22 welfare benefits. 
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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 possible by 

5 setting a target of 40 percent improved efficiency by 

6 2025. 

7 I can remember as a child not being able to see 

8 the beautiful San Gabriel mountains or even the corner 

9 of my one-block street many times in San Gabriel. You 

10 brought us so far. We know that strong standards can 

11 improve our quality of life. We have seen it done 

12 before. It is a win for our planet, our state, and our 

13 citizens' health. 

14 Thank you so much. 

15 MS. AMERLING: Thank you very much. Are there any 

16 questions for this panel? Bill? 

17 MR. CHARMLEY: Just one question for Mr. Lovelace. 

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 saying 

22 that directionally we underestimated the impacts of
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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. Those 

6 seem too low. 

7 But in terms of implying back to what that means 

8 in terms of the cost learning curves, you know, I read 

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 needs to 

14 get the quite tremendous scales before you see really 

15 measurable reductions. 

16 So, honestly, it is not the total dollar levels. 

17 It is the shapes of the curves are to me not 

18 specifically applicable to hybridization, applicable to 

19 the other categories. 

20 MR. CHARMLEY: Okay. Thank you. 

21 MR. LOVELACE: Sure. 

22 MS. AMERLING: Steve, did you have a question?
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1 MR. SILVERMAN: A couple of questions. First off, 

2 I want to commend Mr. Lovelace for slogging through the 

3 RIA. I am sure if you had any insomnia difficulties, 

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 averaging 

8 sets; for example, just within 2B's and 3's or across 

9 categories. Could you clarify that, please? 

10 MR. LOVELACE: Yes. And my expectation is this is 

11 going to take more follow-up. The basic point is that 

12 a company like us plays outside the regulation. And so 

13 we are looking for additional flexibility and basically 

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 neither do 

18 the major OEMs the way it is currently structured. So 

19 that was the major point that I was trying to get at 

20 there. 

21 MR. SILVERMAN: Thank you. 

22 And one further question to you and also to Mr. 
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1 Rodriguez, if you could. Any preliminary position on 

2 certification mechanisms for hybrids, either the ones 

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 various 

8 other organizations that have testified today. 

9 MR. SILVERMAN: Okay. 

10 MR. D. RODRIGUEZ: I have got, I think, the second 

11 question. 

12 MR. SILVERMAN: Yes. 

13 MR. D. RODRIGUEZ: So I would kind of echo that 

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 detailed 

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 standards, 
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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 you 

4 could address that in your comments as well, please? 

5 MS. AMERLING: I think that wraps up this panel. 

6 Many thanks to the members of this panel. And we will 

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 citizen 

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 Effenco, 

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 you 

17 for the opportunity to testify here today. And I would 

18 also like to thank your staff for allowing me to move 

19 to the head of the line because I have an engagement I 

20 have to get to and get on the freeway right away. 

21 My name is Joe McLaughlin. I am a retired teacher 

22 from Huntington Park High School. I worked there for 
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1 42 years. Huntington Park High School is situated 

2 about one mile from the Alameda corridor and sits equal 

3 distance between the Harbor Freeway and the Long Beach 

4 Freeway. So we got a highly concentrated dose of Los 

5 Angeles air. 

6 I would like to thank you for bringing in some

7 regulations that have improved that quality. I wish 

8 you could do something with the Farmer John 

9 Slaughterhouse that is right in the neighborhood also 

10 because that certainly affects the air quality in the 

11 area. 

12 Being a lay person, I am a little in awe of the 

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 pale in 

16 comparison. So, instead of making that type of a case, 

17 I would like to bring to the floor the duty that you 

18 have as the Environmental Protection Agency. And the 

19 environment that you protect is what I live in, what my 

20 children live in, and what my grandchildren live in. 

21 And I can tell from some of the testimony here that you 

22 are certainly aware of the threat that our environment 
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1 is under, posed by the global warming that is taking 

2 place. 

3 So what I would like to do is just encourage you 

4 to take the leadership and responsibilities that you 

5 have to protect the environment for all of us, to move 

6 as swiftly and as courageously as you can to put in the 

7 strongest regulations possible because an awful lot is 

8 depending on that. 

9 And I know that you are on the forefront, right on 

10 the battle lines of this because the fossil fuels have 

11 built the world's civilization and economy. And we are 

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 here and 

16 talk and talk and talk, but you actually have the power 

17 to do some things. So I encourage you to take that to 

18 heart and know that you are protecting a lot of people. 

19 So thank you very much. And I am sorry to excuse 

20 myself, but I do need to go. Thank you very much. 

21 MR. GRUNDLER: Thank you and no worries. 

22 Mr. Grossman, welcome. 
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1 MR. GROSSMAN: Yes. Thank you. 

2 I am with STEMCO, which is a company that 

3 manufactures many components for trucks and trailers, 

4 including trailer tails, which are aerodynamic devices 

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, but I 

12 would like to share three comments with everyone today. 

13 Number one, we support alternative 4 for the trailers, 

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 manufacturers, 

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 the 

22 trailer manufacturers. And we see this as a great 
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1 example of that. 

2 I would encourage the EPA and NHTSA to spend 

3 additional time investigating ways to further reduce 

4 the work placed on the trailer manufacturers as part 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 requiring 

15 an aerodynamic device to pass more than one of those 

16 testing methods before it is recognized as preapproved. 

17 We have seen great advances over the past decade 

18 in testing facilities and protocols, and I would like 

19 to particularly applaud the 2014 EPA SmartWay program, 

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 best 
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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 aerodynamic 

5 devices certified at their appropriate and accurate

6 level is paramount to the environment and fuel savings 

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 the 

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 have 

15 for a long time. I will not say anything new to you, 

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 panels. 

20 There is a tremendous amount of ingenuity and intellect 

21 and capability that is represented here. And I am sure 

22 you folks recognize that. So listen closely to what 
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1 they say. You don't have to listen closely to what I 

2 say. 

3 There is something that came up a couple of times 

4 about history when we were not able here to walk out 

5 our front door without tearing and not being able to 

6 breathe. So what happened? How do we get where we are 

7 here today? 

8 So the EPA established standards. And the 

9 standards were implemented, and the air became cleaner 

10 but not clean enough. So as time went by, we had to 

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, it is 

14 probably 1,000 percent maybe. 

15 We still have areas of concern. We still have a 

16 lot of pollution here. But it is so much cleaner 

17 because of our history and the actions we have taken. 

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 utilize 
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1 mostly commercial trucks through brokers. And we have 

2 a lot of trucks on the road. 

3 The food industry is probably when you -- food and 

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 the 

8 food service trucks. The food service industry when 

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 want 

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. Otherwise, 

18 the food will spoil. So I had the opportunity to talk 

19 to Mr. Curl over lunch. And we talked about a couple 

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 electrical 
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1 component where they can operate it. But most of the 

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 on 

12 the bottom which help. And then, of course, you see 

13 the bulbs on the front of the trailers and the hoods 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 question. 

18 And it is a combination electrical and gas. She said, 

19 "Dad, you know when the last time I filled up my tank 

20 with gas?" 

21 And I said, "No." 

22 And she said, "Three months ago." Okay? And then 
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1 she says, "Do you know what my gas mileage is?" 

2 And I said, "No." She said, "It's approximately 

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 in 

8 2011. Where have we been? Okay. We need to expedite 

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 program. 

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 that 

20 are down a lot mechanically. And when they go down, it 

21 costs you money and time. So a big part of what he was 

22 saying as an individual owner is that a big part of why 
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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 commission 

8 and it costs him a bunch of money. He doesn't have a 

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 into his 

17 truck. You heard the costs. So a big part of that is 

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. 
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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 sure 

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 and 

14 Strategy Development for Achates Power. We were formed 

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 durable 

18 for today's markets requirements while optimizing its 

19 inherent engines efficiencies. 

20 Achates Power works with established engine 

21 companies to apply our technology to engines for their 

22 applications, primarily for trucks and cars. We have 
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1 programs underway today to develop engines for leading 

2 global OEMs that together account for 40 percent of the 

3 worldwide volume of cars and trucks sold every year. 

4 These programs are subject to nondisclosure agreements. 

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. Our 

12 partner on that project is Cummins. And, then, 

13 finally, Fairbanks Morse has licensed our technology 

14 and employed our technology to improve their opposed15 piston engine for stationary power and marine power to 

16 improve the emissions, efficiencies, and durability of 

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 80 

20 employees, mostly technical, and offices in San Diego 

21 and also near Detroit, Michigan. We have been running 

22 prototype engines on our dynamometers in San Diego 
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1 since 2005 and have over 6,000 hours of testing to 

2 validate our claims. We have published and presented 

3 our test results around the world in a series of more 

4 than 30 technical papers since 2011. Some are 

5 available at a table just outside the conference room 

6 right now. 

7 The five-liter prototype engine that we are 

8 testing in San Diego as we speak is the most efficient 

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 than 

12 the new Ford power stroke 6.7-liter engine. With 

13 identified design improvements, it will be 32 percent 

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 version 

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 being 

21 developed for conventional engines, those technologies 

22 can be applied to our engine to make it more efficient 
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1 still. 

2 I want to make three points. First, we support 

3 the separate engine efficiency standards for the 

4 reasons well-articulated in the proposed rule. Second, 

5 we support the agencies' intent, as stated in the 

6 proposed rule, that the standards are meant to be set 

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 is 

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 consumption is 

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. 
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1 MR. GRUNDLER: Thank you very much. 

2 Ms. Sheth, you are up. 

3 MS. SHETH: Good afternoon, everyone. My name is 

4 Mona Sheth. I am here on behalf of the Advanced Engine 

5 Systems Institute to provide comments on the agencies' 

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 States. 

11 For more than 40 years, our industry has been working 

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 science18 driven air quality regulations have reduced pollution 

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 agency 

22 and the President for going beyond public health and 
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1 environmental impacts of criteria pollutants, like 

2 particulate matter, and nitrogen oxides to tackle the 

3 grave risks associated with greenhouse gas and black 

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 atmospheric 

8 concentrations and will rise through 2040 without phase 

9 2 or similar limits. 

10 AESI is pleased that the agency has proposed to 

11 retain the basic regulatory structure used in phase 1, 

12 including a separate engine standard and similar 

13 testing and certification procedures. Our industry has 

14 invested heavily in research and systems to deliver

15 cost-effective greenhouse gas reductions to meet the 

16 phase 1 schedule while meeting the 2010 standards for 

17 NOx and PM. Retaining a separate engine standard and 

18 enhancing compliance enforcement will help ensure the 

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 that 
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1 can help vehicle and engine makers to quickly, cost2 effectively, and reliably reduce or eliminate carbon 

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 that 

14 greater reductions in the 4.2 percent target in the

15 proposal could well be technically feasible and still 

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. 
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1 The agencies may want to consider incentives or 

2 credits, particularly in an era of low fuel prices, to 

3 expedite the commercialization of these technologies 

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 economy GHG 

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 languish 

19 and leave significant fuel economy gains on the table. 

20 California is seriously considering an additional 

21 90 percent reduction in NOx emissions beyond the 2010 

22 standards for medium- and heavy-duty vehicles. Should 
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1 California, the Ozone Transport Commission states, or 

2 EPA choose to adopt such a standard, AESI members will 

3 work with our customers to ensure that standard can be 

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' efforts 

7 to tighten the nitrous oxide cap to ensure that 

8 efficiency enhancements made by engine manufacturers to 

9 reduce CO2 pollution do not lead to unintended 

10 increases of this potent greenhouse gas. Meeting the 

11 proposed cap will be challenging, but our members are 

12 already working on the cutting-edge materials necessary 

13 to limit nitrous oxide formation. 

14 Thank you for the opportunity to provide comments 

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 very 

21 much for this opportunity today. My name is Benoit

22 Lacroix. I am co-founder and VP-Sales at Effenco, 
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1 based in Montreal, Canada. That will explain my accent 

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 currently 

9 market our Active Stop-Start Technology in heavy-duty 

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 quickly, 

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 America 

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 percent on 
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1 the fuel measured. We just completed test sessions at 

2 the VTAF laboratory at the Department of Sanitation of 

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, which I 

7 strongly support. So yes, as far as Stop-Start 

8 Technology is concerned, our technology is on the road 

9 performing, delivering, performance, and payback as we 

10 speak. And we are also in the process of negotiating 

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 one
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1 thing that holds true for all vocational application is 

2 that idling accounts for a very, very large proportion 

3 of the operation time. We have seen anything between 

4 25 and 60 percent, nothing less for sure. Sixty 

5 percent, of course, is more urban utilization. I would 

6 say that the bulk is between 40 and 50 percent of all 

7 the data that we gathered so far. 

8 So the three different duty cycles that you used, 

9 the approach is great. I think it is a very good idea. 

10 However, of course, we strongly recommend and hope that 

11 the weightings for idling for the composite test cycles 

12 would be reviewed for higher values. At least I think 

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 observations. 

16 I would be glad to help them. Actually, I am going to 

17 contact them. 

18 Also, average speed is very much higher than what 

19 we see on the field, especially for urban, the urban 

20 part of the cycles. 

21 Yes. I mean, about the idea that the manufacturer 

22 could request different duty cycles, I recognize it
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1 would be a very big challenge to administrate, but I 

2 think it is a very, very good idea given the wide range 

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 could 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 their 

16 business. And it helps a third, more secondary tier 

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 drive 

21 the adoption of advanced technologies. I don't know, 

22 though, if phase 1 will allow this because hybrid and 
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1 stop-start, for example, were not included in the phase 

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 in our 

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 support of 

15 the EPA's newly proposed fuel efficiency standards for 

16 medium- and heavy-duty trucks. My name is Lola Ungar, 

17 First Vice President and Action/Advocacy Director of 

18 the League of Women Voters of Los Angeles County and 

19 also a retired planning director of a nearby city. 

20 Both the national, LVWUS, and state, LWVC, League 

21 of Women Voters support measures to establish air 

22 quality standards that will protect the public health 
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1 and welfare and the development of effective 

2 enforcement and implementation procedures at each level 

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 areas 

7 closest to Los Angeles County's main port areas of Los 

8 Angeles and Long Beach and along the related freeway 

9 truck routes, it is abundantly clear that unless we

10 adopt the proposed truck standards, air pollution will 

11 worsen asthma symptoms and trigger higher rates of 

12 asthma attacks among children and adults, along with 

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. 
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1 MR. DALE: Good afternoon. Thank you, ladies and 

2 gentlemen. 

3 I am proud to say that I am not merely an observer 

4 on the sidelines taking notes, listening to those in 

5 ivory towers hoping to glean a bit of wisdom to share. 

6 We are talking trucks today and now to increase their 

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, and 

12 fully capable of serving as an example of how truck

13 makers can make significant gains in the average truck 

14 MPG you seek. And it is not just me, dozens of others 

15 in this area and others all over the country, frankly. 

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 more 

20 ground in a day than I do, but there are many thousands 

21 of drivers here in this area and every other large city 

22 who could reduce their fuel consumption if they only 
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1 had the option of driving a vehicle similar to mine. I 

2 call it the electruck. You will see the pictures of it 

3 here, electruck. They could save significant expenses 

4 as well, but such electric and hybrid trucks have to be 

5 available for them to buy. 

6 My electruck is a one-of-a-kind conversion. So 

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 to 

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. 
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1 I have seen so many exciting signs that we have 

2 reached a tipping point in EV acceptance or soon will. 

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 might, 

5 including electric and hybrid trucks. 

6 I have a hybrid I rarely drive anymore and another 

7 very popular little car that you will see in a minute. 

8 If I had found EVs to be impractical, problematical, I 

9 would have stopped after my first EV conversion before 

10 Teslas and Leafs were available. Poll those that have 

11 EVs. You will find very high satisfaction among owners 

12 and drivers. And nearly all my friends and neighbors 

13 are bitten with a bug to drive electric, including 

14 those who presently drive trucks costing them dearly at 

15 the pump and who realize the national security aspect. 

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 Orange, 

19 California, is one of several that have quietly been 

20 converting trucks and buses to run either electrically 

21 or as hybrids. Another is Balqon in Harbor City, who 

22 has been quietly -- a third is Left Coast Electric, who 
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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 providing, 

4 quietly providing, wonderful, powerful EVs to those

5 such as myself. I am so grateful to them to be able 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 but 

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 they 

14 get into their buses. This is a fully electric truck. 

15 That is fully electric. He drives between Corona and 

16 Long Beach or Orange, California every day, same truck. 

17 This is my truck here. As you can see, I have it 

18 tricked up a bit so that it really gets people's 

19 attention. And as soon as they, "Wow. Wait a minute. 

20 What is going on here?" that is the hook. 

21 It gives me the opportunity to say, "Oh, you can 

22 be driving electric, too. And this is how." And I
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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 this, 

6 people just go crazy. They are coming up alongside. 

7 But they will follow me off the freeway. And it gives 

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 can 

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 Bill, 

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, for 

21 your time. 

22 Now I would like to invite panel 12. You have the 
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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 small 

7 business located in Torrance, California, which is 

8 right next to the Port of L.A. and Port of Long Beach. 

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 family 

13 and I are exposed to the high pollution caused by the 

14 trucks serving the local ports that support the 

15 California and national economy. 

16 I thank you for your leadership and initiative for 

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 the 

22 NOx level down low enough to improve the health of 
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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 our 

5 fuel cell power plant running, driving an a/c transit 

6 fleet up in Oakland exceeded 20,000 hours with zero

7 stack failure, which putting the fuel cell on par with 

8 diesel and CNG engine. 

9 Combustion engine technologies have improved a lot 

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 methods. 

16 And now it is all of the last couple of decades we have 

17 been working on after treatments. After all of this 

18 effort and time and time again shows that combustion 

19 engine has reached a level of technology limit that is 

20 financially prohibitive to improve. 

21 As has been published and as stated by engine 

22 manufacturers, the NOx reduction and fuel economy 
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1 improvement contradicts the engine controller strategy. 

2 In contrast, fuel cell not only provides better fuel 

3 economy and the zero tailpipe emission, but also they 

4 are not sensitive or as sensitive to drive cycles, 

5 traffic congestions, and emission test method, steady6 state versus cycle average, et cetera. 

7 Therefore, on behalf of U.S. Hybrid, I urge you to 

8 further support zero-emission fuel cell medium9 duty/heavy-duty vehicle, especially in urban settings. 

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 technology 

14 and clean transportation, incentives are also needed 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 technologies. 

18 And this way, you can provide a path for companies that 

19 work hard to develop a product that enables us to reach 

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 this 
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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 Surgeon 

8 General C. Everett Koop doing health risk assessments 

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 here, 

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 written 

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 very 
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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 fleet? 

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 make a 

10 real difference. 

11 You have asked very specifically about .2 versus 

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 satisfaction. 

16 We can get to .02 NOx with natural gas engines with our 

17 technology. Do I push for that? No. Why? Because 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 going 

22 under because of EGR, lots of jobs lost. I am talking 
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1 about Caterpillar leaving the on-road heavy-duty world, 

2 20,000 jobs lost in Peoria. 

3 When I was with the surgeon general, one of the 

4 things that came to the light every time is that the 

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 concern 

8 is about those other impacts. 

9 You have asked specifically about the glider kits. 

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 feed 

16 their family and put a roof over their head and get the 

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 taking the 

20 engine transmission and differential that they already 

21 have and use and they maintain primarily themselves, if 

22 they can put that into a new chassis, they have got a 
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1 more aerodynamic truck. They have got a safer truck. 

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 have to 

5 be current-year emissions standard, you are eliminating 

6 that program. It disappears because no OEM 

7 manufacturer is going to support retrofitting a brand 

8 new engine into a new chassis with a used transmission 

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 fuel 

15 use? I think that sends the right message. It 

16 addresses the folks who would love to participate in 

17 bringing down our emissions but they can't afford to. 

18 They don't have the access to capital. They can't 

19 issue a bond, issue a corporate bond, like UPS. They 

20 can't do it. So give those folks the benefit of the 

21 doubt. Give them opportunities. 

22 Along those opportunities, let's talk about the 
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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, California 

5 has the luxury of being able to push those trucks into 

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 the 

12 fleet owners? What lessons can we learn from the truck 

13 and bus regulations that California has put in place so 

14 that we make all of these regulations we are talking 

15 about effect the end-user directly so they participate 

16 and have a stake in this? Because right now, the way 

17 the regulations work, you can keep on remanning and

18 rebuilding your old diesel and keep it along just as 

19 long as you want to. All right? That is not really a 

20 bad thing for these guys because, you know what, diesel 

21 engine remanufacturing creates jobs in the United 

22 States. It is what Caterpillar does more of than 
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1 anything else. It is what SRC, the largest employee2 owned company in the world. 

3 So I am asking you to look at what CARB has done. 

4 What lessons can we learn there? How can we create

5 credits for companies that take and modernize faster? 

6 How can we credit those folks that move to alternative 

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 now 

12 that run refrigerated regional routes, they could all 

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 going to 

16 buy RNG. It is more expensive. But it actually brings 

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 the 
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1 directive from the President to do it. 

2 So I am going to be submitting much more detailed 

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 manufacturers, 

8 well, like you said, there is the good and there is the 

9 bad of that. We run the risk of putting technology out 

10 in the field that isn't ready. And the person who 

11 bears the cost of that is the end-user. So we need to 

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 transportation 

19 reporter, who found himself becoming an endangered 

20 species as a print journalist and went back to school 

21 recently and got a Master's degree in urban planning 

22 and environmental policy from UCLA, where I work. I am 
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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 fitting 

5 that you are sitting today in California because today 

6 is California's quarterly auction of carbon allowances. 

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 gas, 

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 our 

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 over 

22 $2 billion a year for the State of California to 
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1 reinvest in further strategies that reduce greenhouse 

2 gas emissions. And the California Air Resources Board 

3 is anticipating receiving $350 million in the current 

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 everything 

11 imported into the United States in a cargo container. 

12 So you couldn't pick a better place to be today to be 

13 discussing this topic. And we appreciate you coming to 

14 hear us. 

15 I want to focus on the issue of fuel economy in 

16 heavy-duty trucks. And the hew and cry by the industry 

17 that it can't be done without causing a great 

18 dislocation reminds me of the decades of hew and cry 

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 driving 

22 the emission reductions to address our very severe air 
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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 air 

7 quality and micro fine particulate emissions, we have 

8 to address diesel trucks. We have to address diesel 

9 trains. We have to address ships. We have to address 

10 those portions of the transportation industry, 

11 particularly the global goods movement industry that is 

12 leaving a toxic trail across California that is 

13 creating environmental justice issues in low-income

14 communities, predominantly minority communities, along 

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 diesel 

20 trucks in the entire United States with the Ports of 

21 L.A. and Long Beach and their clean truck programs,

22 which have been significantly beneficial to this area 
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1 in terms of reduction of micro fine particulates. 

2 Now, my wife grew up in Southern California in the 

3 smog siege of the '60s. She has asthma. Many children 

4 in this Community of Long Beach have asthma. It is the 

5 number one source of hospital admissions in this entire 

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 our 

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 buy 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 truck. 

19 It is a hybrid program, much like California's clean 

20 vehicle rebate project, which incentivizes Californians 

21 to buy electric vehicles. 

22 We have in California invested over $200 million 
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1 in rebates to people who buy electric vehicles and 

2 plug-in hybrid electric vehicles or fuel cell vehicles. 

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. Anything 

7 that can be done at the federal level to reduce the

8 emissions from diesel trucks by increasing their fuel 

9 efficiency, much as the CAFE standards have been set 

10 for cars and light-duty vehicles. The car standards, 

11 the CAFE standards, were fought tooth and nail, but

12 California is making progress and the U.S. is making 

13 progress in dramatically improving the fuel efficiency 

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 imported 

18 oil consumption and to create a more healthful 

19 environmentally and produce less greenhouse gas. It 

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 at 
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1 California's model. California is making significant 

2 progress and will reduce its greenhouse gas emissions 

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 statute. 

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 firm 

16 does is repower engines that can be used in glider 

17 kits. And so the proposal, what we have proposed to 

18 do, is require that beginning in 2018, that glider kit 

19 engines would meet the most recent emissions standards, 

20 so like the 2010 standards, as well as the model year 

21 greenhouse gas. 

22 Your suggestion was that we should consider 
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1 allowing CNG conversion kits to be used. And I would 

2 suspect that, if done properly, a CNG-converted engine 

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 your 

6 assumption that a -- is that why you are suggesting a 

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 suggesting is 

11 that we can have a large incremental improvement, both 

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 in 

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 that 

18 falls into place there. It puts a huge burden on both 

19 the person who is doing the conversion and on the fleet 

20 owner. And you are not going to have adoption. You

21 will have killed that program. And you will have no 

22 alternative for the folks who don't have large capital 
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1 to try and participate in bringing down our greenhouse 

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 to 

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 what 

10 we are looking at. I think what we are looking at is 

11 trying to make a significant improvement today. That 

12 is what everyone up here asked for. That is what the 

13 EDF asked for. 

14 You know, I guess one of the more specific things 

15 I can talk about is TRUs and APUs. We can take those 

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 greenhouse 

20 gases. For the cost of that DPF installation, we can 

21 convert that to run on natural gas. It doesn't account 

22 for the cost of the tanks. That is the biggest price. 
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1 But if you are already running a natural gas tractor, 

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. Maybe we 

5 will be allowed to use TRUs and APUs that are now 

6 natural gas. And, you know, memo 1-A guides us there 

7 because there are no alternative fuel conversion 

8 regulations for non-road. So, you know, are we willing 

9 to take the chance? Yes, my company is. 

10 We were EPA-compliant over a year and a half ago 

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 it is 

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 me do 

16 it. 

17 I am very fortunate that I have got a great team. 

18 I have got folks from McLaren. I have got folks from 

19 Ferrari. I have got the ex-head of global engineering 

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. Neither 
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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 natural 

5 gas on-road engines?" 

6 He said, "John, Cat makes diesels. End of story." 

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 what is 

10 actually possible. 

11 One of the things you have is .1 grams for methane 

12 emissions right now. There is no catalyst manufacturer 

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 not 

15 even going to invest in it. It is such a low number. 

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. 
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1 So I ask that, instead, maybe you look at those 

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 percent 

6 reduction, 40 percent improvement in fuel economy, you 

7 wouldn't need these regulations. Every truck owner in 

8 the world would say, "Sign me up right now. That is my 

9 number one cost of operation." If I can knock 40 

10 percent off, this thing pays for itself. What happens 

11 when it doesn't? Who pays that guy for his investment 

12 that didn't turn out? How are you going to prove to 

13 this person up front that, yes, you are actually going 

14 to realize that? 

15 The bottom line is, with all the bad things that 

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. People are 

22 going to keep these things alive. 
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1 You say you don't have the authority on outside 

2 useful life. What is useful life? The average age of 

3 a heavy-duty truck in the United States is almost 20 

4 years of age. That is registered. That is Polk data. 

5 That is real data. So what are we going to do to shift 

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 any 

10 other citizens or other testifiers show up. So thank 

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 Mill 

18 Valley, California. I am here today to testify as a 

19 private citizen. For the past 11 years, I have been 

20 teaching as a lecturer at Stanford in public policy in 

21 urban studies. And prior to that, I had a career in 

22 business, government, and the nonprofit sector. Also, 
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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 for 

4 my lateness, but the plane was delayed for two hours 

5 from San Francisco. 

6 MR. GRUNDLER: No apology necessary. 

7 MR. LITVAK: I am glad that I was able to make it 

8 in. 

9 I am primarily going to be testifying today from 

10 the point of view of someone whose community is 

11 threatened by climate change, and I am also going to 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 explicit 

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 documents. 
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1 And I think that the process that you are following in 

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 fuel 

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 whose 

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 the 

17 decades progress and specifically dairy farmers in our 

18 county. Much of the western part of Marin County is 

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 it is 

22 something that we are experiencing today. 
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1 Also, I live only one mile from San Francisco Bay, 

2 from the edge of the bay. And I am personally lucky 

3 because my house is 170 feet above sea level, even 

4 though it is only a mile away. But in our town, miles 

5 of roads, thousands of homes, and many schools, 

6 including the ones where my children went to primary 

7 school, middle school, and high school, are very close 

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 have 

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 oil 

18 refinery. So for that community, these standards are 

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 refineries. 

22 So because there is so much at stake, I think that 
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1 your two agencies need to take full advantage of the 

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 current 

5 proposal for phase 2 to adopt the standard recommended 

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 down 12 

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 thank 

19 you for traveling all the way down from San Francisco 

20 to share your thoughts. 

21 Any questions for Mr. Litvak? 

22 MR. CHARMLEY: So does that mean that we would
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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. The 

7 students in teams of four do a consulting project for 

8 an outside government or nonprofit client. So if this 

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 all 

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.) 
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