August 18, 2015 

California 

Before the 

US Environmental Protection Agency 

and 

National Highway Traffic Safety Administration 

On the matter of 

Phase 2 Proposed GHG Rules for Medium and Heavy Duty Trucks 

Dockets: EPA-HQ-QAR-2014-0827 and NHTSA-2014-0132 

My name is Tom Fulks and I am appearing here today on behalf of the Diesel Technology Forum. The Diesel 

Technology Forum represents the leaders in clean diesel technology including engine, vehicle and equipment 

manufacturers and affiliated organizations. 

Today, manufacturers of commercial trucks, engines and their components produce the cleanest, safest and 

most fuel efficient technology in the world. For all parties, the challenge of further increasing fuel efficiency 

while maintaining or improving environmental, safety and productivity of commercial vehicles is as complex as 

it is important. 

Diesel engines are the prime mover of the global economy and the primary power plant for the wide range of 

commercial trucks, and we hope that the outcome of these proceedings builds on the success already 

accomplished in achieving near-zero emissions with today's new clean diesel technology. 

We would like to focus our comments on three areas: 

• The transformation to clean and the current and future role for diesel engines and 

• Clean air, fuel saving and other benefits accruing from clean diesel; and 

• A framework for continued success. 

1. NEW CLEAN DIESEL TECHNOLOGY WILL CONTRIBUTE TO FURTHER EFFICIENCY GAINS AND CONTINUE TO 

BE THE PRIMARY POWERTRAIN FOR COMMERCIAL VEHICLES. 

Today, more than 95 percent of all heavy duty trucks and an overwhelming majority of medium duty trucks on 

the road are diesel-powered. Manufacturers envision further advances and innovations in diesel engines that 

will improve efficiency beyond where we are today. That progress coupled with diesel's unmatched 

combination of power, increasing energyefficiency, work capability, reliability and now near-zero emissions 

environmental performance, along with an ability to utilize a variety of low-carbon renewable diesel fuels, 

solidifies diesel's role for commercial trucking going forward. 

Last year {2014) was a very strong year for new truck sales; with over 186,000 new medium duty t rucks sold 

(Class 4-7) along with over 230,000 heavy-duty (Class 8) trucks sold. The overwhelming majority of these 

vehicles are powered by clean diesel technology with just a few thousand units powered by other fuels. 

Since 2000, the leaders in clean diesel technology have met the challenge from both CARB and USEPA to 

virtually eliminate both NOx and particulate emissions from diesel engines, reducing emissions by as much as 

98 percent from previous levels. 
Statement of the Diesel Technology Forum August 18, 2015 CALIFORNIA Page 2 

In fact, last year the American Lung Association, in its annual State of the Air Report identified cleaner diesel 

fleets as one of the two main contributors to helping the nation achieve cleaner air and meet the national 

ambient air quality standards. 

New technology clean diesel engines are being widely embraced by customers as evidenced by the increasing 

penetration into the vehicle population. According to state vehicle registration data for 2014, 

• about 37 percent, or 3.4 million vehicles of the roughly 9.2 million Class 3-8 heavy-duty vehicles on the 

road nationwide, are deployed with a 2007 or newer model year enginewith near zero particulate 

emissions. 

• Further, of these,22 percent( roughly 1.9 million) vehicles on the road meet the most stringent 2010 

and later year emissions milestone that requires near zero levels of both particulate matter and 

nitrogen oxide emissions.1 

By way of comparison, there are 120,429 model year 2010-2014 heavy duty (class 3-8) trucks in operation in 

California, making california rank third nationwide in terms of total number of new technology diesel engines 

on the road.(This is out of a population of 867,000 total diesel heavy duty vehicles). 

2. CLIMATE, FUEl SAVINGS AND CLEAN AIR BENEFITS FROM NEW TECHNOLOGY DIESEL ENGINES IN 

COMMERCIAL TRUCKS IN OPERATION TODAY ARE SIGNIFICANT AND GROWING 

New diesel technology on the road today is delivering real world benefits in the form of fuel savings and 

reducing carbon emissions. According to research commissioned by the Diesel Technology Forum, in just the 

last four years-between 2010 and 2014- technologies developed to meet strict diesel emissions standards 

beginning for model year 2010 engines have generated substantial fuel savings and emission reductions. Over 

880 million gallons of diesel fuelwhich equates to 9 million tons of C02 have been savedin that 4 year period 

thanks simply to the adoption of new clean diesel technology in commercial trucks. 

With one of the largest medium and heavy duty fleets in the country, California stands to benefit the most from 

these proposed Phase 2 rules. Already, model year 2010 and newer engines that are found in Class 3- 8 

vehicles in the state have eliminated 120,000 tons of NOx and 580,000 tons of carbon dioxide and saved 1.4 

billion barrels of crude oil between 2010 and 2014, according to our most recent research. 

As recently stated by CARB, the further adoption of new and newer diesel engines in heavy-duty applications in 

California is expected to reduce emissions of oxides of nitrogen by fifty percent between 2012 and 2020. 

3. FRAMEWORK FOR CONTINUED SUCCESS SHOULD INCLUDE APPROPRIATE TIMEFRAMES, UNIFORMITY 

AND HARMONIZATION 

Based on the industry experience over the last decade-plus we strongly urge EPA and NHTSA to finalize these 

rules to ensure a national program uniform to all 50 states including California, that ample lead time and 

stability are provided, and that it is compatible with the diversity of the commercial trucking marketplace. 

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Statement of the Diesel Technology Forum August 18, 2015 CALIFORNIA Page 3 

In addition, we strongly urge that EPA and NHTSA ensure that the final phase 2 program be fuel neutral in 

nature. Through the adoption of emissions standards, testing procedures and other provisions, the proposed 

rule must ensure that one fuel or technology is not directly or indirectly favored over others, for any of the 

categories of vehicles covered. Various provisions in the current proposal particularly for lighter duty 

commercial vehicles as well as vocational trucks may be skewed to favor one fuel over another, or make 

assumptions that work against the diesel engine option. EPA and NHTSA's role is to establish and maintain a 

level playing field that allows manufacturers and their customers to select the technology that makes the most 

sense for their specific needs. 

While this proposed rule focuses on vehicle and engine standards, in the context of efficiency and reducing 

greenhouse gas emissions, we believe that it is important to also note the benefits from changes to fuels. Just 

last week, the City of San Francisco announced that renewable diesel fuel will power all city owned diesel 

vehicles and equipment by years' end. 

The diesel platform is most unique in its ability to operate on a wide range of renewable low-carbon biofuels. 

Today, most heavy-duty diesel engines are approved to operate on blends of biodiesel up to twenty percent. 

Renewable diesel fuels made from renewable bio-feed-stocks are now also commercially available. These 

"drop-in" replacement fuels couple even greater carbon reduction with further emission reduction. Studies by 

the California Air Resources Board indicate that such fuels can reduce by 70 percent the greenhouse gas 

emissions over conventional diesel fuel. 

4. SUMMARY 

Now achieving near-zero emissions, clean diesel technology powers the overwhelming majority of medium and 

commercial trucks today. Thanks to these improvements, and the gains anticipated from this Phase 2 rule, 

clean diesel power is poised to continue as the main powertrain technology for commercial vehicles in the 

future. 

The engine of the future may look and perform somewhat differently, and may be burning different kinds of 

low carbon fuels. But in the end, it will still be a diesel engineand an integral component of meeting the needs 

of a growing economy anda cleaner and more sustainable future. 

Contact Information: 

Tom Fulks, Mightycomm . tfulks@mightycomm.com 

Allen Schaeffer- Executive Director aschaeffer@dieselforum.org 

Ezra Finkin, Director of Policy, efinkin@dieselforum.org 

301-668-7230