### August 18, 2015 California 

### Before the US Environmental Protection Agency 

## a

nd National HighwayTraffic Safety Administration On the matterof 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 behalfofthe Diesel Technology Forum. The Diesel Technology Forum represents the leaders in clean diesel technology including engine, vehicle and equipment manufacturers and affil iated organizations. Today, manufacturers ofcommercial 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 ofthe 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-ze ro 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 CONTINU ETO BE THE PRIMARY POWERTRAIN FOR C OMMERCIALVEHIC LES. Today, more than 95 percent of all heavy duty trucks and an overwhelming majority of medium dutytrucks 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 com bination of power, increasing energyefficiency, work capab ility, re liabi lity and now near-zero emissions environmental performance, along with an ability to utilize a variety of low-carbon renewable diesel fuels, solidifies d iesel's role for commercial trucking going forward. Last year {2014) was a very strong year for new t ruck sales; with over 186,000 new medi um dutyt rucks sold (Class 4-7) along with over 230,000 heavy-duty (Class 8) trucks sold. The overwhelming majority ofthese 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 ofthe 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 emb raced by customers as evidenced by the increasing penetration into the vehicle population. According to state ve hicle 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, ofthese,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 i n operation in California, making california rank third nationwide in terms oftotal number of new technology diesel engines on the road.(This is out ofa 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, injust 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 ofthe 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 ofcarbon 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 byfifty 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 fi nalize 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.

1http://www

.dieselforum.org /index

.cfm?objectid= 090207DS-01F9-11E4-91B7000C296BA163Statement ofthe 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 ofthe 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 custome rs 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 ofSan 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 abilityto 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 contin ue as the main powertrain technology for comme rcial vehicles in the future. The engine ofthe f uture may look and perform somewhat differently, and may be burning different kinds of low carbon fue ls. But in the end, it will still be a diesel engineand an integ ral 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