WASHINGTON (April 12, 2022) – The DTF has prepared the following testimony for delivery on April 12, 2022.
Testimony of the
Diesel Technology Forum
U.S. Environmental Protection Agency
NOTICE OF PROPOSED RULEMAKING
ESTABLISHING FUTURE EMISSIONS STANDARDS FOR HEAVY-DUTY VEHICLES
Docket Numbers: EPA-HQ-OAR-2019-0055; FRL-7165-03-OAR
Thank you for the opportunity to appear today. The Diesel Technology Forum is a not-for profit educational group that represents diesel engine vehicle and equipment manufacturers, suppliers of engine components and emissions control systems, as well as producers of renewable and petroleum fuels. DTF member companies will or have already provided substantial comments on various aspects of the rule, and we would like to emphasize the following.
By building off of today’s success, we can better address tomorrow’s needs as well as the longer-term opportunities.
Today’s Diesel Technology Is a Success Story
- The new generation of advanced diesel technology has been a success story, introducing technology that achieved over 98 percent reductions in nitrogen oxides (NOx) and particulate matter (PM). Since 2011, this has translated into saving more than 20 billion gallons of fuel, along with associated emissions benefits (preventing 202 million metric tons of greenhouse gas emissions and 27 million metric tons of nitrogen oxide emissions).
- As evidenced by these benefits, truckers and fleets have embraced this generation of diesel technology above all other options. And going forward, diesel engines will continue to dominate many segments of the trucking sector for some time yet — likely decades. To continue this success story, future truckers must be ready, willing, and able to invest in the next generation of advanced diesel technology.
Future Emissions Standards Must Encourage Continued Investment Through Proper Balance in Timing, Stringency And Other Factors
- The last thing anyone wants out of this is that truckers stop buying new trucks because they are too expensive, too unpredictable, and too complex. A balanced rule will alleviate undesirable outcomes like swings in the new truck market including a pre-buying of current generation technology. We support the continued development of robust technologies that have proven they meet the challenges of reducing emissions. The value of the technologies will need to be obvious to the truckers in order to avoid outcomes that will be detrimental for jobs, the economy, and the environment.
Reducing Emissions should be more than just Setting New Engine Standards, but also Implementing More Immediate Term Solutions Like Use Of Renewable Fuels And Accelerating The Turnover Of The Legacy Fleet
- The most substantial opportunities to reduce emissions in our communities in the relative near term are ones that this proposed rule does not address, the use of renewable fuels and the existing population of older commercial trucks — the legacy fleet.
- Consider if more commercial trucks were operating on blends of 100 percent renewable low-carbon biodiesel fuels. According to EPA’s own detailed analysis, the current pool of biodiesel is of very high quality and blends of biodiesel may function seamlessly with next-generation aftertreatment devices developed to meet this low standard. The fuel is available now. The infrastructure to deliver it is available now. The vehicles qualified to use it are available now. Putting it in operation now, can begin reducing emissions now, and, like compound interest, we will be banking emissions reductions every mile, starting now. It is a competitive strategy that is more affordable and available than mandating ZEVs or very stringent future NOx standards.
- As for the legacy fleet, it is large. According to our most recent analysis of vehicles in operation (VIO) data from IHSMarkit as of the end of 2021, 53 percent are 2011 and newer model year vehicles and 47 percent are an older generation. These are pre-2011 model year vehicles with relatively higher emissions. Those made before 2007 do not have particulate traps and/or selective catalytic reduction technology to help combat emissions. They are second, or third, owner trucks operated by independent truckers and smaller fleet operators.
- The potential for rapid mitigation of both NOX and PM emissions by accelerating the turnover of this older fleet to advanced diesel technology, is tremendous. The Diesel Emissions Reduction Act has played an important role in addressing turnover in this legacy fleet and has delivered immediate improvements in local emissions. The new set of options and standards proposed will continue to improve the health of all impacted by the transportation network. While the proposals continue to clean the air, with as much as a 90 percent NOx reduction across the vehicle fleet, we are setting the stage to gain the benefits of these new proposals over the next 25 years.
Future And Zero Emission Vehicles
- The agency’s decision not to pursue a ZEV mandate is appropriate because ZEV mandates effectively alter otherwise open markets and take away options and fuels that may be more desirable, available, and affordable. Regardless of what today’s studies and projections of total cost of ownership might show, there are many uncertainties about the ultimate timing and market for ZEVs, not the least of which is the adequacy and availability of the charging and fueling infrastructure.
Above all else, this proposed rule must enable continued investment in the next generation of diesel technology by manufacturers, suppliers, and their customers. Without that, none of the anticipated benefits will accrue, older trucks will stay on the road for longer, and both manufacturers and suppliers will not have the capital to invest in future fuels and technologies.
In the meantime, getting more of the current generation of advanced diesel technology on the road and using more advanced low carbon renewable biodiesel fuels will continue to deliver everything we need; air quality improvements and sustaining progress on climate change. That’s something everyone should be able to get behind.
We look forward to continuing dialogue with the agency, and all stakeholders, about this rulemaking as well as the future for commercial vehicles powered by advanced diesel engines.
Thank you for the opportunity to submit this testimony.
Delivered by Allen Schaeffer, Executive Director, Diesel Technology Forum