Testimony of the Diesel Technology Forum before the U.S. Environmental Protection Agency, April 12, 2022

April 12, 2022

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(Diesel Technology Forum) ... 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.

Summary

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. ... Delivered by Allen Schaeffer, Executive Director, Diesel Technology Forum READ MORE

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