                  Heavy Duty Fuel Efficiency Leadership Group
                                FE/GHG Phase II
                            Statement of Principles
                                  April, 2015
                                       
                                       

	The Heavy Duty Fuel Efficiency Leadership Group (Leadership Group), a diverse coalition of medium and heavy duty fleets and advanced technology providers, was formed in 2010. The Group worked collaboratively with EPA, NHTSA and other stakeholders to inform and support the first ever national program to reduce GHG and improve the fuel efficiency of medium and heavy duty vehicles.

	The Leadership Group has now developed the following Statement of Principles which are consistent with our corporate values and should form the basis for a successful national FE/GHG Phase II program. 

Achieve Significant Environmental, Economic and Energy Security Benefits

Phase I will reduce U.S. oil consumption, cut GHG emissions and produce fuel costs savings for fleets. Phase II should drive substantial GHG reductions while achieving important economic and energy security benefits. 

Ensure a National Harmonized Program

A single nationwide FE/GHG program must be maintained in Phase II. Inconsistencies between regulatory agencies (EPA/NHTSA/CARB) must be avoided. Harmonization of certification and compliance requirements is critical. 

Maintain Market, Fleet, Fuel and Technology Choices

Fleets are necessarily diverse in weight, size and capability to perform specific work tasks. Phase II should achieve significant FE/GHG gains without restricting fleet choice of product specifications and FE/GHG technologies needed for different applications.  Phase II should be fuel neutral and should not advantage one fuel over another. 

Build on Success of Phase I

Phase I utilized proven testing/certification protocols while establishing incentives to drive adoption of advanced and innovative technologies. Additionally, it minimized compliance burdens by relying heavily on the existing emissions protocols. Phase II should not impose requirements that shift compliance burdens to end-users. The Phase I framework, which minimized market disruption and compliance burdens, should be maintained and improved for Phase II.

Provide Regulatory Certainty with Adequate Lead Time and Stability 
A longer term roadmap (up to 10 years) with enough lead time (4 years) and stability (3 years) to develop, mature and deploy advanced technology will provide regulatory certainty and pull through advanced solutions that will provide significant GHG and fuel consumption reduction in an economically sustainable fashion. This is necessary for both manufacturers to make long-term investments that would support the new standards, as well as for fleets that need a high level of reliability and cost effective solutions in order to deploy new technology. 

Drive GHG/FE Improvement Technologies in Tractors, Trailers and Vocational Vehicles

Greater opportunities exist to drive more significant technology adoption than in Phase I. Apart from the engine standards, tractors were required to meet one set of standards in 2014, trailers were not included and vocational vehicles were regulated based on tires only. There are challenges in addressing each of these aspects given the diversity and complexity of the market. Verifiable testing and certification procedures should be adopted that balance accurately and equitably quantifying the benefits of GHG/FE technologies with regulatory complexity.  While trailers were not included in Phase I, in Phase II, regulations should be focused on taking advantage of existing GHG/FE technologies for trailers that are already in use today.

Maintain Incentives and Flexibilities

Credits intended to incentivize early market adoption of advanced FE/GHG technology should be retained. The ATC and ITC programs from Phase I should be improved to increase the attractiveness of early adoption of advanced and emerging technologies (Hybrids; EVs; Route Automation, etc.).

Adopt Complimentary Policies

The Leadership Group continues to believe that other governmental policies must promote research, development and deployment of efficient technologies in the heavy duty vehicle space.  
Financial and other incentives  -  including investment tax credits; accelerated depreciation of new capital investment; increased highway infrastructure spending and increased size (e.g. increasing federal standard for twin trailers from 28 to 33 ft.) and weight of vehicles  -  can accelerate the deployment of new, more fuel efficient trucks and assist in rapid fleet turnover. 

* Con-way Inc.
* Cummins Inc.
* Eaton Corporation
* FedEx Corporation
* PepsiCo
* Wabash National Corporation
* Waste Management, Inc. 


