      
           INTERNATIONAL UNION, UNITED AUTOMOBILE, AEROSPACE & AGRICULTURAL IMPLEMENT WORKERS OF AMERICA  -  UAW
      
            
       DENNIS WILLIAMS, President	     GARY CASTEEL, Secretary-Treasurer
                                       
 VICE PRESIDENTS:  CINDY ESTRADA   ::   JIMMY SETTLES   ::   NORWOOD JEWELL
                                                                  
                                                                  
                                                                  
                                                                        IN REPLY REFER TO
                                August 18, 2015
                                                                        1757 N STREET, N.W.
                                                                        WASHINGTON, D.C. 20036
                                                                        TELEPHONE: (202) 828-8500
                                                                        FAX (202) 293-3457
                        Environmental Protection Agency
 Department of Transportation--National Highway Traffic Safety Administration
                 EPA - HQ - OAR - 2014 - 0827; NHTSA - 2014 - 
                          0132; FRL - 9931 - 77 - OAR
                       RIN 2060 - AS16; RIN 2127 - AL52
                       Greenhouse Gas Emissions and Fuel
                     Efficiency Standards for Medium- and
                      Heavy-Duty Engines and Vehicles -- 
                                    Phase 2
                                       
                       Comments submitted by President 
             Dennis Williams, President, International Union, UAW

The International Union, United Automobile, Aerospace and Agricultural Implement Workers of America, (UAW) appreciates the opportunity to share our views on the proposed Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium and Heavy-Duty Engines and Vehicles-Phase 2 National Program. 

The UAW represents over one million active and retired members, many of whom have a considerable stake in the continued success of the motor vehicle manufacturing industry. We represent over 34,000 workers who could be directly impacted by this proposal. Our members assemble Navistar, Freightliner, Volvo and Mack medium and heavy trucks; heavy-duty pick-up trucks; vocational vehicles; school buses and vans. Our members also  work in plants making engines, axles, transmissions and other parts for those vehicles.

The UAW supports President Obama's goal of addressing climate change, increasing fuel efficiency and reducing greenhouse gas emissions in the combination tractor, heavy-duty pick-up truck, van, and vocational vehicle fleets. Regulations, properly crafted, can be good for the environment and the broader economy. This can and should be a win-win. For example, increasing the efficiency of light-duty vehicles has led directly to the creation of jobs in the auto industry.

We commend the U.S. Environmental Protection Agency (EPA) and Department of Transportation's National Highway Traffic Safety Administration (NHTSA) for their diligent work in crafting this proposal and for their willingness to engage on this important matter. We are carefully studying the various options presented in this proposal and are not making final recommendations at this time.  Even under the most optimal circumstances, industry participants will be required to make changes to their product design and adapt to comply. With this in mind, we urge you to proceed carefully.  We are concerned about the potential economic disruption caused by any standards that are not achievable or are developed without giving proper consideration to market reaction and other possible ramifications.  Here are some of our guiding principles and overarching recommendations in no particular order.

As you know, the medium and heavy duty sector is already working to comply with the first-ever fuel economy and emission standards for model years 2014-2018. This is a challenging task and the existing standards will reduce greenhouse gas emissions by approximately 270 million metric tons and save 530 million barrels of oil.  Your main proposal recognizes this reality and the challenges it presents. We support the phasing-in of stringency standards as most of the new requirements will not start until model year 2021. This will enable the industry to improve efficiency without causing major market disruption and accounts for product cycle. We would have significant concerns about the feasibility and impact from moving the 2021 requirements to an earlier date.

It is essential to maintain flexibility by allowing companies to achieve stringency targets in a manner that best suits their competitive and market position.  The regulation should not be overly prescriptive or technology forcing.  Specifically, the Averaging, Banking and Trading (ABT) and advanced technology credit system is essential for achieving this end. We urge you to give consideration to proposals that would further improve the credit system and allow increased flexibility around product cycles. 

Without sufficient flexibility, the tough standards included in this proposal would likely lead to layoffs and other negative economic consequences. The "Phase 2" requirements cannot result in a boom and bust cycle for American working men and women and their families who work hard to manufacture the vehicles our nation depends on.  Prescriptive, technology forcing requirements in this industry have been problematic in the past and may very well be again.   

Many of our members experienced economic hardship and uncertainty when new truck purchasers rushed to pre-buy trucks in anticipation of increased costs due to regulatory requirements outlined in earlier heavy-duty engine emission standards. This was especially a problem for complying with 2007 standards. This pre-buy was a contributing factor resulting in the lay-off of thousands of UAW members and other workers. Sadly, it took as long as five or six years before some workers were recalled.  This was a time filled with financial hardship and stress as many workers struggled to make ends meet. 

The pre-buy/no buy cycle is not only bad for workers. It is also bad for the environment and undermines the entire goal of regulations. Customers in the heavy duty sector are especially sensitive to the bottom line and will resist buying vehicles that are viewed as prohibitively expensive or include unproven technologies. We want to encourage innovation and purchases of more efficient vehicles.  Regulations designed the wrong way achieve the opposite results.  A separate engine standard that is overly stringent has the potential to lead to this outcome.  We are still examining the engine standard but encourage you to ensure the final rule does not create an engine standard that would lead to a pre buy/no buy cycle.  Companies that choose to rely on engine efficiency to help meet the standard can do so under the overall combination tractor standard.

We encourage the agencies to continue to refine the standard's compliance testing procedures to not only accurately reflect real world driving and work conditions, but to also avoid increasing stringency via technical requirements.

Finally, the standard has to be harmonized and applicable throughout the country. To do otherwise would be entirely inconsistent to the realities of commerce.  

UAW wants this proposed regulation to succeed and is willing to work with all stakeholders and interested parties to reach this achievement. Thank you.


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