Document pmd9po7gJaQoD3xK0rJ04meoB
To: From: Sent: Subject:
Jackson, Ryan[jackson.ryan@epa.gov] Market Connections Tue 8/22/2017 1:21:35 PM Federal Decision Makers: Your input is needed
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17cv1906 Sierra Club v. EPA
ED_001523_00001264-00001
To:
Jackson, Ryan[jackson.ryan@epa.gov]
From: Brian C Mormino
Sent: Fri 9/22/2017 5:14:28 PM
Subject: Followup on Cummins Mtg with Administrator
PruittEMAHandout9.20.17.pdf
Hi Ryan. Hope you are doing well. My CEO along with other leaders in the industry had a great discussion with the Administrator earlier this week. Attached is the handout that we provided to him and the rest of the EPA team that was in the meeting. As we discussed in the meeting, it seems like we have the potential for a collaborative initiative on NOx for the commercial vehicle sector which aligns with the Administrator's goals. Let me know if you would like to discuss.
Thanks,
Brian
Brian C. Mormino Executive Director - Worldwide Environmental Strategy & Compliance Cummins Inc.
MC 60203, 500 Jackson Street Columbus, IN 47201 812-377-0512 (p) 202-669-3597 (c) brian.c.mormino@cummins.com
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17cv1906 Sierra Club v. EPA
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L.na Truck & Engine Manufacturers Association*
Bringing Glean&r Power to
333 West Wacker Drive, Suite 810 Chicago, Illinois 60606
Tel: (312) 929-19701 Fax: (312) 929-1975 wwwlruckandenginemanufacturers.org
September 20, 2017
Requests for Regulatory Action and Relief Heavy-Duty Commercial Vehicle and Engine Manufacturers
Our industry is vital to the U.S. economy and American jobs
Trucks operate in interstate commerce and move 70% of the nation's freight by weight
Substantial U.S. manufacturing presence with significant capital investment in infrastructure; leaders in developing innovative technologies
jobs and
Compared to passenger cars: smaller production volumes, more diverse product lines, more limited resources; extremely long planning cycles; few players
Customers ranging from large commercial fleets to small businesses invest significant capital resources in trucks and require reliable, durable and affordable products
Manufacturers need regulatory certainty, feasibility, stability and leadtime
Strong Support for Phase 2 Greenhouse Gas Rule
O Three Phase 2 rules in play: EPA, NHTSA and CARB
Must maintain full regulatory alignment/uniformity and avoid uncertainty of change as extensive planning and coordination is already in place to meet comprehensive negotiated regulatory schedule
Certain technical corrections are required (e.g., chassis/aero testing, credit-reporting, etc.)
Requested Action: EPA should implement the Phase 2 rule as finalized, but should make required technical amendments as agreed upon by industry and the Agency
EPA's leadership in developing a streamlined national low-NOx rule can be a win-win for business and the nation's air quality
O The nation's interests in clean air and NAAQS attainment are best served by a cost-effective national program
O A new paradigm of next-tier low-NOx regulations to improve air quality for all Americans affords a unique chance for a streamlined national program that could:
- achieve significant real-world in-use NOX reductions
- reduce current regulatory burden s and costs (e.g., 2 -for-1 reductions, including streamlining OBD and several up-front certification and testing requirements)
- provide sufficient lead time, phase-ins and a subsequent period of regulatory stability to allow manufacturers to recoup their capital investment, while avoidingadverse impacts on fuel efficiency/GHG Phase 2 implementation
Requested Action: It is critical that EPA publicly signal that the Agency will take the lead in developing and implementing nationwide, next -tier, streamlined and cost -effective low -NOX regulations that will allow U.S. manufacturers to grow their businesses and that will promote NAAQS attainment across the country
A Non Governmental Organization in Special Consultative Status with the Economic and Social Council of the United Nations
17cv1906 Sierra Club v. EPA
ED_001523_00001272-00001