GHG and CSA: Those are the two key acronyms trailer dealers have to understand and embrace if they are going to successfully navigate the legislative waters in the coming years.
Greenhouse gas emissions regulations and Compliance, Safety & Accountability were the focus of a presentation given by Rob Fortney of Great Dane and Al Cohn of PSI.
The National Highway Traffic Safety Administration (NHTSA) is working closely with SmartWay, the Environmental Protection Agency’s (EPA) voluntary government program, on new rulemaking for tractors and trailers in the spring of 2015.
“This is a big deal,” Cohn said.
He said joint rulemaking between EPA and NHTSA, finalized in 2011, sets limits for GHS emissions and phases in model years 2014-2018+, and covers all on-road vehicles over 8500 lbs GVWR (Class 2-8).
It’s projected to reduce GHG emissions of 270 MMT (530 million barrels of oil) and save $40 billion over the life of the regulated vehicles. He said EPA and NHTSA relied on input from a broad range of stakeholders to construct a rule that was widely accepted, and the industry has already responded by developing innovative, GHG-reducing technologies for MY 2014.
The Administration’s Climate Action Plan called for new fuel efficiency and GHG standards to help reduce emissions from heavy-duty vehicles. In February, the Administration announced the upcoming rulemaking for HD vehicles and set a target of March 2016 for the final rule. EPA and DOT, in close coordination with the California Air Resources Board (CARB), will develop a comprehensive national program for medium- and heavy-duty vehicle greenhouse gas emissions and fuel efficiency standards for model years beyond 2018.
Rulemaking comes out in March, with six months of comments and six months to finalize it.
“Basically, they’ve figured out that even though a trailer doesn’t burn fuel, it does make a huge difference to how much fuel a tractor runs,” Fortney said. “They’re not only trying to drive down how much fossil fuel is burned, but also what effect it has on the ozone layer. That’s the greenhouse gas.”
The EPA regulates greenhouse emissions, including CO2, under the Clean Air Act. NHTSA regulated fuel efficiency under the Energy Independence and Security Act. CO2 emissions and fuel efficiency are closely related, he said. CO2 is a product of fossil fuel combustion, and reducing fuel consumption and improving fuel efficiency generally reduces CO2 emissions. EPA and NHTSA coordinated their rulemakings to allow manufacturers to choose technologies that will meet both agencies’ requirements. The regulations are separate, promulgated under separate statues and codified separately in the CFR.
Phase 1 involves manufacturers of complete vehicles 8500-14,000 lbs GVWR (pickup trucks and vans); heavy-duty engine manufacturers, including secondary manufacturers of alternative fuel engines; manufacturers of semi-tractors; and vocational vehicle chassis manufacturers.
Phase 2 would add semi-trailers.
Trailers are a significant contributor to combination tractor-trailer CO2 production, he said. They were not regulated in Phase 1, but the EPA committed to considering trailers in future rulemakings. The EPA is investigating the feasibility of GG-reducing technologies for the wide range of trailer applications, focusing on dry vans and reefers and looking very closely at tandem (pups) and others such as tankers, flatbeds, and container chassis.
Vehicle compliance would be based on vehicle simulation (Greenhouse Gas Emission Model, or GEM). Trailer manufacturers would test GHG-reducing technologies with a “reference tractor” and establish input values for simulation. The manufacturer would submit a model’s inputs and CO2 output (g/ton-mi) to the EPA.
The estimated costs to achieve compliance:
• Aerodynamic. Side skirt: $700-1100. End fairing: $1000-$1600. Gap reducer: $700-$1000.
• Weight reduction. Single wide tire: $168. Aluminum wheel (dual): $272. Aluminum wheel (single wide): $327.
• Lower rolling resistance. Dual (incremental): $50. Single wide (incremental): $50.
• Tire inflation. Automatic tire inflation system: $700-$1000.
EPA and NHTSA are currently considering the potential scope of applicability for the proposal. The Notice of Proposed Rulemaking (NPRM) is expected to propose a nationwide program and propose to directly regulate trailer OEMs.
Any EPA/NHTSA proposal would apply only to new trailers. Fleets and owner-operators would not be regulated. And current in-use fleets would not be required to retrofit trailers.
Cohn said the agencies recognize the need for: lead time to develop, test, and gain experience with technology; periods where standard levels are stable; flexible compliance provisions; and certainty with regard to future requirements.
He said EPA and NHTSA are currently focused on addressing the trailer types where GHG and fuel efficiency technologies would be technically feasible, practically implementable and safe, provide meaningful emission reductions at reasonable costs, and have reasonable payback periods.
“As currently envisioned, the proposal would not cover all trailer types,” he said. “It’s focusing mainly on dry box vans and reefers for aerodynamics, including pups, and is still considering some types of tankers, flatbeds, and container chassis for aerodynamics. Other types of highway trailers such as auto carriers, livestock, and bulk carriers are not being considered for aerodynamic improvements for reasons of practicality or small markets. All on-highway trailers are being considered for tire technology, regardless of number of axles. Trailers that are dominantly in off-road areas, such as trash haulers, dumps, and loggers, are not under consideration for the proposal, and many of these trailer OEMs are small businesses. They’re looking at everything—that’s the bottom line.”
The program could start as early as 2018 for aerodynamic requirements for new dry box and reefers over 53 feet and tire technology for other highway trailers. They’re focusing on a smooth nationwide transition to SmartWay and AB32 technologies and need to be sure that the rule does not create incentive to “temporarily” create shorter trailers, he said.
“In later years, the program could increase overall penetration and reduction/efficiency requirements for dry box and reefer trailers, extend the program to shorter length dry box vans and reefers, and include other types of trailers,” he said.
Potential GHG emission and fuel efficiency requirements for each trailer type would be based on both penetration rates for identified technologies and their efficiency improvement. However, the potential regulation would not prescribe the use of any given technology. Currently under consideration are improved aerodynamics, lower rolling resistance tires, automatic tire inflation systems, and weight reductions.
Three new classifications will be in Phase 2: Basic SmartWay, SmartWay Combinations, and SmartWay Elite.
“Elite is if you spec the new advanced skirts, tail gap reducers, best single wide tires and automatic tire inflation,” he said. “You have to have a 10.5% improvement in fuel economy.”
He said the USEPA Technology Assessment Center is researching and testing a wide range of applications to evaluate technologies, using a wind tunnel on a one-eighth scale. Preliminary results show that a full aerodynamic package is projected to save 11.76% in fuel.
Fortney said the top CSA violations are lights, brakes, and tires, and fleets are fighting the new CSA formula because points can add up very quickly.
He said trailer dealers should get familiar with CSA Regulation Part 396, which deals with inspection of motor vehicles and intermodal equipment because it’s a huge opportunity for mobile maintenance inspections and repairs.
“The three top issues are tires, lights, and brakes—all types that can be taken care of, either through mobile or in the shop,” he said.
He also said trailer dealers should be monitoring the actions of FedEx and several other LTL carriers that are promoting a change from 28-foot pups to 33-foot pups. They are not requesting any increase in GVW from the current 80,000 lbs. They site a potential increase in freight capacity of 18% and a reduction of 1.8 billion miles and $2.6 billion in cost reductions for the trucking industry. No change in GVW is expected for at least 18 months.
“Trailer dealers love all of that, because if GVW goes up, they’re going to sell more of a different spec,” he said. “If trailers get longer, they’re going to sell more trailers.
“It’s a tremendous opportunity for service and parts work, performing factory engineered ‘stretch’ jobs. It’s an opportunity for refurbishment work, including rear door replacement.”
He said the Food Safety Modernization Act (FSMA) Proposed Rule on Sanitary Transportation of Human and Animal Food involves the design and maintenance of vehicles and transportation equipment to ensure that it does not cause the food that it transports to become contaminated.
“Interior washout becomes more critical,” he said. “Interior condition and repair becomes more critical. There is the potential for upgrades of doors and security systems to prevent adulteration of food products due to temperature or outside contamination.” ♦