EPA representatives telegraph what to expect in the GHG rule

July 5, 2015
Jessica Brakora, EPA research engineer for EPA’s Office of Transportation and Air Quality, explains how customer choice could affect a trailer’s ability to comply with upcoming Phase 2 regulations for greenhouse gas and fuel economy of heavy vehicles. Each scenario included customer refusal to buy at least one of the technologies that could help trailers comply with the regulation. The technologies include aerodynamic devices, low rolling-resistance tires, automatic tire inflation system, and weight reduction. In these examples, all trailers complied with what EPA believes will be included in the regulation.

TRAILER manufacturers got a detailed look at what might be in store for them when the much anticipated Phase 2 of heavy truck greenhouse gas emission regulations—rules that were expected to set performance standards for trailers—eventually takes effect.

Representatives from the Environmental Protection Agency met with TTMA members for almost five hours April 29 prior to the official start of the TTMA convention. However, they stressed that the information they presented still had to be approved by the Office of Management and Budget before it is officially presented to the public as a formal proposal.

“This is still a pre-proposal,” said Jessica Brakora, EPA research engineer for EPA’s Office of Transportation and Air Quality. “Everything is still subject to change. The proposal was submitted for review at the end of March. It could take as much as 90 days before it is published. When the proposal is published, it will call for a public comment period. Please participate.”

Presenters strongly indicated that trailers will be included in Phase 2.

“Tractor trailers make up the largest fraction of CO2 emissions and fuel consumption from heavy-duty vehicles,” Brakora said. “Trailers are an integral part of the tractor-trailer vehicle. Tractors and trailers are not useful vehicles on their own. Trailer design contributes to the CO2 emissions and fuel consumption from the tractor’s engine.”

Brakora said the proposal that has been submitted has been based on multiple meetings with trailer industry stakeholders. They include meetings with TTMA, individual trailer manufacturers, the National Trailer Dealers Association, the American Trucking Associations’ Fuel Efficiency Advisory Committee and their Technology and Maintenance Council, trailer aerodynamic device manufacturers, tire manufacturers, test labs, and others.

Here are some of the key points these stakeholders wanted EPA to consider when drawing up the regulation, Brakora said:

•  There are many unique trailer designs.

•  Many small businesses are part of the trailer industry.

•  It is a customer-driven industry. Customers play a key role in specifying the design and features of the trailers they buy.

•  Unlike care and truck manufacturing, the trailer manufacturing industry has little experience with performance-based testing or modeling. As a result, Brakora said, staff identified multiple compliance approaches to evaluate performance with minimal trailer testing or modeling on the part of the trailer manufacturer.

•  Companies have limited resources for regulatory compliance. Brakora said EPA staff is considering simplified compliance strategies and long phase-in periods in order to reduce some of the compliance burdens for an industry that has not be regulated in this manner before.

The fuel-efficient trailer

So how does a regulatory agency set emissions and fuel economy standards for vehicle that does not have its own engine? EPA appears to be concentrating on three areas:

•  Aerodynamic technologies. This would be measured as a change in drag area (delta CDA). This would involve aerodynamic testing. Brakora said staff is considering several alternatives: tests conducted by the trailer manufacturer, a contractor, or an aerodynamic device manufacturer and having been pre-approved by EPA/NHTSA.

•  Lower rolling resistance tires. These tires would be measured through an ISO evaluation procedure. It is expected that the trailer manufacturer would simply employ the evaluation of the tire and would not be required to do their own testing.

•  Automatic tire inflation systems. Another technology that would not require testing by the trailer manufacturer, EPA is expected to apply a percentage of emission reduction for the trailer based on information supplied by the automatic tire inflation system manufacturer.

•  Weight reduction. Specific weight reduction values would be able to be applied toward compliance.

EPA continues to see different standards being applied to different types of trailers. Potential trailer “families” include:

•  Long dry-freight vans. These types of trailers will be assumed to operate long distances on highways and thus have the potential to benefit most from improved aerodynamics.

•  Long refrigerated vans. Refrigeration units create a different scenario for the aerodynamic devices designed for dry-freight vans.

•  Short dry-freight vans. These frequently operate in local delivery operations and would not benefit as much from aerodynamic reductions.

•  Short refrigerated vans.

•  Non-van trailers. There is expected to be no aerodynamic requirement for these types of trailers.

Manufacturers are expected to be allowed some flexibility in defining the families of trailers that they produce.

How to comply

The regulations could offer manufacturers two compliance strategies: every trailer complies, or the average of all trailers complies. The second strategy accommodates the possibility that some customers may refuse to equip their trailers with some technologies. Such a strategy will require more recordkeeping and year-end reporting.

Trailer manufacturers are not expected to be required to test their trailers in order to quantify CO2 reductions. However, they probably will be required to submit their CO2 and fuel consumption results and to estimate the production volumes for each family.

At the time of the meeting with TTMA, a number of issues remained to be resolved. For example:

•  Staff is considering separate treatment for box vans with work-performing devices that reduce the use of aerodynamic devices.

•  Establishing a baseline. To what extent will trailer manufacturers be stretched by this regulation? If a manufacturer already has implemented much of the proposed technologies, how much more will be required?

•  How common is common? In order to improve EPA is expected to require technologies that are not currently in common use. But what does it mean that certain reduction technologies are in “common use?”

•  Limitations. Do any trailer design characteristics indicate an intended use that could consistently limit the benefits of the proposed technologies?

•  Lead times. A ten-year implementation period is being considered to provide significant lead time for manufacturers to become familiar with technologies and compliance process.

Brakora said that the requirements for trailer manufacturers are expected to be gradual, and that the burden will be “minimal” in the early years.

“With full implementation in 2027, this regulation will have the longest period to comply than any in history, she said.