The Environmental Protection Agency overstepped its bounds in applying Phase 2 of it greenhouse gas regulations to trailers, said Jeff Bennett, vice-president of engineering and product development for Utility Trailer Manufacturing.
In an interview with Eric Starks as part of the FTR virtual conference held February 16, Bennett explained that Phase 2 is still in the proposal stage at this point. The final rule is expected to be announced this spring. Objections include:
• Bennett and other trailer industry stakeholders disagree with the EPA position that trailers fall within the scope of EPA regulatory authority, even though trailers have no engine that can emit greenhouse gases. While historically treated as a single vehicle, trailers are seen through EPA eyes as part of single vehicle—the tractor and trailer.
• Fleets already are voluntarily adopting equipment such as aerodynamic devices, automatic tire inflation systems, and low rolling resistance tires when they prove to be cost effective. The fleets buying these products tend to be high-mileage highway operations. Local delivery and other low-speed operations do not benefit as much from the equipment. Trailer manufacturers are questioning the value of a regulation that requires these specialized fleets to buy equipment that in actual use shows limited benefit or effectiveness.
• EPA has proposed requiring trailer manufacturers to forecast by trailer type how many trailers they will build. Bennett said this proposal has the potential of enabling some manufacturers to game the system. In addition, he said, it is difficult for manufacturers to know what the demand and product mix will be a year out.
• Flaws in the agency’s cost-benefit analysis. The computer model that the agency uses assumes the average trailer speed to be 65 mph. Yet trailers spent a lot of time waiting to load and unload. The average speed—and the benefits of the proposal—are much less.
Greenhouse gas regulation is not the only regulatory proposal with the potential to impact trailer manufacturers. Bennett also expressed concern about an EPA proposal to regulate the blowing agents used in insulating refrigerated trailers.
“If we had found their options to be viable, we would be using them now,” he said. “We have been testing them, but we have not been able to get them out of the laboratory.”