The trailer-specific portions of the Phase 2 rulemaking proposal to increase fuel economy and greenhouse gas (GHG) standards would be costly, inefficient and worsen the trucking industry’s carbon footprint and safety record, Truck Trailer Manufacturers Association (TTMA) engineering manager John Freiler testified at a government hearing.
“We’re concerned that this proposal doesn’t seem to recognize that the trailers that would gain benefit from application of SmartWay style technologies have already done so,” Freiler said. “Also that the purported gains of this rule seem to come exclusively from theoretical modeling rather than real-world experience.
“If this rule is not to have unintended consequences, very careful thought will have to be applied to excluded classes of trailers. Further, some of our members are dubious of EPA’s claims of legal authority to regulate our products at all; we have issues with the widespread requirement of LRR Tires and ATIS; we have issues with the warranties that the government is mandating as well as industry disruptions from averaging; and we have ideas as to how the rule could better be crafted to accomplish its goals with a minimum of cost to the shippers, operators and ultimately all consumers.
“We are not opposed to all regulation: TTMA has a long history of working closely with regulators to help craft sensible regulations that serve to better both the industry and the public. You can see this in the number of times information from TTMA is cited in various regulatory evaluations. But to accomplish this needs time.”
He said the trailer industry is different than the automotive market: These are mostly small businesses, often working in niche markets for a handful of customers, and they need more time to respond.
“While the proposed regulation was crafted over the course of some 16 months, our members have been given just bit over 60 days to respond,” he said. “Just understanding what it means to have our products come under EPA rules is a daunting task that is just one of the unwritten consequences of this proposal in addition to the requirements in the 629 pages of the printed document. We lack the dedicated engineering and legal man-hours needed to properly respond to this rule in the allotted time.
“Therefore, I will end with this plea: We need more time to respond to this proposal. We’ve submitted a petition to the docket to extend the comment period by at least 90 days, and 180 days would more reasonable: it’s still far less than the 500 days the government spent writing it and we could be of great help in actually achieving the agencies’ goals of reducing fuel consumption and GHG emissions.”