GHG & Trailer Fuel Efficiency
Over the past decade, the trucking industry has faced increasingly more stringent fuel economy and emissions regulations. Some of the recent regulatory activity began with passage of the Energy Independence and Security Act (EISA) of 2007 and picked up momentum in 2010, when President Obama signed a Memorandum of Understanding directing the U.S. Department of Transportation (DOT) and the U.S. Environmental Protection Agency (EPA) to develop joint-rulemaking for medium and heavy-duty vehicles under EISA and the federal Clean Air Act.
Getting Ready for Change
The industry is now getting ready for EPA and the National Highway Safety Administration (NHTSA)’s proposed fuel consumption standards (a continuation of the Energy Independence and Security Act of 2007) and EPA’s proposed GHG emission standards are authorized under the Clean Air Act. GHG 2 initiatives will include trailers pulled by combination tractors. Trailers contribute significantly to carbon pollution emissions and to the vehicle’s fuel consumption. Cost-effective technologies, including aerodynamic devices, low rolling resistance tires, and automatic tire inflation systems can offer significant CO2 emissions and fuel use reductions, providing a benefit to the environment and the nation’s energy security, and reducing fuel costs.
Support and Advocacy
Great Dane is actively involved in discussions with EPA and NHTSA and has provided comments for their consideration. In the company’s opinion, one shared with many industry thought leaders, a main issue with these proposed regulations lies in the difficulty of creating a regulation for an industry where a high degree of customer-specified customization and critical variations in product configurations and specifications are the norm. Because trailer manufacturers tailor designs to meet customers needs, fleet owners and owner-operators rely on trailer OEMs to build the optimum product—based on their operations, influencing everything from size, number of axles and door placement to weight and load capacity and everything in-between.
The difficulty in establishing a regulation for trailers is compounded by the number of factors that affect fuel efficiency, such as tire selection, weight and aerodynamic device compatibility. On the surface, weight reduction may appear to be a key factor in decreasing fuel consumption. However, reducing the weight of a trailer may result in increased maintenance costs and the premature need for replacement. Aerodynamic devices are widely available in the marketplace and are generally recognized as having the greatest potential to impact fuel efficiency of vehicles pulling trailers. Yet, not all trailers are configured to allow them to be equipped with these devices, and many operational factors and necessities, such as operational speed, maintenance issues and damage concerns, influence many fleets to avoid using them entirely.
Great Dane believes that thorough evaluation of the technologies required to comply with the proposed regulation is necessary to gauge the overall impact of proposed changes. There are many products on the market that claim to positively impact fuel efficiency, but there are differences of opinions on their effectiveness. Any regulation or the addition of any mandatory equipment or devices must be borne out with consistent and reliable data that confirms not only a real and positive environmental impact, and a reasonable payback period for those who invest in them.
• The EPA program: initial proposed standards for trailers would apply beginning January 1, 2018
• The NHTSA trailer standards would be voluntary from 2018 to 2020, and would become mandatory in 2021.
• The standards would gradually increase in stringency in model years 2021 and 2024, and the most stringent requirements would not apply until model year 2027.
• The intent of the rule is to be performance regulating rather than design-specific or technology-forcing.
• These changes would apply only to new production of trucks and trailers.
• The proposed Federal standards only apply for new trailers, with no requirement for owners or operators to retire or retrofit trailers. The California Air Resources Board may impose separate standard though, which could involve retrofits.