What you need to know about the latest greenhouse gas proposal

By David Tanner, senior editor

What will trucks and trailers look like, and what choices will truck owners have when spec’ing new vehicles in the next five, 10 or 12 years? The manufacturers certainly have ideas brewing about body style, power and performance for the future, but so does the Environmental Protection Agency.

No, the EPA is not sitting at a drafting table attempting to create new truck designs, but the agency’s influence through rulemakings – as it has had for years – will play into the conversation for future engines, transmissions, cabs, tires and even trailers.

Yes, trailers. For the first time ever, EPA plans to regulate trailers as part of an overall approach to truck combinations as it proposes new benchmarks for equipment manufacturers to meet to reduce greenhouse gas emissions and increase fuel economy.

Earlier this summer, the EPA, along with the National Highway Traffic Safety Administration, proposed a rule known as Greenhouse Gas Phase 2, or GHG Phase 2, that will take effect for some trailer types starting in 2018 but is mainly geared toward equipment manufactured between 2021 and 2027.

Phase 2, with the addition of trailers and a rolling-resistance component for tires, builds on the Phase 1 final rule affecting model years 2014-2018.

The proposal borrows heavily from EPA SmartWay and California’s greenhouse gas rules to achieve the agencies’ goals.

The agencies estimate that their standards will reduce carbon dioxide emissions by approximately 1 billion metric tons and save 1.8 billion barrels of oil over the life of vehicles and provide $200 billion in net societal benefits. They estimate the life of vehicles at five years, 435,000 miles.

Phase 2 is still a proposal for now, but it sheds light on what the EPA and NHTSA want to see in the future for trucks, trailers and tires.

EPA and NHTSA say they understand that trucking is not one size fits all, and that technologies or add-ons that work in one setting, such as side skirts or boat tails, don’t work in other applications. As such, the agencies are requesting comments from stakeholders on issues of practicality.

A 60-day comment period open through Sept. 11 is providing that platform.

When and if the proposal becomes a final rule, a truck purchaser can expect a $10,000 to $13,000 increase in the cost of a new truck and a $1,400 increase for a new trailer by 2027.

OOIDA and other stakeholders have raised the issue of cost, as well as the agencies’ faith in unproven technologies, among their chief concerns with EPA mandates.

To address stakeholder concerns, EPA and NHTSA say a truck purchaser can recoup costs in “less than two years” due to savings.

OOIDA leadership has some concerns about the claims being made, since Phase 1 is not even complete yet and some of the technologies remain unproven.

“This proposal isn’t mandating specific technologies, but it does set performance standards that only certain technologies will likely meet,” said Ryan Bowley, OOIDA director of government affairs.

“Phase 1, which was issued back in 2011, will require GHG emission reductions of 23 percent by model year 2017,” he said. “The government’s Phase 2 proposal mandates an additional 23 percent by 2027. Whenever that level of reduction is being pushed, there are going to be significant costs – and not just a higher sticker price.”

Read on and become acquainted with GHG Phase 2, especially the parts in which the agencies ask for stakeholder comments.

EPA and NHTSA did not regulate trailers in Phase 1, but the agencies believe it is appropriate to go there in Phase 2. Standards will feature some – but not many – choices for manufacturers in terms of aerodynamics and weight reduction where practical.

The proposal covers dry and refrigerated vans, flatbeds, tankers, container chassis, bulk, dump, grain and many other specialized types such as car haulers, pole trailers and logging trailers.

EPA and NHTSA estimate that 50 percent of new trailers sold in 2018 will have side skirts. Of course, the vast majority of those will be vans, and a lot of those will also have some type of rear panels or boat tails. The agencies are requesting comments about whether tails should automatically deploy when a vehicle is in motion and whether rear aerodynamics will affect under-guards and safety.

Where skirts and tails are not practical, such as a flatbed application, the agencies are proposing to make low-rolling-resistance tires and automatic tire inflation systems mandatory. Before that happens, however, the agencies want comments on the practicality of a mandate. A “how to comment” section appears later in this article.

The agencies also want comments about their proposed adoption rates for certain technologies. Again, it’s another chance to comment on practicality.

EPA is not setting out to regulate refrigeration units or refrigerant leakage at this time, although the agency is accepting comments on how EPA could address those topics in the future.

Much has been done to engines in Phase 1 and in previous EPA mandates over the years, and the agency acknowledges that in its Phase 2 proposal. Nonetheless, the agency is proposing 1.5 percent better economy and reduced emissions from engines by 2021. The agency desires a 3.5 percent gain in 2024 and 4 percent gain by 2027.

Phase 2 leaves it up to the manufacturer to figure out how.

According to the proposal, manufacturers can use combinations of technologies and designs that achieve the desired gains. Manufacturers will be given some flexibility to average, bank and trade credits due to how their equipment achieves gains in the overall equation.

According to research cited in the proposal, 53 percent of a vehicle’s drag is due to resistance from the air. The agencies are touting continued improvements to grille, bumper and hood designs to minimize pressure on the front of a truck.

The proposal gives manufacturers choices for aerodynamic mirrors, fuel tank fairings, extenders to close the gap between truck and trailer, and rear and underbelly treatments such as side skirts and boat tails to achieve standards and accumulate, bank and trade credits.

EPA says that reducing the overall weight of an empty vehicle and trailer can lead to fuel savings and also bigger payloads for the freight hauler. The agency suggests new composite materials for structural components, and choices for aluminum over steel where practical.

The agencies suggest that a 400-pound weight reduction could achieve a 0.3 percent fuel savings.

EPA and NHTSA see a day when 90 percent of Class 8 sleeper cabs will use key-off technologies. They suggest that there’s no reason why Class 8s couldn’t also have automatic engine shutoffs, or AES, as part of the package. Before that happens as a possible mandate, they want to hear from truckers and fleets on the practicality of automatic shutoffs.

The EPA says speed limiters can aid in fuel savings, but the agency is leaving well enough alone on pursuing a mandate, even as its counterpart agency, NHTSA, continues to pursue a mandate.

EPA says the proliferation of speed limiters could lead to fleets having to deploy more trucks to haul freight – thereby negating potential savings.

“We want to leave the use of vehicles speed limiters (VSLs) to the truck purchaser ...” EPA says. “We welcome comment on whether the use of a VSL would require a fleet to deploy additional tractors.”

Automatic transmissions remain an option with potential credits for the manufacturer, although EPA and NHTSA acknowledge that a lot of the savings depend on driver performance.

“Well-trained drivers would be expected to perform as well or even better than an automatic transmission,” the agencies stated. “However, poorly trained drivers that shift too frequently or not frequently enough to maintain optimum engine operating conditions could be expected to realize improved in-use fuel consumption by switching from a manual transmission to an automatic or automated manual transmission.”

For the drivetrain, the agencies say a 6x2 axle can achieve savings of 1 to 3 percent.

“Similarly, with the increased use (sic) of double and triple trailers, which reduce the weight on the tractor axles when compared to a single trailer, manufacturers offer 4x2 axle configurations. The 4x2 axle configuration would have as good as or better fuel efficiency performance than a 6x2.”

EPA and NHTSA eye potential savings in predictive cruise control systems that mimic the way the best drivers grab and coast hilly roadways.

By the very nature of the proposal, many new vehicles in the future will have automatic tire inflation systems. While they cost more than tire monitoring systems, they say ATI is an easy grab at a 1 percent savings due to the consistency of tires at a desired pressure.

Tires and rolling resistance

Also by the nature of the proposal, low-rolling-resistance tires will end up on a lot of trucks and trailers in the future if it becomes a final rule.

EPA says 32 percent of a vehicle’s drag is due to rolling resistance – where the rubber meets the road.

To reduce rolling resistance, EPA suggests choices for tire manufacturers concerning tread materials, architecture of the casing, tread design and ratings for speed, temperature and inflation.

The agencies request comments about rolling resistance and how it plays into the different trucking applications.

Glider kits

Glider kits were exempt from the Phase 1 final rule, but would not be exempt under Phase 2, according to the agencies.

They acknowledge that their proposal could hurt small-business manufacturers and want to hear from them about whether they should be given special considerations.

“EPA is proposing an option that would grandfather existing small businesses, but cap annual production based on their recent sales,” the agencies state. “EPA requests comment on whether any special provisions would be needed to accommodate glider kits.”

What about heavy haulers?

Heavy haulers definitely do not fit the bill as one size fits all, and therefore certain things just won’t work to improve their efficiency besides engine output and perhaps some wheel and tire designs.

“Heavy-haul tractors are not typically used in the same manner as long-haul tractors with extended highway driving, and therefore would experience less benefit from aerodynamics,” the agency says.

How to comment

When submitting comments, refer to Docket ID No. EPA–HQ–OAR–2014-0827 for EPA and NHTSA-2014-0132 for NHTSA.

File online at regulations.gov; by email to a-and-r-docket@epa.gov; or by mail to EPA at Air and Radiation Docket and Information Center, Environmental Protection Agency, Mail code: 28221T, 1200 Pennsylvania Ave. NW, Washington, DC 20460; and to NHTSA at Docket Management Facility, M–30, U.S. Department of Transportation, West Building, Ground Floor, Rm. W12–140, 1200 New Jersey Avenue SE, Washington, DC 20590. LL