EPA Hearing - Phase 2 Greenhouse Gas Emissions Standards for Medium- and Heavy-Duty 

Engines and Vehicles- Wabash National Statement - August 6, 2015 

Wabash National Corporation thanks the U.S. Environmental Protection Agency and the 

National Highway Traffic Safety Administration for allowing it the opportunity to comment on 

the joint proposed rulemaking Phase 2 Greenhouse Gas Emissions Standards and Fuel Efficiency 

Standards for Mediwn- and Heavy-Duty Engines and Vehicles. 

Wabash National, a publicly traded di versified manufacturer headquartered in Lafayette, 

Indiana, is North America's leading producer of semi-trailers, having shipped more than 57,000 

units in 2014 and an expectation to ship an even greater number in 2015. With today's just-intime environment, semi-trailers are vital to keeping the U.S. economy moving, as they deliver 

nearly 70 percent of all freight tonnage. 

Wabash National continuously seeks innovative solutions to improve fuel efficiency on 

trailers and lower operating costs for our customers. Wabash National supports the objectives of 

the EP A/NHTSA Phase 2 Proposal and agrees that sensibly reducing greenhouse gas emissions 

through fuel efficiency solutions is a good thing. Not only are sensible fuel efficiency solutions 

good for our air quality, but they help to conserve our fuel resources and have the potential to 

contri bute to the decrease in the cost of freight transportation by creating greater overall freight 

efficiency. 

Freight efficiency is, essentially, hauling as much freight as possible at the lowest total cost. 

Fuel efficiency is just one of many inputs into the overall freight efficiency equation. Other 

considerations include: 

• Road Congestion and Travel Speed 

• Total Cube Space and Freight Capacity 

• Vehicle Durability and Safety, and 

• Driver Behavior 

Thus, to achieve overall improvements in freight efficiency, consideration should be given to 

not only programs encouraging the improvement of fuel efficiency, but also to complementary 

programs and fundi ng that seek to: 

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• Maintain and improve state and federal highway systems; 

• Maximize the freight capacity hauled in any one tractor-trailer load - for example, the 

measures to allow for pulling twin 33' semi-trailers on federal highways; 

• Further enhance the safety and durability of semi-trailers. 

The success of any of these programs - including these Phase 2 proposed rules- will depend. 

however, on adopting easy to implement policies that the complexity of the trucking industry and 

the need for flexible solutions. And so, Wabash National urges the EPA and NHTSA to continue 

to address the following three concerns in promulgating a final rulemakjng: 

I. The trailer manufacturer actually has very little leverage in determining what 

components are and are not included in a specific trailer. Contrary to popular belief, a 

semi-trailer is much more than a box on wheels. Most trailers are designed for a specific 

freight application and are custom-bujlt for each customer. Additionally, trailers are federally 

regulated by length, width and height - so any innovations to improve freight capacity or fuel 

efficiency must also comply with these federal regulations. As a result of these regulations, 

today's solutions for improving fuel efficiency rely on devices attached to the trailers. Our 

customers do not simply accept the addition of these devices (and the resulting additional 

cost) without proof that they will definitively result in greater overall freight efficiency for 

their operations. 

2. Not all trailer types or freight carriers will benefit from adopting fuel efficiency 

technologies. For example, tank trailers, flatbed trailers, and other specialty trailer types will 

not necessarily see benefits from the addition of aerodynamic devices and Wabash supports 

the EPAINHTSA decision to exempt these trailers from aero requirements. In additiOn, even 

some fleets operating nothing but van semi-trailers will not see benefits from the adoption of 

aerodynamic devices. This is because these types of trailers and fleets might: 

• Operate in different duty cycles, created by variations in operating locations and 

geographies. 

• They may haul locally or regionally and infrequently reach highway speeds - which is 

where aerodynamic devices provide payback. 

• They may have unique freight hauling requirements, or operate off-road for a portion 

of time. 

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The reality is, some fleets and some trailer types simply will never demonstrate fuel savings 

through the use of aerodynamic devices. Thus, sensible final regulations should include 

exemptions for particular trailer types or fleets- whether through a fleet exception approval 

process or by including an extensive list of trailer characteristics that would define an 

aerodynamic exemption. 

3. Incentivize Early Adoption of Fuel Efficiency Devices. With the federal regulation of the 

height, length and weight of our trailers, our solutions- and our ability to comply with these 

regulations - rely on our customers accepting the addition of aerodynamic devices to the 

frame of a trailer. If manufacturers are to be successful in influencing their customers to 

accept the inclusion of aerodynamic devices on new trailers, the regulations and 

complementary regulations or legislation should not create disincentives for compliance. 

Thus, we urge the EPA, NHTSA, other agencies and Congress to support legislation and 

adoption of ruJ es that: 

• Exempt the cost of devices intended to improve fuel efficiency from federal excise 

tax; 

• Exempt the weight of devices intended to improve fuel efficiency from federal freight 

weight limits; 

• Minimize the time, cost and complexity of complying with the reporting obligations 

under the Phase 2 rulemaking. While we would prefer that compliance be voluntary 

based on our industry's history of proactive introduction and adoption of aerodynamic 

and weight-saving innovations, and request consideration of same, we acknowledge 

that there will be a trailer requirement. Absent a voluntary program, required 

adoption is preferred over an unmanageable averaging compliance approach. 

As a technology leader in the semi-trailer industry, Wabash National welcomes any 

technology that assists our customers in improving overall freight efficiency. We support the 

goal of improving overall fuel efficiency and welcome continuing to work together - fleets, 

manufacturers, suppliers and regulators- to develop holistic, practical solutions that benefit all 

stakeholders. 

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