### EPA Hearing- Phase 2 Greenhouse Gas Emission Standards for Medium- and Heavy-Duty Engines and Vehicles The First Name In Tra il er

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### August 18 , 2015

- Long Beach, California Utility Trailer Manufacturing Statement

Paul G. McNamara- General Counsel Utility Trailer Manufacturing Company, headquartered locally in the City of Indust ry, is North America's l eading manufacturer of refrigerated semi-trailers and the country's third largest trailer manufacturer. Every day, our engineers and factory workers strive to deliver a lighter, stronger, more-efficient semi-trailer- a goal harmonious with the Phase 2 objectives. Accordingly , Utility Trailer asks that you modifY the proposal as published in a number of ways that reflect th e nature of the semi-trailer industry. 1. The trailer industry is an exceptionally competitive, low-margin industry. Utility, and the other manufacturers, have little ability to determine what customers want
. Large trucking fleets purchase the overwhelming majority of semi-traile rs; they demand trailers customized for their needs. Unless the manufacturer meets those needs in a reliable, cost-effective way, the customers will not purchase the trailer. This reality leads to the following three conclusions : a. Initially - The best approach is one where the demand for the technology comes from the customer. We urge Utility Trailer Manuf acturin g Company Page 1NHTSA and EPA to require that the trailer owner have certain fuel-efficient equipment on its trailer. The customers then would demand that manufacturers install the equipment on their trailers. b. Next, the final rulemaking should encourage customers to welcome the technologies, by exempting these technologies from excise taxes, weight limits, and length and width restrictions. c. Lastly , we encourage the EPA to abandon its bin-andaveraging approach in favor of requiring all van trailers

- except those demonstrabl y unsuited for the approved technologies (and many trailers fall into this category)

- to have the technology. This will alleviate the crushing administrative burden imposed by the binand-averaging approach. It also will avoid large purchasers attempting to game the system by using their market power to pressure a manufacturer to allocate non-aerodynamic-equipment- b earing trailers to those large purchasers
. And while I'm on the subject of minimizing administrative burden, we urge you to adopt a streamlined system of compliance. Trailer manufacturers currently affix a plate to each trailer certifying that the trailer meets all relevant DOT requirements. A similar approach would be us ef ul here. Utility Trailer Manufacturing Company Page 22. Maintain flexibility in out-year requirements
. The pro p osed rulemaking r egulations b ecome increasingly stringe nt by 2027. We understand that it is impossible to fore cast the s t a te of the transportation industry a dozen years from now. But what we know now i s that although curre ntly available technology will allow us to me et the 2018 standards, we don 't beli eve we have the t echno logy to d ay to meet the standard s proposed for 2027. Of c ours e, like you , we anticip ate a dvances in technology. But
we believe it appropriate to dela y esta blishing standards so far in the fu ture until th e Age n cy and indu stry h ave a better grasp on what the transportation indus try lo oks like as it e mbarks o n the second quarter of the 2 1 st century, and on what improvements
can be made economicall y and on a c ost-ju s tified basis.
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. Adop t reali stic exemptions for classes of e qu ipment wher e there is no cost-benefit ju s tification for installing th e equipment. The manufacturers build many trai lers for the food-service distribution business
. Th ese are not long-haul trailers; rather, they delive r the vast quantities of food and beverages from distribution centers to points throughout the c itie s and suburbs. This is how your groceries arrive at the Vons or the 7- 11
. These trailers spend most of their lives on lo cal roads, obeying local speed limits. They may trave l on the crowded urban freeways for
s hort distances, but most of their travel is well b e l ow 50 mph or i s in stop-and -go traffic. Th e benefit o f aerodynamic devices on these trailers is negligible , and some of the d evices- suc h as soUtility Trai ler M anufacturin g Com pany Page 3called boat tails and skirts- won't work because these trailers usually have roll-up doors incompatible with the boat-tail s; and many have loading ramps, which are incompatible with skirts. There is no reason to impose the cost of these devices on these trailers
. Additionally, some of these devices reduce productivity through increased weight and cost; this translates to more trailers in use and on the road
. 4. Make certain that any regulations adopted apply to imports. Foreign manufacturers import an increasing number of trail ers, e ither in finished form or in kits. To ensure the maximum benefit from the fmal EPA / NHTSA regulations, they must apply to all trailers wherever manufactured. In its rules regulating ozone-depleting fluorocarbons used to manufacture insulating foam in refrigerated trailers, the EPA did not regulate foreignmanufactured trailers
. As a result , thousands of trailers are manufactured in Mexico and China and imported here , all using chemicals and processes the EPA has banned in this country. We ask that you not overlook this in r egu lating greenhouse gasses . Thank you.

Utility Trailer Manufacturing Company Page4