EPA Hearing- Phase 2 Greenhouse Gas 

Emission Standards for Medium- and 

Heavy-Duty Engines and Vehicles 

The First Name In Trailers 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 Industry, is North America's leading 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-trailers; 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 Manufacturing Company Page 1 
NHTSA 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 demonstrably 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-bearing 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 useful 

here. 

Utility Trailer Manufacturing Company Page 2 
2. Maintain flexibility in out-year requirements. The prop osed 

rulemaking regulations b ecome increasingly stringent by 2027. 

We understand that it is impossible to forecast the sta te of the 

transportation industry a dozen years from now. But what we 

know now is that although currently available technology will 

allow us to meet the 2018 standards, we don't believe we have 

the technology today to meet the standard s proposed for 2027. 

Of course, like you , we anticipate a dvances in technology. But 

we believe it appropriate to delay establishing standards so far in 

the future until the Agen cy and industry h ave a better grasp on 

what the transportation industry looks like as it embarks on the 

second quarter of the 2 1st century, and on what improvements 

can be made economically and on a cost-justified basis. 

3 . Adopt realistic exemptions for classes of equipment where there 

is no cost-benefit justification for installing the equipment. The 

manufacturers build many trailers for the food -service 

distribution business. These are not long-haul trailers; rather, 

they deliver the vast quantities of food and beverages from 

distribution centers to points throughout the cities and suburbs. 

This is how your groceries arrive at the Vons or the 7- 11 . These 

trailers spend most of their lives on local roads, obeying local 

speed limits. They may travel on the crowded urban freeways for 

short distances, but most of their travel is well below 50 mph or 

is in stop-and-go traffic. The benefit of aerodynamic devices on 

these trailers is negligible, and some of the devices- such as soUtility Trailer Manufacturing Company Page 3 
called boat tails and skirts- won't work because these trailers 

usually have roll-up doors incompatible with the boat-tails; 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 trailers, 

either 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 regulating greenhouse 

gasses. 

Thank you. 

Utility Trailer Manufacturing Company Page4