January 19, 2010

ISSUE

In order to have clear, appropriate, and implementable vehicle classifications in the 

GHG/FE regulation, EPA and NHTSA should adopt criteria for presumptively determining what 

qualifies as “combination tractors” and “heavy-duty pickup and vans.” Further, the Agencies 

should establish that vehicles that do not meet those criteria are, presumptively “vocational 

vehicles.” Finally, the Agencies should allow someone who believes that a vehicle is improperly 

categorized to have the burden of overcoming the presumptive criteria-based categorization. 

Set forth below are proposed definitions:

COMBINATION TRACTORS

The category only includes vehicles with a GVWR above 26,000 lbs. that meet the DOT 

definition for truck tractor, i.e., “a truck designed primarily for drawing other motor vehicles and 

not so constructed as to carry a load other than a part of the weight of the vehicle and the load so 

drawn.” See, 49 C.F.R. § 571.3.

Combination tractors have a front axle GAWR of 14,600 lbs. or less; and a single rear 

drive axle GAWR of 23,000 lbs. or less, or two rear drive axles with a combined GAWR of 

45,000 lbs. or less. They may have additional non-driven axles but a GVWR of 85,000 lbs. or 

less. 

Combination tractors are intended exclusively for on-highway applications and typically 

accumulate more than 50,000 miles annually. They are designed to operate within Federal size 

and weight limits, which may include use as part of a long combination vehicle. They are not 

intended for use that would require a special size or weight permit. 

If a vehicle meets these requirements, it will be presumed to be a combination tractor for 

the purposes of the GHG/FE regulation. If a manufacturer believes that a vehicle that meets the 

combination tractor definition is actually a vocational vehicle, the manufacturer has the burden 

of establishing that fact to the Agencies’ reasonable satisfaction. Factors that would meet the 

manufacturer’s burden of establishing that a vehicle meeting the combination tractor definition is 

actually a vocational vehicle include, without limitation: vehicle speed limiter set at 55 mph or 

less, PTO controls, extended front frame, ground clearance greater than 14 in., approach angle 

greater than 20°, frame RBM greater than 2,000,000 in.-lbs., or total gear reduction in low gear 

greater than 57, or total gear reduction in top gear greater than three. 

HEAVY-DUTY PICKUP TRUCKS AND VANS

Heavy-duty pickup trucks and vans are pickup trucks and vans with a GVWR between 

8,501 lbs. and 14,000 lbs. (Class 2b through 3) manufactured as complete vehicles by a single or 
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final stage manufacturer and include cab-complete vehicles that are first sold as incomplete 

vehicles that substantially include the vehicle cab section.

If a vehicle meets these requirements, it is presumptively a heavy-duty pickup truck or 

van for the purposes of the GHG/FE regulation. If a manufacturer believes that a vehicle that 

meets the heavy-duty pickup trucks and vans definition is actually a vocational vehicle, the 

manufacturer has the burden of establishing that fact to the Agencies’ reasonable satisfaction.

VOCATIONAL VEHICLES

Any vehicle that does not meet one of the definitions above is presumptively a vocational 

vehicle for the purposes of the GHG/FE regulation. If the Agencies believe that such a vehicle 

should actually be classified as a combination tractor or a heavy-duty pickup truck or van, the 

Agencies have the burden of demonstrating that.