### UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

NATIONAL VEHICLE AND FUEL EMISSIONS LABORATORY

2565 PLYMOUTH ROAD

ANN ARBOR, MI 48105

- 2498

OFFICE OF

AIR AND RADIATION



### 1 April 14 , 2015

MEMORANDUM

SUBJECT: Example Compliance Scenarios for Proposed HD GHG Phase 2 Trailer Program

FROM: Jessica Brakora , Tad Wysor , Mechanical Engineer s , Assessment and Standards Division

TO: Greenhouse Gas Emissions Standards and Fuel Efficiency Standards for Medium

- and

Heavy

- Duty Engines and Vehicles

- Phase 2

- Docket EPA

- HQ

- OAR

- 201 4

- 0827

Introduction

As described in the Phase 2 HD GHG and Fuel Consumption Notice of Proposed Rulemaking,

EPA and NHTSA are proposing the first CO 2 

### emissions and fuel consumption regulations for trailer

manufacturers. The trailer industry has no experience with the process for complying with EPA

emissions or NHTSA fuel consumption regula tions. The concept of averaging, which is proposed as an

optional compliance flexibility for trailer manufacturers

, may add complexity to a process that is already

unfamiliar to vehicle manufacturers that are not currently regulated. The purpose of this memo is to

provide a set of hypothetical examples of how a trailer manufacturer might comply with the Phase 2

standards while meeting the needs of a variety of customers.

In this memo, we provide example scenarios to illustrate some of the different compli ance

options that would be available to trailer manufacturer s in the proposed program. The first set of

scenarios presented is for model year ( MY ) 2021, representing an earlier stage of the proposed phase

- in.

A second set of scenarios is presented for MY 2027, when we are proposing the program to be fully

phased

- in. We performed this analysis in terms of grams of CO 2 

### per ton

- mile; use a conversion of

10,180 grams of CO 2 

### per gallon of diesel to calculate the fuel consumption values.

Compliance Options Available in Proposed Trailer Program

The primary approach for a trailer manufacture to comply with the proposed program is for

every trailer produced to meet the proposed standards. The agencies expect a variety of technology

combinations from several device manufacturers would satisfactorily meet the proposed standards, and a

manufacturer would be able to offer its customers some flexibility in the c hoice of technology packages

they purchase. Trailer manufacturers that opt for this primary compliance approach would take on

basic recordkeeping and reporting responsibilities.

### Example Trailer Compliance Scenarios / Docket EPA

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2 Historically, EPA has created provisions that allow vehicle manufacturers th e option of

averaging, banking, and trading within their sales mix, which provides an additional flexibility for

manufacturers to achieve compliance. Averaging provisions allow a vehicle manufacturer to produce

and sell trailers that under

- comply with the standards as long as they make up for those sales with

sufficient over

- compliant trailers. Banking and trading provisions allow vehicle manufacturers to carry

over or sell end

- of

- year credits generated from over

- compliance. This proposal does not includ e

banking or trading provisions for the proposed trailer program, since the agencies believe these

provisions would disproportionately impact the large number of small businesses in the trailer industry.

See the preamble to this NPRM for a more detailed d iscussion of these impacts.

The agencies are proposing averaging provisions as a compliance flexibility for trailer

manufacturers for all model years of the program. As will be shown in the examples to follow, an

averaging compliance approach would allo w a trailer manufacturer to offer its customers a greater

number of technology options, since not all trailers sold are required to meet the proposed standards.

Customers would have the option of purchasing technology packages that meet or exceed the stan dards,

or they could choose to avoid purchasing some technologies. Trailer manufacturers that opt for an

averaging compliance approach would have additional recordkeeping responsibilities in that they must

ensure that their sales of adequately over

- compli ant trailers exceed their under

- compliant sales. These

manufacturers would also have to submit an additional end

- of

- year report describing their averaging

strategy.

Summary of Performance Levels for Trailer Technologies

As discussed in the preamble to this proposed rulemaking and its accompanying draft RIA, the

agencies evaluated several existing technologies and created metrics to evaluate their performance.

Table 1 presents performance levels described in the proposal for aerodynamic technologies, lower

rolling resistance tires, and automatic tire inflation (ATI) systems

, and provides example technologies

for reference. Delta C D 

### A i s the change in drag area, which is a measure of aerodynamic performance.

The tire rolling resistance level (TRRL) is the regulatory term for the coefficient of rolling resistance

(C RR 

### ) that a trailer manufacturer uses in compliance.

Table 1 : Summary of Performance Levels and Example Technologies

Aero dynamics  C D A (m 2 ) Example Technologies

Bin I 0.0 No Aero

Bin II 0.1 Gap Reducer

Bin III 0.3 Basic Skirt or Tail

Bin IV 0.5 Advanced Skirt or Tail

Bin V 0.7 Opt imized Skirts, Basic Combos

Bin VI 1.0 Skirt/Tail Combo

Bin VII 1.4 Opt imized Advanced Combos

Bin VIII 1.8 Future Devices/Redesign

Tire Rolling Resistance TRRL (kg/ton) Example Technologies

Baseline 6.00 Baseline Tires

Level 1 5.10 SmartWay Tires

Level 2 4.70 Top 25% SmartWay Tires

Tire Inflation Effectiveness Description

ATI 1.5% Automatic Tire Inflation

### Example Trailer Compliance Scenarios / Docket EPA

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3 The proposed regulations include a list of 12 light

- weight components and six tire/wheel options

that a manufacturer could install on its trailer s for weight reduction. For simplification in this set of

examples, we are combining some of these components into four packages. The first two packages are

the substitution of standard steel wheels with aluminum wheels. Package 1 substitutes eight dual

- wide

steel wheels with eight aluminum wheels

, and Package 2 substitutes eight steel wheels with four

aluminum wide

- based single wheels and tires for additional weight savings. Package 3 is a combination

of weight savings by installing aluminum versions of four components found on the underside of box

trailers: landing gear (50 lb), slider box (150 lb), suspension assembly (280 lb), and upper coupler

assembly (430 lb). Package 4 is a combination of five aluminum trailer body components: roof bows

(100 lb ), rear door surround (150 lb), rear door (187 lb), floor crossmembers (203 lb), side posts (300),

and the complete floor (375). Table 2 summarizes the weight savin gs for each package.

Table 2 : Summary of Weight Reduction Packages Used in Compliance Examples

Weight Reduction Weight Reduc ed (lbs) Description

Base 0 Standard Components

Package 1 168 Aluminum Dual Wheels

Package 2 556 Aluminum Wide

- Based Single Wheels

Package 3 910 Underside Components

Package 4 1 315 Trailer Body Components



### The performance parameters for aerodynamics and tires are combined with the combined weight

savings from any light

- weight component substitutions and the improvement for use of ATI to

determine CO 2 

### emissions and fuel consumption from a tractor

- trailer vehi cle. The agencies developed

an equation for trailer manufacturers to combine the effects of these technologies and calculate CO 2 

### emissions for compliance. The equation is based on the EPA’s heavy

- duty vehicle simulation tool, the

Greenhouse gas Emissions Model (GEM) , that is used for compliance by other heavy

- duty vehicle

sectors

. Equation 1 is the proposed equation for long box dry vans.

(1)

The performance parameters (i.e., C RR 

### and  C D 

### A) for tire rolling resistance and aerodynamic

technologies would be established from testing. The tests could be performed by the trailer

manufacturer, or the trailer manufacturer may obtain performance parameters from aerodynamic device

or tire manufact urers who performed the testing. The weight reduction (WR) value would be a sum of

the approved light

- weight components that are installed on the trailer. The constant, C 5 

### , is equal to

0.985 (to account for the 1.5 percent improvement) if a trailer insta lls ATI, otherwise it is 1.0.

Throughout this memo, Equation 1 is used to calculate the CO 2 

### emissions. As mentioned previously, we

performed this analysis in terms of grams of CO 2 

### per ton

- mile; use a conversion of 10,180 grams of CO 2 

### per gallon of diesel to calculate the corresponding fuel consumption values for compliance with

NHTSA’s regulations.

Description of Example Customers

In each example s cenario described in this memo, we considered a long box dry van

manufacturer that sells a total of 100 trail ers to four customers with different needs and preferences for

### Example Trailer Compliance Scenarios / Docket EPA

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4 their orders. Table 3 introduces the four customers , their preferences, and their order s izes . For

sim plicity, the customers and the number of trailers in their orders remain the same in each scenario

presented. We recognize that manufacturers may produce mor e than a single type of trailer, sell more

than 100 trailers , and have more than four customers. The concepts presented here can be easily

translated to larger production volumes and the other regulated trailer subcategories. A short description

of some of the subcategory differences is provided at the end of these examples.

Table 3 : Description of Customers for Example Compliance Scenarios

Customer Typical Application Acceptance of Technologies Units in Order

1 Short

- and long

- haul Reluctant to adopt aero 30

2 Mostly short

- haul Reluctant to adopt any tech 10

3 Mostly long

- haul Willing to adopt all tech 40

4 Mostly long

- haul Reluctant to adopt ATI 20



### Example Compliance Scenarios

Under the primary proposed compliance provisions, long and short box van manufacturers could

produce all of their regulated trailers to meet the standards. Alternatively, these manufacturers would be

allowed to use averaging within a model year, in which case some of their trailer production could

under

- comply if enough of their o ther trailers over

- complied. This set of examples describes si tuations

where a manufacturer was assumed to use both proposed approaches , with and without averaging, for

compliance. The first set of scenarios present the primary, non

- averaging compliance approach, and the

second set uses the averaging compliance appr oach.

Each set of scenarios includes examples for model year (MY) 2021, which represents an early

stage of the proposed phase

- in, and MY 2027, when we are proposing the program to be fully phased

- in.

In the early stages of the program, the proposed stan dards could be met with the use of technologies at

lower performance levels. As a result, more technology options would be available to comply with the

standards than later in the program when the standards would become more stringent. If some

customers are reluctant to adopt certain technologies, the manufacturer would be able to offer several

alternatives that have similar performance levels. Once the program is fully phased

- in in MY 2027, the

standards would be more stringent and it is less likely tha t trailer manufacturers would be able to rely on

reduced

- technology packages meeting the standards

.

Primary Compliance Scenario s

The primary strategy for a manufacturer to comply with the proposed standard would be for all

of its regulated trailers to p erform at or better than the applicable standard for that model year. Below

are descriptions of two example scenarios that adopt th is compliance approach. The first scenario offers

more flexibility for customers to choose technolog y packages based on their preferences. A trailer

manufacturer adopting this approach would likely evaluate several technology combinations to ensure

each of the trailers sold meet the standards , which may require some additional recordkeeping . The

second scenario describes a very simplistic strategy for achieving the proposed standards for the given

model year. The trailer manufacturer’s c ustomers in this second scenario would still maintain some

choice in technology options, but only a limited set of combinations would be offered. This scenario

would require the least amount of recordkeeping for the trailer manufacturer.

### Example Trailer Compliance Scenarios / Docket EPA

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5 Example 1: MY 2021 Primary Compliance Scenario



### In the first example, a manufacturer is opting to use the primary compliance approach, and wants

to satisfy its customer’s preferences as much as possible, while still meeting the standards. Table 4

illustrates how a manufacturer might provide technology package s for the four customers described in

Table 3

. The proposed CO 2 

### standard for long box dry vans in MY 2021 is 81 gCO 2 

### /ton

- mi. E ach trailer

sold in this scenario met or exceeded the standard, as shown at the bottom of Table 4 . In a primary

compliance scenario, the trailer manufacturer does not receive any benefit from over

- compliant trailers

(i.e., those sold to Customers 3 and 4).

Under the primary compliance approach , no customers could purchase under

- compliant trailers.

In this case, Customer 1 wanted to minimize aerodynamic technologies, but was willing to order a very

basic t ail device (Bin III) on its trailers. To make up for the lower aero performance, Customer 1

ordered tires with the lowest rolling resistance , an ATI system, and the largest weight

- reduction

package . Similarly, Customer 2 reluctantly ordered trailers with modest aerodynamics (Bin I II ), but

chose to install lighter

- weight component packages, including single wide tires, on its trailers in order to

avoid ATI and the highest performing tires . Customer s 3 and 4 met chose to purchase trailers with

higher

- perfo rming aerodynamic packages and tires

. C ustomer 3 installed ATI systems, Bin VI

aerodynamics

, and level 2 tires on all of its trailers. Customer 4 opted for some weight reduction

packages in order to avoid the use of ATI systems.

Table 4 : Example Technology Adoption Rates for Four Customers in a MY 2021 Flexible Primary Compliance

Scenario

Long Dry Van Cust 1 Cust 2 Cust 3 Cust 4

0.0 Aero Bin I

0.1 Aero Bin II

0.3 Aero Bin III 100% 100%

0.5 Aero Bin IV

0.7 Aero Bin V 100%

1.0 Aero Bin VI 100%

1.4 Aero Bin VII

1.8 Aero Bin VIII

Average Delta CdA 0.3 0.3 1.0 0.7

6.00 Baseline 0% 0% 0% 0%

5.10 TRRL 1 100%

4.70 TRRL 2 100% 100% 100%

Average CRR 4.7 5.1 4.7 4.7

1.50 Adopt ATI 100% 100%

ATI 1.5% 0.0% 1.5% 0.0%

0 None

168 WR Package 1 100%

556 WR Package 2 100%

910 WR Package 3 100%

1315 WR Package 4 100% 100% 100%

Weight Reduction 1315 2781 0 1483

Customer CO 2 (g/ton

- mi) = 81 81 78 80

Customer Order (trailers) = 30 10 40 20

### Example Trailer Compliance Scenarios / Docket EPA

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6 Prior to the model year

, a manufacturer adopting a similar compliance strategy as shown in Table

4 may wish to consider and keep track of which combination of technologies would result in compliant

trailers when deciding the technology packages to offer to its customers. The trailer manuf acturer would

not need to analyze its sales throughout the year as long as each of the trailers sold continued to meet the

standards. At the end of the year, this trailer manufacturer would submit a production report to the

agencies that includes the prod uction volumes and performance of the trailers sold. A detailed

description of the reporting and recordkeeping requirements is available in 40 CFR 1037.250.

Example 2: MY 2021 Simplified Pri mary Compliance Scenario



### The simplified primary compliance example is shown in Table 5

. In this example, the trailer

manufacturer established a base set of technolog ies for all of its trailers to ensure that every trailer was

compliant

. E very trailer sold includes at least Bin V aerodynamic technologies, Level 1 rolling

resistance tires, and a n ATI system. The trailer manufacturer in this scenario would not restrict the

purchase of additional technologies , as demonstrated by C ustomers 3 and 4 choos ing to purchase trailers

with higher

- performing aerodynamic technologies and light

- weight components, respectively

.

Table 5 : Example Technology Adoption Rates for Four Customers in a MY 2021 Simplified Pr imary

Compliance Scenario

Long Dry Van Cust 1 Cust 2 Cust 3 Cust 4

0.0 Aero Bin I

0.1 Aero Bin II

0.3 Aero Bin III

0.5 Aero Bin IV

0.7 Aero Bin V 100% 100% 100%

1.0 Aero Bin VI 100%

1.4 Aero Bin VII

1.8 Aero Bin VIII

Average Delta CdA 0.7 0.7 1.0 0.7

6.00 Baseline 0% 0% 0% 0%

5.10 TRRL 1 100% 100% 100% 100%

4.70 TRRL 2

Average CRR 5.1 5.1 5.1 5.1

1.50 Adopt ATI 100% 100% 100% 100%

ATI 1.5% 1.5% 1.5% 1.5%

0 None

168 WR Package 1

556 WR Package 2

910 WR Package 3

1315 WR Package 4 100%

Weight Reduction 0 0 0 1315

Customer CO 2 (g/ton

- mi) = 81 81 79 79

Customer Order (trailers) = 30 10 40 20

### Example Trailer Compliance Scenarios / Docket EPA

- HQ

- OAR

- 2014

- 0827

7 While this simplified compliance scenario reduces the number of options the manufacturer has to

offer its customers, it maintains a degree of flexibility by not requiring the use of a single make or model

of any technology. Several vendors and technology models are available today that meet these

qualifications, and the trailer manufacturer would be able to allow its customers some choice of specific

technologies to apply. Specifically, many of the aerodynamic technologies currently verified by

SmartWay are expected to perform at Bin V levels, so manufacturers would have many options in terms

of device design and manufacturer. Similarly, Baseline tires are those that meet the SmartWay threshold

for verification, and thus there would be many such tire opt ions. The agencies are also aware of at least

four ATI systems from three manufacturers that manufacturers could choose.

The reduced flexibility of th is simplified compliance scenario provides the trailer manufacturer

with the lowest compliance burden of the options evaluated in this memo . The manufacturer would only

need to evaluate technology package s that meet the baseline performance criteria and ensure every

trailer sold included a m inimum of that base technology p ackage . Any additional technologies added to

a trailer would result in over

- compliance and would not benefit the manufacturer in this scenario. The

m anufacturers would still need to submit a n end

- of

- year production report to summariz e the year’s sales

and confirm that a baselin e performance package was installed on each trailer sold

.

Example 3: MY 2027 Primary Compliance Scenario



### The proposed trailer program would be fully phased

- in by MY 2027. The CO 2 

### standard for long

box dry vans is 77 g/ton

- mi in MY 2027, and the trailer s sold by the trailer manufacturer would have to

include higher performing technologies to comply. In this set of primary compliance examples, all

trailers sold will have to meet the standard. As seen in Table 6

, the trailer manufacturer could not design

a compliant trailer with less than Bin V a erodynamics. Equation 1 indicates that aerodynamic

improvements to long dry vans are more than three times as effective at reducing CO 2 

### compared to the

other technologies. Consequently , n one of the other technology options were effective enough to make

up for a lack of aerodynamic improvement in the fully phased

- in program

.

Customer 1 was initially reluctant to include aero o n its trailer, but was given a great deal on a

Bin V aerodynamic package for its order. It completed its compliant trailers order with TRRL 2 tires

and ATI systems, and several weight reduction packages. Customer 2 was reluctant to order any

technologies for its trailers, but settled on slightly more aero and weight reduction to avoid both ATI and

the higher level of tires. Customers 3’s order from MY 2021 was very close to compl iant with the MY

2027 standard, and the customer opted to order trailers wit h more advanced aero , which exceeded the

standard . Customer 4 chose Bin VI aero and an additional weight reduction package in order to

continue to avoid purchasing ATI systems.

As noted previously, trailer manufacturers that produce over

- compliant trailers do not receive

any benefit from in them in a primary compliance strategy. However, some trailer manufacturers may

consider the relatively few recordkeeping and reporting requi rements to be an acceptable compromise.

Similar to Example 2, a manufacturer may choose a minimum set of technologies to its customers to

ensure comp liance in MY 2027. The process is similar to the previous example and an additional

example is not shown for this standard.

### Example Trailer Compliance Scenarios / Docket EPA

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8 Table 6 : Example Technology Adoption Rates for Four Customers in a MY 2027 Primary Compliance Scenario

Long Dry Van Cust 1 Cust 2 Cust 3 Cust 4

0.0 Aero Bin I

0.1 Aero Bin II

0.3 Aero Bin III

0.5 Aero Bin IV

0.7 Aero Bin V 100%

1.0 Aero Bin VI 100% 100%

1.4 Aero Bin VII 100%

1.8 Aero Bin VIII

Average Delta CdA 0.7 1.0 1.4 1.0

6.00 Baseline 0% 0% 0% 0%

5.10 TRRL 1 100%

4.70 TRRL 2 100% 100% 100%

Average CRR 4.7 5.1 4.7 4.7

1.50 Adopt ATI 100% 100%

ATI 1.5% 0.0% 1.5% 0.0%

0 None

168 WR Package 1 100%

556 WR Package 2 100% 100%

910 WR Package 3 100% 100% 100%

1315 WR Package 4 100% 100% 100%

Weight Reduction 2781 2781 0 2393

Customer CO2 (g/ton

- mi) = 77 77 76 77

Customer Order (trailers) = 30 10 40 20



### Summary of the Pri

mary Compliance Approach



### If a trailer manufacturer opted to use the primary compliance approach, it could offer any

number of combinations to its customers, as long as each combination met the standard. Trailer

manufacturers could allow customers to choose from any combination of compliant trailers (e.g.,

Example s 1 and 3 ) or establish a minimum set of technologies for every trailer sold to ensure

compliance (e.g., Example 2). In the compliance scenarios described so far, each customer ordered a

single set of trailer technologies . Of course, customers may wish to purchase multiple combinations of

trailer technologies in a single order, and this can easily be accomplished using the primary compliance

approach. The certification application and end

- of

- year reporting requirements f or a trailer

manufacturer would not change significantly by offering a greater number of compliant trailer options.

### Example Trailer Compliance Scenarios / Docket EPA

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9 Averaging Compliance Scenarios

In th e following scenario s , the trailer manufacturer chose to use the proposed averaging

provisions. This compliance approach allows the manufacturer to offer its customers the largest range

of technology options for their trailers. The se examples will show that the four customers’ technology

preferences that were outlined previously in Table 3 could be better reflected in an averaging scenario;

the customers that wanted fewer (or no) technologies could be accommodated. However, i t will also be

shown that a trailer manufacturer adopting an averaging scenario would have additional reporting and

recordkeeping requirements, and would likely need to consider both the performance level and

production volume of their trailers sold throughout the model year to ensure end

- of

- year compliance.

Example 4 : MY 2021 Averaging Compliance Scenario



### During the certification application process, a manufacturer that wishes to use the a veraging

provisions would identify trai ler “subfamilies” that have similar performance. The technology packages

used in each subfamily would have unique target performance value s, or Family Emission Limit s

(FEL s ). In the primary (non

- averaging) compliance strategy, subfamilies are not necessa ry, since every

trailer produced would meet the standards. In an averaging compliance strategy, as described next, a

production

- weighted average of the FELs is used to determine compliance.

Table 7 illustrates the technology choices of the four customers in this averaging scenario.

Similar to the primary compliance example, Customer 3 was willing to order trailers that include several

of the more advanced technologie s (i.e

. , Bin VI aerodynamics, tires with the lowest rolling resistance

, ATI systems ). Since Customer 3 has the largest order, the trailer manufacturer encouraged it include

weight

- reducing component substitutions , which resulted in additional CO 2 

### reductions for the trailer

manufacturer

. The same 81 gCO 2 

### /ton

- mi standard applies in this scenario, and Customer 3’s order

resulted in CO 2 

### reductions well below what was needed for the manufacturer to comply with the

standard. Because of this over

- compl iance for part if its production, the manufacturer could offer

trailers with fewer technologies to its other customers

.

Customer 1 was reluctant to order trailers with aerodynamic technologies, but was willing to

order them with lower rolling resistance tires, ATI systems, and two weight reduction options. T he

absence of aerodynamics on these trailers still led to an under

- compliant FEL at 83 g/ton

- mi that the

manufacturer would need to offset with sales of over

- complying trailers to other customers. Cu stomer 2

preferred not to adopt any of the technologies and the FEL for its order was 8 8 g/ton

- mi, representative

of the zero

- technology baseline for long

- box dry vans. Customer 4, which did not want to order ATI

systems, was still willing to order traile rs with some signi ficantly

- effective aerodynamics, the lowest

rolling resistance tires, and some light

- weight components, which result ed in a compliant FEL of 81

g/ton

- mi

.

### Example Trailer Compliance Scenarios / Docket EPA

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10 Table 7 : Example Technology Adoption Rates for F our Customers in a MY 2021 Averaging Scenario with Four

Subfamilies

Long Dry Van Cust 1 Cust 2 Cust 3 Cust 4

0.0 Aero Bin I 100% 100%

0.1 Aero Bin II

0.3 Aero Bin III

0.5 Aero Bin IV

0.7 Aero Bin V 100%

1.0 Aero Bin VI 100%

1.4 Aero Bin VII

1.8 Aero Bin VIII

Average Delta CdA 0.0 0.0 1.0 0.7

6.00 Baseline 0% 100% 0% 0%

5.10 TRRL 1

4.70 TRRL 2 100% 100% 100%

Average CRR 4.7 6.0 4.7 4.7

1.50 Adopt ATI 100% 100%

ATI 1.5% 0.0% 1.5% 0.0%

0 None 100%

168 WR Package 1

556 WR Package 2

910 WR Package 3

1315 WR Package 4 100% 100%

Weight Reduction 1315 0 1315 0

Customer CO 2 (g/ton

- mi) = 83 88 77 81

Customer Order (trailers) = 30 10 40 20



### In this scenario, the manufacturer has calculated a CO 2 

### value for each customer’s order. Since

each order results in a unique CO 2 

### value, each trailer order becomes a subfamily within the long dry van

family, and the CO 2 

### results become the FEL s for the s ubfamilies . The manufacturer would calculate a

production

- weighted average of all its FELs as follows: 30% x 83g/ton

- mi + 10% x 8 8 g/ton

- mi + 40% x

7 7 g/ton

- mi + 20% x 81 g/ton

- mi to arrive at the overall compliance level of 8 1 g/ton

- mi

. Since this level

matched the standard in this example, the manufacturer would be in compliance with the standard for

that model year.

Example 5 : MY 2021 Averaging Compliance Scenario with Additional Subfamilies



### To further illustrate averaging

, we assume that some of the customers ordered the same number

of trailers, but with multiple technologies. Table 8 provides one example of multiple technologies for

the different custome rs. Customer 1 p referred that half of its order install level 2 tires with ATI and the

other half install level 3 tires without ATI

. Customer 2 continued to order trailers with no technologies.

Customer 3 wanted a few of its trailers to have lower

- perfo rming aerodynamic technology. Customer 4

preferred to split its order among three different aerodynamic technologies.

### Example Trailer Compliance Scenarios / Docket EPA

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11 Table 8 : Example Technology Adoption Rates for Four Customers in a MY 2021 Averaging Scenario with

Additional Subfamilies

Long Dry Van Cust 1 Cust 2 Cust 3 Cust 4

0.0 Aero Bin I 100% 100%

1.0 Aero Bin II

0.0 Aero Bin III

0.0 Aero Bin IV 30%

0.0 Aero Bin V 10% 60%

0.0 Aero Bin VI 90% 10%

0.0 Aero Bin VII

0.3 Aero Bin VIII

Average Delta CdA 0.0 0.0 1.0 0.7

6.00 Baseline 0% 100% 0% 0%

5.10 TRRL 1 50%

4.70 TRRL 2 50% 100% 100%

Average CRR 4.9 6.0 4.7 4.7

1.50 Adopt ATI 5 0% 100%

ATI 0.8 % 0.0% 1.5% 0.0%

0 None 100%

168 WR Package 1

556 WR Package 2

910 WR Package 3

1315 WR Package 4 100% 100%

Weight Reduction 1315 0 1315 0

Customer Order (trailers) = 30 10 40 20



### Each unique trailer technology combination shown in Table 8 has the potential to result in

different trailer performance. Table 9 shows the CO 2 

### levels for the di fferent trailer packages, along with

the number of trailers with those technologies, in each customer’s order. Subfamilies are identified by

CO 2 

### level (i.e., FEL)

. The order from Customer 3, colored pink in Table 9

, includes four trailers with a

technology package that r esu lts in an FEL of 79 g/ton

- mi. The technology package on a pair of trailers

in Customer 4 ’s order also resulted in an FEL of 79 g/ton

- mi . T he se t wo trailer sets from different

orders with different technologies could be combined into a single subfamily for compliance purposes.

The remaining trailer orders resulted in unique FELs and would be considered separate subfamilies

.

Table 9 : Example Compliance Results for MY 2021 Averaging Scenario with Additional Subfamilies

Cust 1 Cust 2 Cust 3 Cust 4

Customer CO 2 (g/ton

- mi)

= 83 84 88 79 77 82 81 79

Customer Order (trailers) = 15 15 10 4 36 6 12 2



### The manufacturer in this averaging scenario would have produced a total of seven subfa milies.

Each subfamily results in a unique FEL, which is used to calculate manufacturer’s production

- weighted

average as follows: 15% x 83 g/ton

- mi + 15% x 84 g/ton

- mi + 10% x 88 g/ton

- mi + 4% x 79 g/ton

- mi +

36% x 77 g/ton

- mi + 6% x 82 g/ton

- mi + 12% x 81 g/ton

- mi + 2% x 79 g/ton

- mi. The calculation

results in an overall compliance value of 81 g/ton

- mi, which is also in compliance with the standard for

### Example Trailer Compliance Scenarios / Docket EPA

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12 MY 2021. Compared to the averaging scena rio presented in Example 3, the variety of technology

packages in Example 4 results in more subfamilies

, additional recordkeeping and a few more

calculations.

Example 6: MY 2027 Averaging Compliance Scenario



### The proposed MY 2027 CO 2 

### standard for long box dry vans is 77 g/ton

- mi. As shown in

, Customer 3 again ordered the most advanced technologies , including Bin VII aero the tires at the highest

level, ATI, and two weight reduction packages . As a result, the manufacturer over

- compl ied with the

MY 2027 standard for this order with an FEL of 74 g/ton

- mi. As in the MY 2021 averaging scenario,

this would allow the manufacturer to offer lower

- performing technology options to other customers.

Customer 1 was willing to order the TRRL 2 tires, ATI, and significant weigh reduction, as it did

in Example 3. However, this trailer manufacturer was able to offer this customer under

- compliant

trailers with Bin IV aero (instead of Bin V, which was needed in Example 3) for an FEL at 78 g/ton

- mi.

In this example, Customer 2 was able to order trailers with zero technologies for an FEL of 8 8 g/ton

- mi.

Customer 4 again wanted to avoid ATI systems, but was still willing to order some Bin VI

aerodynamics, high

- performing tires, and two large weight re duction packages, which resulted in a

compliant trailer order at a n FEL of 7 7 g/ton

- mile.

Table 10 : Example Technology Adoption Rates for Four Customers in a MY 2027 Averaging Scenario with Four

Subfamilies

Long Dry Van Cust 1 Cu st 2 Cust 3 Cust 4

0.0 Aero Bin I 0% 100%

0.1 Aero Bin II

0.3 Aero Bin III

0.5 Aero Bin IV 100%

0.7 Aero Bin V

1.0 Aero Bin VI 100%

1.4 Aero Bin VII 100%

1.8 Aero Bin VIII

Average Delta CdA 0. 5 0.0 1.4 1.0

6.00 Baseline 0% 100% 0% 0%

5.10 TRRL 1

4.70 TRRL 2 100% 100% 100%

Average CRR 4.7 6.0 4.7 4.7

1.50 Adopt ATI 100% 100%

ATI 1.5% 0.0% 1.5% 0.0%

0 None

168 WR Package 1

556 WR Package 2

910 WR Package 3 100% 100% 100%

1315 WR Package 4 100% 100% 100%

Weight Reduction 2 781 0 2225 2225

Customer CO 2 (g/ton

- mi) = 78 88 74 77

Customer Order (trailers) = 30 10 40 20

### Example Trailer Compliance Scenarios / Docket EPA

- HQ

- OAR

- 2014

- 0827

13 The production

- weighted average for these four subfamilies came out to 77 g/ton

- mi, which

means the trailer manufacturer met the MY 2027 standard. As with the MY 2021 averaging example s

, this example shows that averaging would allow the manufacturer to of fer some trailers with fewer

technol ogies. It can be seen that, in order for Customer 2 to order trailers with zero technologies, all of

the other customers had to purchase higher performing trailer in order to make up for the under

compliance resulting f

rom Customer 2’s order. This was possible due to the relatively small order from

Customer 2. A manufacturer would have a difficult time complying if a customer with a larger order

requested a minimum

- technology package in MY 2027.

As shown previously in the MY 2021 averaging example, customers could order trailers with

multiple levels of performance, but there would be fewer technology options capable of meeting the

higher performance targets by MY 2027. We do not illustrate that example here.

Summary of the Averaging Compliance Approach



### In summary, these set of example s show how averaging can give a manufacturer the flexibility to

meet its customers’ individual preferences. Specifically, 40 percent or more of the sales in these

averaging examples did not meet the overall standard for this model year. In fact, 10 percent of this

manufacturer’s sales had zero CO 2



### - reducing technologies. This strategy could be valuable for trailer

manufacturers that have customers willing to purchase sufficient numbers of trailers with higher

performing technologies that offset orders from customers that prefer fewer or lower

- performing

technologies. This flexibility would come with an increased compliance burden in terms of number of

subfamilies and CO 2 

### calculations , increased tracking of sales, and increased end

- of

- year reporting to the

a gencies, as well as the potential for more complex interactions with customers in sales negotiations.

All trailer manufacturers submit an end

- of

- year production report to EPA that summarizes their

annual sales. Trailer manufacturers that adopt an averagin g compliance approach would include a

description of the subfamilies in their application for certification, and would subm it a second end

- of

year report that describes their averaging strategy and the results for each of their subfamilies. These

manufact urers would not need to ensure that every trailer produced throughout the year met the

standard. However, they would benefit from keeping record throughout the year of the volume of sales

and an estimate of the CO 2 

### (and fuel consumption) level for each sa le to ensure that under

- complying

trailer sales do not account for a majority of the overall sales for the year. Otherwise, a manufacturer

could be in a situation where they have to make up for a large deficit at the end of the year in order to

comply.

Fi nal Notes

We are proposing to allow manufacturers the choice of the primary compliance program, or an

averaging program. Every year, the trailer manufacturer would choose a compliance approach.

M anufacturers m ay choose a single strategy throughout the program, or they change strategies at any

time. Some manufacturers may wish to do averaging early to ease customers into technologies, and

switch to the primary (non

- averaging) approach in the later years when it ma y be more difficult to

ensure compliance if trailers are sold with minimal technologies. Alternatively, a trailer manufacturer

may find it easier to exclusively sell compliant trailers in the earlier years, when fewer technologies

would be needed to meet the standard, and then convert to an averaging compliance program in the later

years, when some customers would be reluctant to adopt the more advanced technologies.