UNITED STATES ENVIRONMENTAL PROTECTION AGENCY NATIONAL VEHICLE AND FUEL EMISSIONS LABORATORY

2565 PLYMOUTH ROAD ANN ARBOR, MICHIGAN 48105 - 2498

MEMORA NDUM

SUBJECT: Truck and Trailer Roof Height Match Analysis FROM: Am y Kopin TO: The Docket DATE: August 9, 2010 T he aerody

namic performance of a combination truck is dependent on many factors, including tractor and trailer size and design, the gap between the tractor and trailer, vehicle speed, the height difference between the cab and trailer roofs, and many others. To assess the aerody namic performance of combinations trucks more accurately , certain aspects of the truck need t o be defined, including the use of a standardized trailer during testing
. We are proposing that the standardized trailer be determined by the roof height definition of the regulatory subcategories, including low, mid , and high roof designs
. Many tracto rs have roof fairings installed to improve aerody namic performance. The height of the roof fairing is designed to minimize the height differential between the tractor and ty pical trailer to maintain a smooth, attached airflow over the vehicle and reduce the air flow disruption , or drag
. Lo w roof tractors are designed to carry platform
- ty pe trailers, which can include flatbed or low
- boy

trailers. Mid roof tractors are designed to carry tanker
- ty pe trailers, which can include liquid and other bulk trailers
. High roof tractors are designed to pull box
- ty pe trailers , which can include dry

van trailers and refrigerated van trailers
. However, we recognize that during actual operation tractors may pull trailers that do not provide the optimal roof height that matches the tractor and reduces drag . In this memorandum, this situation will be referred to as a “mismatch
. ” Inorder to assess how often truck and traile r mismatches are found , we conducted a study based on observations of traffic across the U.S . The purpose of this memo is to describe how this study

was carried out, and to present the results. The intent of the study

was to sample traffic in various locations throughout the U.S. Originally , it was thought that truck weigh stations might provide goo d sources of this information, however, the best way

to assess the h eight match of tractors and trailers currently in use would be through individual counts in person , and there was not sufficient data from truck stops to determine the trailer height
. To avoid the need to phy sically travel to different sites across the country to count trucks , which would be cost prohibitive , we determined it was possible to sample traffic through OFFICE OF AIR AND RADIATIONthe use of traffic cameras. Nearly every state has a number of traffic came ras available for public viewing
. Some states offer a large number of available cameras for their drivers and visitors to view ; Figure 1 shows an example of the numerous available traffic cameras in Oregon. Figure 1 Example of Av ailable Cam eras - Oregon

Source: http://www.tripcheck.com/Pages/Cam erasEntry.asp Inmany cases, cameras are close enough to the road to easi ly determine if the tractor and trailer roof heights match ; only

cameras offering these close
- up views were used in this study
. Each camera used in this study was carefully

selected to provide a clear view of the truck and trailer roof height ; an example is shown below in Figure 2 . Cameras were observed between 9 AM and 6 PM as long as cle ar pictures could be observed (i.e. sufficient daylight was available to s ee the truck and trailer roofs and/or cle ment weather conditions were present that did not obscure camera views). D ata was taken in the last week of January , 2010 an d continued thro ugh the first week of February , 2010
. The data was taken such that at least one hundred consecutive truck and trailer combinations were recorded from each cameraFigure 2 Sample Im age froman Oregon Cam era

The study sampled i mages from 33 real
- time traffic cameras , collecting d ata on more than 4 , 000 tractor - trailer combinations
. Where possible, traffic passing in both directions was used in th is study
. The process consisted of keeping count of whether or not the tractor and trailer roof height profiles matched . A combination was considered to be a match if the height of the tractor roof was within a few inches of the height of the trailer roof, for example: if a tall trailer was hauling a tall container (as shown in Figure 2 ) , a medium roof tracto r was hauling a tanker, and a low roof tractor was hauling a flatbed trailer. I f the combination didn’t match, a note was made as to what the combination was (e.g. high roof tractor with flatbed, etc.) Not es were also made if a tractor was empty (not hauling a trailer) or was hauling an empty flatbed trailer. The locations used in this study cover 22 states across the United States , and a number of main highways , seeFigure 3
. Ac ross this broad geographic range, we found that the cameras are located within

predominately

well
- populated areas, since the primary intent of these cameras is for the public to have access to real
- time traffic congestion data , which is ty pically not a pro blem in less well
populated areas.Figure 3 Location of Cam eras Where Traffic was Observed

Based on the data gathered, a pproximately

95% of trucks were “matched” per our definition (e.g. b ox trailers were pulled by high roof tractors and flatbed trailers were pulled with low roof tractors). Ingeneral, the occurrence of a truck being lower than the trailer (e.g. day cab and tall container) was over seven times as likely as a truck being higher than the trailer (e.g. high roof truck and flatbed trailer). The amount of mismatch varied depending on the ty pe of location surveyed , for example o ver 99% of the tractors were in matched configuration s in Indiana at the I - 80/I
- 94/ I - 65 interchange, which is representative of long
- haul o peration. On the other han d, in metro New York City , the match percentage was just over 90% , in which case every mis match ed combination consisted of a day cab and a tall container , Figure 4 shows the approximate locations of thes e traffic cameras.

Figure 4 Map of Lowest and Highest Mism atch Percentage Found in this StudyInaddition, this study also looked at the number of trucks without trailers or trucks hauling empty flatbeds, although the number of empty box trailers is unknown. It was found that of all the data included in this study (match and mismatch counts) that approximately 3% of the tractors were traveling without a trailer or with an empty flatbed ; the ratio between no trailer and empty fl atbed trailer wa s approximately 50 percent
. References: STATE WE BSITE Alabam a www.dot.state.al.us Arizona www.az511.gov California http://video.dot.ca.gov Colorado www.cotrip.org Del a ware www.deldot.gov Florida www.fl511.com Iowa http://hb.511ia.org/main.jsf Kansas http://www.kcscout.net Kentuc k y/ Ohio www.artim is.org/camaccess1.html Maine http://maineturnpike.com/traffic_cam s/traffic_cams.php Massachusetts http://www1.eot.state.m a.us/ Michigan http://mdotwas1.mdot.state.mi.us/public/drive/rtt.cfm#1 Minn esota http://www.dot.state.m n.us/tmc/trafficinfo/cameras_map.html Mississippi www.m straffic.com New York http://cameras.nysdot.gov/ New York http://peacebridge.com North Carolina http://www.greensboro - nc.gov/departments/GDOT/trafficinfo/ Ohio http://buckeyetraffic. org Oklahoma www.ok traffic.org Oregon http://www.tripcheck.com Tennessee http://www.tdot.state.tn.us/tdotsmartw ay / Texas http://amaits.dot.state.tx.us/AMA - ITS/default.htm Texas www.transguide.dot.state.tx.us