### EPA Hearing- Phase 2 Greenhouse Gas Emission Standards for Medium- and Heavy-Duty Engines and Vehicles rheFirstNameln Trailers 

### August 1 8, 2015- Long Beach, California Utility Trailer Manufacturing Statement Jeffrey J. Bennett
- Vice President Engineering & 

### Development Utility Trailer Manufacturing Company appreciates the opportunity to comment on EPA's Phase Two Greenhouse Gas Emissions proposed trailer regulations. For over 100 years, Utility Trailer Manufacturing has manufactured truck trailers; we've grown to one of the top three manufacturers by volume in the United States. Every day , we strive to improve the standard of living by providing high-quality transportation products and other services to the transportation industry. Being good stewards of the earth is a major part of our mission. Utility Trailer and its customers continuously seek to provide safe and improved products, services, and efficiencies. Customers haul trailers on all types of roads , the rail, and by sea. They must perform reliably and safely in extremely harsh, and at times , punishing environments. Trailer design has evolved over time in these environments , which is why there is great concem abou t the proposed EPA GHG-2 trailer regulations. The EPA regulations propose to reduce the C02 output of trucks by employing aerodynamic devices to long- and short-box Utility Trailer Manufacturing Company Page 1trailers. But the EPA's underlying analysis is incomplete in its failure to demonstrate how the lifecycle of these aerodynamic devices reduces the net carbon footprint. These devices , typically constructed from lightweight metal and plastic , require extreme heat and significant quantities of petrochemicals to produce. And once attached to a trailer, they are unlikely to survive more than a fraction of the trailer's expected life. Customers expect our freight trailers to last 15 years on average, but these aerodynamic trailer devices have only been available since 20 10. Man y early-adopter fleets report spending over $300,000 per year replacing damaged skirts and trailer tails on their long- box trailers . As a result, the amount of C02 output to produce and maintain the devices proposed by the Agency is still, to this day, unknown , growing, and may exceed any aerodynamic savings. Currently, the claimed fuel savings for trailer aerodynamic devices are significantly overstated . For example, many trailer aerodynamic devices, approved by EPA Smartway, that claim to provide (5 to lO)o/o fuel savings. But these fuel savings are based on overly simplified tests. Some tests, for example, are conducted at a constant cruise speed of 65-miles per hour on level roads
- not a real-world situation. A large , long-haul customer fl eet of ours measured and r ecorded the percentage of time that its fleet
- consisting of 4 ,000 trucks and 7,000 long-box trailers
- traveled at various speeds from 0-mph to 65-mph over the past six months. On average, the trucks spent less than 1.3o/o of the time at or above 65-mph . 20o/o of the time was between 60-65 mph , and 40o/o of the Utility Trailer Manufacturing Company Page 2time the truck was stopped while the engine was running , waiting for traffic, or something else. I've included a graph with my remarks showing results for all speeds. This real-world study contradicts the speed assumptions that the Agency used in its GEM-2 analysis (GEM-2 analysis of 86°/o at 65-mph cruise, 9°/o at 55-mph cruise, and 5°/o transient) . For a proper fuel-savings estimate, the aerodynamic fuel savings measured at each speed must be multiplied by the actual percentage of time the truck travels at that specific speed and summed to an expected average savings. The Agency has failed to provide such a study. In addition, the Agency has proposed trailer speeds in their analysis that are dramatically greater than what has been measured in the field. We have performed a study based on an EPA Smartway approved trailer side skirt that measured a 7.5°/o fuel savings per the SAE-1321, type-2 modified certification test . Using a CFD analysis, the fuel savings was determined at each speed, from 0- mph to 65-mph. The aerodynamic fuel savings at each speed was then multiplied by the actual, measured fleet percentage of time at that speed, and summed up to arrive at a total cruising speed fuel savings of 1.7°/o across the total measured speed spectrum. This total 1.7o/o savings applies to only the fraction of fuel used for cruising at constant speed on flat ground, not for accelerations, and not for going uphill. Thus , the total fuel savings is less than 1.7°/o of the total fuel used and not the 7.5o/o claimed by EPA.

Utility Trailer Manufacturing Company Page 3How can less than a 1 .7°/o of the total expected fuel savings justify the C02 output required to manufacture , install, and later replace, when damaged, this trailer aerodynamic device? In addition, the Agency has neglected the average trailer-to-truck ratio in the typical trailer fleet. Several of our customer fleets have two trailers for every truck, which doubles the required time and required fuel savings for any C02 pa yb ack to justify the trailer aero device. The Agency stated that it intends not to allow any yaw angle effects to measure efficiencies from trailer aero devices. From our experience from SAE 1321-type track testing, and CFD analysis, yaw angle, or cross winds, increase the fuel savings of side skirts and decrease fuel savings of trailer tails; therefore , the Agency must not ignore the effect of y aw angle on aerodynamic devices. The Agency's impact analysis also failed to account for the substantial reduction in tire life associated with low
-rollingresistance tires and from using tire-inflation systems . Because lowrolling-resistance tires are stiffer, they wear faster due to tire scrubbing, curbing, and other wear and tear. Tire inflation systems add pressure to inflate tires to a set, optimum pressure. But when the tires inevitably h eat up, the pressure increases above that setting, causing the tires to run overinflated. This rapidly deteriorates the tire tread. This increase in tire degradation requires more frequent tire replacement, which increases the C02 out put. The Agency has failed to demonstrate how these tires and Utility Trailer Manufacturing Company Page 4tire inflation systems will generate sufficient savings to make up for the additional C02 released into the atmosphere from additional tires needed during the useful life of trailers. The GEM model and what the Agency has proposed for compliance averaging (bins) would be unmanageable in the trailermanufacturing industry. Trailer orders are comprised of choosing a standard trailer base model, standard options, and a quantity. Added to these are a large number of special, customer-specific options, which can make up approximately 2 

### I 3 of the trailer specifications on a customer order. In addition, numerous changes to specification and quantity are made right up to the time we begin to build the trailer on the assembly line. Many of the customerrequired options conflict directl y with trailer aerodynamic devices , tires, and tire-inflation systems . A better approach would be for the OEM to pick from a list of EPA approved devices and install those on all trailer orders if practicable. Utility Trailer manufacturing and its customers welcome any technology that truly reduces the total, net C02 output and cost associated with the safe , clean, and efficient d elivery of goods to American consumers. We support EPA's goals but warn against regulations that can overstate fuel and C02 reductions and that may actually increase C02 output, and without achieving the goal of a cleaner, safer, environment. Thank you. Utility Trailer Manufacturing Company Page 5

### Fuel Savings Study of EPA Smartway Device Across 

### Speed Spectrum:

Rolling %total % Time Cruising Aero Aero Resistance power at Expected Speed Aero Power Power Skirt Power Power %Aero (fuel} Specific Savings [MPH] Base [KW] [KW] [%]savings [KW} Power Savings Speed at Speed 0 0.000 0.000 0 0 0 0 39.80% 0.00% 2.5 0.005 0.005 7.34% 3.125 0.15 % 0.011% 2.30% 0.00% 7.5 0.134 0.124 7.34% 9.375 1.31% 0 .096% 2 .30% 0.00% 12.5 0.621 0.575 7.34% 15.625 3.55% 0.261 % 1.50% 0.00% 17.5 1.703 1.578 7 .3 4% 21.875 6.73 % 0.494% 1.10% 0 .01 % 22.5 3.620 3.354 7.34% 28.125 10.65% 0.782 % 1.00% 0.01% 27.5 6.609 6.124 7 .34% 34.375 15.12% 1.110% 1.10% 0 .01 % 32.5 10.909 10.108 7.34% 40.625 19.92% 1.462% 1.20% 0.02% 37.5 16.758 15.528 7.34% 46.875 24 .88% 1.826% 1.40% 0.03 % 42.5 24.395 22.604 7.34% 53.125 29 .85 % 2.191 % 2.30% 0.05% 47.5 34.058 31.558 7.34% 59.375 34.70 % 2.547 % 1.70% 0.04% 52.5 45.984 42 . 609 7 . 34% 65.625 39.37% 2.889% 4.20% 0.12% 55.5 54.326 50.339 7.34% 69.375 42 .05% 3.086% 3.10% 0.10% 57.5 60.414 55.980 7.34% 71.875 43.78% 3.213 % 4.10% 0 . 13 % 59.5 66.940 62.027 7.34% 74.375 45.47 % 3.338% 10.40% 0.35% 61.5 73.919 68.494 7 .34% 76.875 47.12% 3.458 % 19.50% 0.67% 63.5 81.368 75 . 396 7 . 34% 79.375 48.71% 3.575 % 1.70% 0 .06% 65.5 89.301 82.747 7.34% 81.875 50.26% 3.689 % 1.30% 0.05% 100.00% 1.65%
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