UNITED STATES ENVIRONMENTAL PROTECTION AGENCY NATIONAL VEHICLE AND FUEL EMISSIONS LABORATORY

2000 TRAVERWOOD DRIVE ANN ARBOR, MI 48105
- 2498 OFFICE OF AIR AND RADIATION July 2 8 , 2015 MEMORANDUM SUBJECT: Meeting with Members of the T ruck Trailer Manufacturers Associ ation Regarding the Proposed Phase 2 Heavy
- Duty Greenhouse Gas and Fuel Efficiency Standards FROM: Jessica Brakora, Engineer, Assessment and Standards Division, Office of Transportation and Air Quality TO: Greenhouse Ga s Emissions Standards and Fuel Efficiency Standards for Medium
- and Heavy
- Duty Engines and Vehicles
- Phase 2
- Docket EPA
- HQ
- OAR
- 2014
- 0827
This me mo documents a meeting held on July 9 , 2015 in Ann Arbor, Michigan between representatives of the Truck Tr ailer Manufacturers Association (TTMA) an d EPA to discuss the recently
- proposed Phase 2 greenhouse gas and fuel efficiency standards for heavy
- duty vehicles . The six TTMA members attended the meeting and four participated by phone :

– John Freiler, TTMA

– G ary Fenton, Stoughton Trailers

– Justin Bell , Strick Trailers

– Jan Hoover, Strick Trailers

– Sam Guron, Talbert Mfg.

– Shannon Richardson , XL Specialized Trailer

– Andy Grow, East Mfg. Corp. (phone)

– Gary Christian, Etnyre and Co. (phone)

– Charles Fetz, Great Dane T railers (phone)

– Brian Polgrean, Heil Industries (phone) The following E PA representatives attended in the meeting:

– Jessica Brakora, A ssessment and Standards Division

– Tad Wysor, Assessment and Standards Division

– Charles Moulis , Assessment and Standards Di vision

– Alan Stout, Assessment and Standards Division

– Stephen Healy, Compliance Division The following NHTSA representatives participated by phone:

– Maurice Hicks, NHTSA

– Coralie Cooper, Department of Transportation’s Volpe CenterThe meeting included a bri ef overview of the status of the proposed HD Phase 2 program

presented by EPA and attached below. The presentation was followed by a discussion of the proposed program elements as outlined in the attached agenda . The meeting concluded with a list of item s TTMA wished to discuss during a follow
- up meeting on July 22, 2015 .

Attachment: EPA Trailer Outreach Meeting Agenda EPA presentation: “ TTMA Intro to Proposed Heavy
- Duty Rule ”

# EPA Trailer Outreach Meeting NVFEL Office Building, 2000 Traverwood Dr, Ann Arbor, MI 48105

July 9 th , 2015 – 12:30 to 3: 3 0 Eastern Conference Line: 1 - 866 - 299 - 3188 // Code: 734
- 214 - 4936 AdobeConnect: https://epa.connectsolutions.com/r3mswekq6sa/



# AGENDA

* Note that information shared during this meeting will be made public in the docket for the final rule * 12:30 Introductions & A nnouncements 12:40 Rulemaking Status: Publication in Federal Register on July 13; docket will be available with publication

 60 - day comment period begins July 13 and ends September 11, 2015  Two public hearings will be scheduled in August (Chicago, IL and Los Angeles, CA)  We will continue to meet with stakeholders and will try to address comments made after formal close of the comment period 12:50 What Trailers are covered? (Least to most) – Describe criteria for each category.

 Excluded Trailers – propo sed as completely out of the rule Requesting comment on “exclusion” (no requirements) vs “exemption” (reporting requirement)  Non - Box Trailers  Non - Aero Box trailers  Partial - Aero Box Trailers  Full - Aero Box Trailers 1:10 Requirements:

Non - Box and Non - Aero trailers  No aerodynamic requirements  Design standard for LRR tires & ATIS : requirements that phase in. Full - Aero Box Trailers  P hased in CO2 reduction requirements, based on year, length and reefer/dry van design  Can be met with any combination o f aero, LRR tires, ATIS, or weight reduction Partial - Aero Box Trailers  Same requirements as Full - Aero through MY 2026  Maintain MY 2024 in 2027 and later Present Table of Requirements. CO2 (g/ton
- mi) to Fuel ( g al/1000 ton
- mi) conversion. Discuss EPA model year designation 2:00 Compliance:

Preliminary steps & certification application Compliance Equation Inputs: LRR Tires, Aerodynamic Devices, Weight Reduction, ATIS. Data sources : (1) P re - approved vendor data and (2) Testing performed by manufacturer End of year reporting & optional a veraging provisions . (See attached “Memo to Docket” with example compliance scenarios) 3:00 Warrant y Requirements: Tires & other devices 3:15 Issues to be discussed further/in detail at our July 22 meeting in Alexandria, VA. Note: All times are approximate to allow some flexibility of discussion. Supplementary materials: Preamble and Reg ulation Reference s: “PreambleRegulationReferences.pdf” Compliance Scenarios: “ 2015 - 04 - 14_MemoToDocket_TrailerComplianceScenarios.pdf ” Small Business Final Panel Report: “ 2015 - 01 - 15_SBREFA_FinalPanelReport_FullDocument.pdf ”

# TTMA 

# Intro to Proposed Heavy - Duty

Rule July 9 , 2015 Jessica Brakora and Tad Wysor 

# U.S. Environmental Protection Agency brakora.jessica@epa.gov, wysor.tad@epa.gov

# Status of the Proposal & Next Steps

• NPRM signed June 19, 2015

– Available on EPA and NHTSA websites
• http:// www.epa.gov/otaq/climate/regs - heavy - duty.htm


# • http:// www.nhtsa.gov/fuel - economy



# • Publication expected Monday , July 13

• Docket will be available on www.regulations.gov 

# on the day of publication

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# Providing Feedback

• All meetings and material shared following the NPRM will be documented and made public with the FRM

• Expect a 60 - day comment period beginning on date of publication

– Written comments are accepted through our dockets, email, or mail



# – We will to respond to written comments made in this comment period



# • Two public hearings expected in August

– Comment period will close no less than 30 days after last hearing



# – Hearings will be in Chicago, IL and Los Angeles, CA

– Individuals and organizations can provide comments at this time

– We will respond to oral comments made during these hearings



# • We will continue to have meetings and accept feedback until the final rule

– We are not required to consider or respond to comments made outside of the comment period For 7/9/2015 Post - NPRM Signature - Will Docket for FRM 3

# Where can I get more information?

• EPA’s Heavy - Duty Vehicles Webpage

– http://www.epa.gov/otaq/climate/regs - heavy - duty.htm



### – Phase 1 and Phase 2 updates



### • EPA’s OTAQ Webpage

– http://www.epa.gov/otaq/index.htm

– Sign up for RSS feeds of press releases!



## • NHSTA’s Fuel Economy Webpage

– http://www.nhtsa.gov/fuel - economy

– Light - duty and heavy - duty vehicles updates



### • Federal Register

– https://www.federalregister.gov/



### – Updated daily



### • Electronic Code of Federal Regulations ( eCFR )

– http://www.ecfr.gov/

– Title 40 for EPA regulations

– Title 49 for NHTSA regulations



### • Docket

– http://www.regulations.gov

– EPA Docket: EPA – HQ – OAR – 2014 - 0827

– NHTSA Docket: NHTSA - 2014 - 0132 For 7/9/2015 Post - NPRM Signature - Will Docket for FRM 4

# IF NEEDED

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# Four Trailer Inputs for Equation

• Drag Area, Delta C D 

# A

– Result of aerodynamic testing • Performed by the manufacturer or a contractor • Performed by aero device manufacturer and results pre - approved by EPA/NHTSA


# • Tire Rolling Resistance Level, TRRL

– Result of rolling resistance testing

– Generally obtained from tire manufacturer



# • ATI

– If you have a qualified system, GEM provides a 1.5% reduction



# • Weight Reduction

– List of components that have light - weight options • Components must be applicable to all box trailers • Components must not be commonly adopted already

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# Performance Measures

For 7/9/2015 Post - NPRM Signature - Will Docket for FRM 7 Aerodynamics (Delta C D A, m 2 ) Bin I 0.0
Manufacturers use bin values for compliance Bin II 0.1 Bin III 0.3 Bin IV 0.5 Bin V 0.7 Bin VI 1.0 Bin VII 1.4 Bin VIII 1.8 Tire Rolling Resistance (C RR , kg/ton) Tire Baseline 6.0 Manufacturers use exact C

RR value from tire manufacturer Tire Level 1 5.1 Tire Level 2 4.7 Tire Inflation System (% reduction) ATI System 1.5 Qualifying systems Weight Reduction (lbs) Weight 1 Weight assigned to

specific components Manufacturers use weight from table Tire Type Material Weight Reduction (lb) Wide - Based Single Steel Wheel 84 Aluminum Wheel 139 Light - Weight Aluminum Alloy Wheel 147 Dual - Wide High - Strength Steel Wheel 8 Aluminum Wheel 21 Light - Weight Aluminum Alloy Wheel 30 Component Material Weight Reduction (lb) Suspension Assembly 1 Aluminum 280 Hub and Drum (per axle) Aluminum 80 Floor Aluminum 375 Floor Composite 245 Floor Crossmembers Aluminum 203 Landing Gear Aluminum 50 Rear Door Aluminum 187 Rear Door Surround Aluminum 150 Roof Bows Aluminum 100 Side Posts Aluminum 300 Slider Box Aluminum 150 Upper Coupler Assembly Aluminum 430 1 For tandem - axle suspension sub - frames made of aluminum, apply a weight reduction of 280 pounds. Use good engineering judgment to estimate a weight reduction for using aluminum sub - frames with other axle configurations. 1 1/3 added to payload, 2/3 reduces overall vehicle weight

# Equation for Trailer Compliance

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# CO 2

1. Calculate fuel consumption; 

# 2. Submit results to Agencies for each trailer family 3. Obtain certificate of conformity prior to production From Tire

Manufacturer’s C RR 

## Testing

From Aerodynamic Testing or Pre - Approved Devices Reduction Applied if ATI Installed From List of Light - Weight Components

# Illustration of Potential Compliance Steps for Trailers

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# Summary of Potential Box Van Compliance Options

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# EPA’s Handling of Confidential Business Information (CBI) Any sensitive information sent to our office would be protected under the federal requirements of the confidential business information (CBI) provisions, if it is marked as such. We have controls in place to properly handle any CBI shared by companies. In some cases, release of some information may be justified or required, but only pursuant to the regulations at 40 CFR part 2. The link below is for the electronic Code of Federal Regulations with all the details on how we handle CBI. http://www.ecfr.gov/cgi - bin/text - idx?SID=7199a8eb4e6113ccc8ffaf81560e66ca&tpl=/ecfrbrowse/Title40/40cfr2_main_02.tpl When we publish proposed rules, we always include clear guidelines on how to submit CBI to EPA. Below is an excerpt of the guidelines that were included when we proposed the HD GHG Phase 1 rule in 2011: All comments received will be included in the public docket without change and may be made available online at www.regulations.gov

, including any personal information provided, unless the comment includes information claimed to be Confidential Business Information (CBI) or other information whose disclosure is restricted by statute. Any CBI submitted to one of the agencies will also be available to the other agency. This statement constitutes notice to commenters pursuant to 40 CFR 2.209(c) that EPA will share confidential business information received with NHTSA unless commenters expressly specify that they wish to submit their CBI only to EPA and not to both agencies. However, as with all public comments, any CBI information only needs to be submitted to either one of the agencies’ dockets and it will be available to the other. Following are specific instructions for submitting CBI to either agenc y. Clearly mark the part or all of the information that you claim to be CBI. For CBI in a disk or CD - ROM that you mail to EPA, mark the outside of the disk or CD - ROM as CBI and then identify electronically within the disk or CD - ROM the specific information that is claimed as CBI. In addition to one complete version of the comment that includes information claimed as CBI, a copy of the comment that does not contain the information claimed as CBI must be submitted for inclusion in the public docket. Information so marked will not be disclosed except in accordance with procedures set forth in 40 CFR part 2. For 7/9/2015 Post - NPRM Signature - Will Docket for FRM 11

# EPA’s Regulatory Definition of Good Engineering Judgment § 1068.30 What definitions apply to this part? 

### Good engineering judgment means judgments made consistent with generally accepted scientific and engineering principles and all available relevant information. § 1068.5 How must manufacturers apply good engineering judgment? (a) You must use good engineering judgment for decisions related to any requirements under this chapter. This includes your applications for certification, any testing you do to show that your certification, production line, and in - use engines/equipment comply with requirements that apply to them, and how you select, 

### categorize, determine, and apply these requirements. (b) If we send you a written request, you must give us a written description of the engineering judgment in question. Respond within 15 working days of receiving our request unless we allow more time. (c) We may reject your decision if it is not based on good engineering judgment or is otherwise inconsistent with the requirements that apply, based on the following provisions: (1) We may suspend, revoke, or void a certificate of conformity if we determine you deliberately used incorrect information or overlooked important information, that you did not decide in good faith, or that your 

### decision was not rational. (2) If we believe a different decision would better reflect good engineering judgment, but none of the provisions of paragraph (c)(1) of this section apply, we will tell you of our concern (and its basis). You will have 30 days to respond to our concerns, or more time if we agree that you need it to generate more information. After considering your information, we will give you a final ruling. If we conclude that you did not use good engineering judgment, we may reject your decision and apply the new ruling to similar situations as soon as possible. 

### (d) We will tell you in writing of the conclusions we reach under paragraph (c) of this section and explain our reasons for them. (e) If you disagree with our conclusions, you may file a request for a hearing with the Designated Compliance Officer as described in subpart G of this part. In your request, specify your objections, include data or supporting analysis, and get your authorized representative's signature. If we agree that your request raises a substantial factual issue, we will hold the hearing according to subpart F of this part. For 7/9/2015 Post - NPRM Signature - Will Docket for FRM 12

# Definition of model year

• 40 CFR 1037.801

– “ Model year means the manufacturer’s annual new model production period, except as restricted under this definition and 40 CFR part 85, subpart X. It must include January 1 of the calendar year for which the model year is named, may not begin 

# before January 2 of the previous calendar year, and it must end by December 31 of the named calendar year.” 

# • 40 CFR 85 subpart X:

– Definition of model year. Model year means the manufacturer's annual production period (as determined under 

# § 85.2304) which includes January 1 of such calendar year, provided, that if the manufacturer has no annual production period, the term “model year” shall mean the calendar year.

– Duration of model year. A specific model year must always 

# include January 1 of the calendar year for which it is designated and may not include a January 1 of any other calendar year. Thus, the maximum duration of a model year is one calendar year plus 364 days.
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