Comments (in red) following the Working Meeting hosted by EPA on December 2, 2014

Received from Jan Hoover of Diamatrix, representing the Strick Group, on December 11, 2014

DRAFT Questions for Possible TTMA/EPA/NHTSA Working Meeting

NOTE: EPA and NHTSA expect that discussion with representatives of the trailer manufacturing industry 

will be very helpful in increasing our understanding of the industry and individual companies, including 

perspectives on potential compliance approaches and how we might be able to make specific unique 

exceptions for certain trailers and designs. 

Feel free to provide information about your company, but also on your understanding of the larger 

industry. Hard numbers are best, but if all you have is educated guesses, please provide them also, 

indicating what the uncertainties are. If TTMA members have information that they think would be 

helpful but that needs to be kept confidential, just indicate that it is CBI and we will use our wellestablished protocols for maintaining confidential information. 

Relevant Physical and Operational Characteristics of Box Trailers

o If EPA and NHTSA were to decide to exclude certain box trailers (dry vans or refrigerated 

trailers) from the program, we would need to provide clear regulatory descriptions of 

the unique trailer equipment or designs -- current and to the extent possible, 

anticipated future designs – and why application of CO2- and fuel consumption-reducing 

technologies would not be feasible or would interfere with the intended function of the

equipment. 

Drop frame vans

Exterior post vans

Exterior roof bow trailers

AAR vans

Vans with three or more axles or with spread fixed axles

Van shells that our customers modify for mobile office space, etc.

o Please describe physical or operational characteristics of non-standard equipment that 

customers request to be installed on box trailers that would tend to make aerodynamic 

devices, LRR tires, or tire inflation technologies incompatible or difficult/costly to install. 

Possible examples that we would need to be able to describe clearly are lift 

gates, ladders/steps for access to trailer side doors, and under-body equipment 

boxes.

Side and rear liftgates

Side doors requiring underbelly mounted steps

Vans with heating or cooling units on the nose

Vents on the nose or rear

Ladders on the front wall to access vents or other devices

Belly boxes or tool boxes
Relevant Physical and Operational Characteristics of Non-Box Trailers

o Similarly, if the agencies were to decide to exclude certain non-box trailers, or 

conceivably entire categories of non-box trailers, we would again need clear regulatory 

descriptions, tied as appropriate to why application of would not be feasible or would 

interfere with trailer function. 

Extendible and specialty container chassis

Drop frame chassis

Drop frame flatbeds

Container chassis in general

Extendable flatbed trailers

Flatbed trailers with winches

Approximate percentages of Van trailers we build per year based on the last two years.

o 50% - 53’ and longer vans.

o 25% - 28’ vans.

o 15% - Other length vans.

o 10% - Drop frame and special vans. Could include belly boxes, etc.

Compliance Issues: Defining Trailer “Families” for Compliance

o Similar to the Phase 1 tractor program and other past regulatory programs, the agencies 

would expect that any proposed trailer program would include provisions for 

manufacturers to identify subsets of their trailer offerings with similar characteristics for 

purposes of the rule, or trailer “families.” 

o The intent of identifying families would be to minimize compliance burdens for trailer 

manufacturers by limiting the number of certificates of compliance that would be 

needed to cover the company’s production, while ensuring that the environmental and 

fuel consumption benefits of the program were achieved.

We would anticipate that families could be grouped so all of a manufacturer’s 

new trailers that would use similar CO2- and fuel consumption-reducing 

technologies might be covered under a single certificate

o The agencies request any early suggestions from the industry about how families might 

be appropriately identified.

Compliance Issues: Averaging Provisions

o Historically, EPA has included averaging provisions as an option for manufacturers to 

use to comply with the standards in most of its motor vehicle emissions-reduction 

programs. NHTSA fuel efficiency programs also include averaging. 

Averaging provisions, are intended to provide manufacturers with flexibility in 

how they choose to comply and smoothing transitions to new standards. We 
have usually implemented averaging programs in conjunction with provisions 

allowing credit banking (credit generation and/or use within a company over 

time) and trading (transferring of credits among companies). 

Manufacturers have generally considered these programs valuable, 

especially as a part of programs that are expected to result in the 

development of fundamentally new technologies. 

Averaging programs can also be an incentive for early compliance and 

associated environmental benefits.

o In the case of the trailer program under consideration, the value of some or any 

averaging provisions to some manufacturers is not as clear. Some reasons that this may 

be the case, as we currently understand them, are:

The expected compliant technologies exist today, so flexibility in compliance is 

arguably less important than in other programs that require fundamentally new 

R&D, development testing, and market launches. 

And the competitive, highly customer-driven market may mean that flexibilities 

for compliance could also change customer demand patterns and create 

complications for manufacturers in simultaneously meeting customer demand 

and new regulatory standards. 

Also, competitive factors, particularly among companies of different sizes and 

with different numbers of distinct models, could also create negative 

consequences for some smaller companies.

o At the same time, a program without any form of averaging would require a 

manufacturer to achieve the standard with 100 percent of its trailers, regardless of 

whether a manufacturer found some applications of aerodynamic or tire technology to 

be less effective or more expensive or could benefit from more time than other 

applications.

o The agencies are interested in continuing to learn how averaging provisions might be 

developed that could provide valuable flexibility to manufacturers without creating 

significant negative consequences. We welcome any early comments on the following 

or other potential approaches to averaging: 

No averaging. Each trailer family would meet the standard each year.

Any family that did not meet the standard would require the agencies to 

consider enforcement action.

OEM Impact: 

o Clear message to customers that all families must meet the 

standard, and that the OEM is not able to “deal” on whether to 

install CO2/fuel consumption technologies.

o No additional internal data tracking beyond basic compliance 

reporting 

o No flexibility for problematic families
“Fleet averaging” only, but no credit banking or trading. 

Manufacturers would certify each trailer family to a self-selected “family 

emission limit” (FEL) 

In its annual certification application, the manufacturer would compare 

its projected sales-weighted average CO2 and fuel consumption for all of

its FELs to the applicable standard to receive its certificate.

Then, at the end of each year, the manufacturer would again calculate 

its sales-weighted average using actual sales numbers to confirm 

compliance.

In this approach, if for whatever reason the average performance did 

not meet the standard, there would be no mechanism for carrying the 

deficit forward to be resolved in future years, and the agencies would 

need to consider enforcement action.

Similarly, if the manufacturer’s average performance was better than 

the standard, there would be no mechanism for “giving credit” for the 

better-than-needed performance. 

OEM Impact: 

o Some flexibility for problematic families so long as make up 

elsewhere in that year’s production. 

o Modest degree of recordkeeping and data management. 

o Potential changes in relationship with customers, with possible 

pressure to supply limited number of lower-performing models. 

o Possible changed competitive relationships, depending on 

differing numbers and capabilities of models and thus internal 

averaging capacity.

Averaging, with Banking and Trading

Full credit program, including ability to generate credits for later use or 

deficits to be made-up later

OEM Impact:

o Greater degree of flexibility in choosing how to comply.

o Higher level of recordkeeping and data management.

o I don’t see how ABT will benefit us as a small entity. We build approximately 2500 vans 

per year with approximately 50% of those being 53’ vans. If some percentage can be 

non-compliant through ABT, I can see the larger manufacturers would have a big and 

almost unfair advantage over us. We could lose business because of it.

Compliance Issues: Pre-Approval of Technologies

o Aerodynamic testing helps ensure that in-use trailers achieve the expected aerodynamic 

performance. However, we also recognize that aerodynamic testing has the potential to 

be a significant burden on trailer manufacturers.
o The agencies are considering two options for trailer manufacturers to evaluate the 

aerodynamic performance of their trailers. In each option, we are considering 

coastdown, constant speed, wind tunnel, and CFD as approved test methods to evaluate 

performance. We expect that test procedures for these methods would be similar to 

SmartWay’s 2014 test protocols.

In the first option, manufacturers could perform the tests themselves or hire a 

contractor to perform the tests.

Test data from a single representative trailer could be applied to all 

trailers within a family and potentially a manufacturer’s entire 

production line

We are also considering an alternative testing option that would allow aero 

device manufacturers (or others) to test aero devices on a representative trailer 

and provide results to EPA for pre-approval.

Trailer manufacturers could then choose from among the appropriate 

pre-approved technologies in order to meet the standard.

With this approach, trailer manufacturers could choose to avoid some 

or all testing. 

In both of these testing options, trailer manufacturers would be allowed to carry 

over certification test data if the trailer design did not change year-to-year.

o The agencies encourage any questions, comments, or other input about how this “preapproval” approach might work for trailer manufacturers, or how it might be 

problematic to implement.

The agencies expect that members of the trailer manufacturing industry, as well as our two 

agencies, will add to this initial list of questions and issues that warrant a detailed discussion 

throughout the process of developing a proposed trailer program. 

You asked about training, tracking and recording with regards to the burden on trailer manufacturers. I 

still do not have a very good feel of what will be required and, in turn, do not have any good ideas of 

what he burden will be. Off the top, I could see the need to add at least one person to do tracking and 

recording along with reporting for our company. There would also be training and tracking requirements 

at the plant level to ensure we are all on the same page. Again, as to specifics, I cannot comment.