Commen ts (in red ) following the Working Meeting hosted by EPA on December 2, 2014
R eceived 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 well

established 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 CO 2 - and fuel consumption

- reducing technologies would not be feasible or would interfere with the intended function of the equipment. Drop f rame 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 charac teristics 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 boxesRelevant Physical and Operational Characteristics of Non

- Box Trailers

o Similarly, if the agencies were to decide to exclude certain non

- box trailers, o r 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 f amilies 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 th e program were achieved. We would anticipate that families could be grouped so all of a manufacturer’s
new trailers that would use similar CO 2 - 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 mo st 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 stand ards. Wehave 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

asso ciated 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 e xpected 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 compan ies 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 10 0 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 continu ing 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 CO 2 /fuel consumption technologies.

o No additional internal data tracking beyond basic compliance reporting

o No flexibility for problematic families“Fleet a veraging ” o nly, but no credit banking or t rading

. 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 CO 2 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 wa s 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 recordkee ping 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 perfor mance . 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 t est procedures for these methods would be similar to SmartWay’s 2014 test protocols

. In the first optio n, 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 al so 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 appropr iate

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 “pre

approval” approach might work for trailer manufacturers, or how it might be problematic to implement.

The agencies e

xpect 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.