/3CJ6 

Comments regarding GHG Phase 2 Proposal from Terex Corporation 

(Docket 10 Number: EPA-HQ-OAR-2014-{)827) 

1. Page 40529 says: "EPA also requests comment on whether we should allow larger manufacturers to 

produce some limited number of glider kits." Similarly, page 40295 says: The Small Business 

Advocacy Review Panel recommended that EPA seek comment on how to design a small business 

vocational vehicle exemption by means of a custom chassis volume exemption and what sales 

volume would be an appropriate threshold. 

• Terex proposes that if the EPA sets limits to the quantity of gliders produced, it should not be 

based solely on the number of employees the glider manufacturer has, but also should be based 

on the number of on-highway vehicles it produces (similar to the off-highway Transition 

Program for Equipment Manufacturers). For example, Terex Corporation has approximately 

20,000 employees globally, but only approximately 220 are involved in the manufacture of 

gliders at one small facility located in Fort Wayne, Indiana. Should the proposed regulations 

continue unchanged, it would result in the redundancy of some 70 team members at the Fort 

Wayne facility. Therefore, Terex proposes if a company manufactured fewer than 1,000 onhighway vehicles between ca lendar years 2010 and 2014, then it should be eligible for the same 

exemptions as a small manufacturer under the proposed 1037.635{b). 

2. The proposed definition 1#3 of Glider Kit on Page 40662 says that a glider kit means: "Any other new 

equipment that is intended to become a motor vehicle with a previously used engine (including a 

rebuilt or remanufactured engine). 

• Terex requests further clarification and/or a definition of "other new equipment". The intention 

of this request is to eliminate confusion over whether certain new parts or assemblies, that 

would be used to repair an existing vehicle, would be considered as "new equipment" by the 

EPA. 

3. Page 40229 says that building a "glider" out of salvaged powertrain from vehicles destroyed in 

accidents is an "arguably legitimate purpose". 

• The proposed limitation on gliders doesn't distinguish between repaired vehicles and glider kits. 

Terex suggests that language be added that allows for used powertrain to be installed onto a 

new chassis for the case of repairing a damaged vehicle, and not be subject to regulations that 

are newer than the original build date of the damaged vehicle. 

4. Page 40186 says that 6x6 and 8x8 vehicle configurations "are only manufactured for specialized 

vehicles that require extra traction for off-road applications, they are very low volume sales and 

their increased fuel consumption and C02 emissions are not significant in comparison to the overall 

reductions of the proposed Phase 2 program." 

• Terex suggests that vehicles with 6x6 and 8x8 configurations must be added to the list of 

exemptions under the proposed 1037.635(b) concerning glider kits. Because these vehicles 

operate off-road, they are far more susceptible to "wear and tear" frame damage that is 

premature compared to the engines that were designed to operate for a million miles. For this 

reason, "glidering" 6x6 and 8x8 vehicles is and has always Ra;. been common industry practice 

even before the arrival of aftertreatment systems on diesel engines.