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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 ofglider 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 ifthe 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 ofon-highway vehicles it produces (simi lar 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 ofsome 70 team members at the Fort Wayne facility. Therefore, Terex proposes ifa company manufactured fewer than 1,000 onhighway veh icles 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 motorvehicle with a previously used engine (including a rebuilt or remanufactured engine). • Terex requests further clarification and/or a defi nition of "other new equipment"

. The i ntention ofthis 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 ofsalvaged 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 ofthe damaged vehicle. 4

. Page 40186 says that 6x6 and 8x8 veh icle configu rations "are on ly 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 ofthe 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 ofaftertreatment systems on diesel engines.