The Honorable Gina McCarthy
Administrator U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, NW Washington, DC 20460

Dear Administrator McCarthy:

Enclosed for your consideration is the report of the Small Business Advocacy Review Panel (SBAR Panel or Panel) convened for EPA’s planned proposed rulemaking entitled “Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium

- and Heavy

- Duty Engines and Vehicles

- Phase 2” (or “Phase 2”). This notice of proposed rulemaking is being developed by the U.S. Environmental Protection Agency (EPA) under the Clean Air Act (CAA).

EPA’s Phase 1 Heavy

- Duty Engines and Vehicles Program, which was finalized in September 2011, ma rked the first greenhouse gas emissions standards for heavy

- duty vehicles and engines. The program addressed heavy

- duty’s GHG emissions through the adoption of performance

based standards that allow manufacturers to determine the optimal mix of technologie s to achieve the necessary reductions for their vehicle fleets and engines.

Building on the Phase 1 rule, this proposed Phase 2 rule would be designed to reduce GHG emissions associated with the transportation of goods across the United States post

- 2017

. The proposed Phase 2 rulemaking considers changes to existing engine and vehicle GHG standards, as well as regulatory standards and certification requirements for previously

- unregulated new trailers pulled by semi

- tractors. If such a rule is adopted, manuf acturers of heavy

- duty engines, chassis, vehicles and trailers could be required to incorporate GHG

- reducing and fuel

- saving technologies in order to comply with EPA’s performance

- based standards.

On October 22, 2014, EPA’s Small Business Advocacy Chairper son convened this Small Business Advocacy Review (SBAR) Panel under section 609(b) of the Regulatory Flexibility Act (RFA), as amended by the Small Business Regulatory Enforcement Fairness Act (SBREFA). In addition to its chairperson, the Panel consists of the Director of the Assessment and Standards Division within EPA’s Office of Transportation and Air Quality, the Administrator of the Office of Information and Regulatory Affairs within the Office of Management and Budget (OMB), and the
Chief Counsel for Advocacy of the Small Business Administration (SBA). It is important to note that the Panel’s findings and discussion are based on the information available at the time this report was written. EPA is continuing to conduct analyses relevant to the proposed rule, and additional information may be developed or obtained during this process as well as from public comment on the proposed rule. The options the Panel identified for reducing the rule’s economic impact on small entities may require further analysis and/or data collection to ensure that the options are cost effective, practicable, enforceable, protective of public health, environmentally sound and consistent
with the CAA.

### Summary of Small Entity Outreach

Before beginning the formal SBREFA process, EPA actively engaged in outreach with entities that would potentially be affected by the upcoming rulemaking. EPA held phone conferences
and face

- to

- face meetings with many of these companies to discuss the upcoming proposed rulemaking and to provide these co ntacts with an early opportunity to ask questions and discuss their concerns with the upcoming rulemaking.

Prior to convening the Panel, EPA conducted outreach with small entities that will potentially be affected by these regulations. On April 2, 2014, EP A issued a press release to solicit potential small entity representatives (SERs) to participate. In June 2014, EPA invited SBA, OMB, and ten potentially affected SERs to a conference call and meeting, and solicited comments from them on preliminary infor mation sent to them. EPA shared the small entities’ written comments with the Panel as part of the Panel convening document.

After the SBAR Panel was convened, the Panel distributed additional information to the SERs on October 22, 2014, for their review a nd comment in preparation for another outreach meeting. On November 5

- 6, 2014, the Panel met with SERs representing 13 small businesses (in three separate meetings by industry) to hear their comments on the information distributed in these mailings. The SE Rs were asked to provide written feedback on ideas under consideration for the proposed rulemaking and responses to questions regarding their experience with existing CO2

- reducing technologies. The Panel received written comments from the SERs in response to the discussions at these meetings and we have summarized them in the Panel Report that is attached. Their full written comments are also attached (see Appendix B of the Panel Report). In light of these discussions and comments, the Panel considered the regulatory flexibility issues specified by RFA/SBREFA and developed the findings and discussion summarized below.



### Panel Findings and Discussion

Under section 609(b) of the RFA, the Panel is to report its findings related to these four
items:

• A description of an estimate of the number of small entities to which the proposed rule will apply.

• A description of the projected reporting, recordkeeping and other compliance requirements of the proposed rule, including an estimate of the classes of small entities
wh ich will be subject to the requirement and the type of professional skills necessary for preparation of the report or record.

• Identification, to the extent practicable, of all relevant federal rules which may duplicate, overlap or conflict with the propose d rule.

• A description of any significant alternatives to the planned proposed rule which would minimize any significant economic impact of the proposed rule on small entities consistent with the stated objectives of the authorizing statute.

2The Panel’s m ost significant findings and discussion with respect to each of these items are summarized below. To read the full discussion of the Panel findings and recommendations, see Section 9 of the Panel Report.



### Number and Types of Entities Affected

EPA identified 115 trailer manufacturers and 100 of them are small. Currently 24 vocational chassis manufacturers have registered with EPA under the Phase 1 rulemaking and three have confirmed small entity status to obtain an exemption for MY 2014. Twenty alternative fuel engine converters are currently registered with EPA to certify their converted HD engines for criteria pollutants. Eighteen of those engine converters are small. EPA is aware of four glider manufacturers and three of these companies are small busine sses.



### General Potential Reporting, Recordkeeping and Compliance Burdens

For any emission control program, EPA must have assurances that the regulated products will meet the standards. The program that EPA is considering for manufacturers subject to this proposal will include testing, reporting, and recordkeeping requirements. Testing requirements for these manufacturers could include use of EPA’s Greenhouse gas Emissions Model (GEM) vehicle
simulation tool to obtain the overall CO 2 emissions rate for cert ification of vocational chassis and trailers, aerodynamic testing to obtain aerodynamic inputs to GEM for some trailer manufacturers and engine dynamometer testing for alternative fuel engine converters to ensure their conversions meet the proposed CO 2 , CH 4 and N 2 O engine standards. Reporting requirements would likely include emissions test data or model inputs and results, technical data related to the vehicles, and
end

- of

- year sales information. Manufacturers would have to k eep records of this informati on.



### Related Federal Rules

The Phase 1 rulemaking would continue to be in effect in the absence of this proposed rule.
The Panel is also aware of several other state and Federal rules related to heavy

- duty vehicles and to the proposed Phase 2 rule under co nsideration. DOT/NHTSA has several safety requirements for these vehicles. California adopted its own greenhouse gas initiative, which places aerodynamic requirements on trailers used in long

- haul applications. None of these existing regulations were
fo und to conflict with the proposed rulemaking.

The Panel recognizes that there is the potential for a tension between technologies to improve fuel efficiency and some other Federal mandates, such as NHTSA safety regulations

, EPA emissions
standards for crit eria pollutants, and EPA transportation fuel blending requirements for biofuels

. EPA sought information from SERs on many of these tensions and flexibilities that could aid small businesses in complying with these multiple mandates and will continue to seek comment on them in the rulemaking development process

.

3

### Regulatory Flexibility Alternatives

As described above, EPA is developing standards for medium

- and heavy

- duty engines and vehicles to be addressed in this rulemaking. Becaus e of the potential costs and technology challenges involved in meeting these standards, the Panel recommends that EPA consider and seek comments on the flexibility options described below. We believe that the following set of flexibility options, taken tog ether, have the potential to significantly reduce compliance burden for small manufacturers without significantly compromising the environmental benefits of the program.



### Trailers

Comments from trailer manufacturer SERs indicate that these companies are fam iliar w i th most of the technologies described in the materials, but have no experience with EPA certification and do not anticipate they could manage the accounting and reporting requirements without additional staff and extensive training. Performance te sting, which is a common requirement for many of EPA’s regulatory programs, is largely unfamiliar to these small business manufacturers and the SERs believe the cost of testing would be a significant burden on their companies

. In light of this feedback, t he Panel recommends a combination of streamlined compliance , which minimizes tracking and testing requirements, and targeted exemptions for these small businesses. The Panel believes these strategies will achieve many of the benefits for the environment b y driving adoption
of CO 2

- reducing technologies, while significantly reducing the burden that these new regulations
would introduce on small businesses.

Box Trailers

Box trailer manufacturers have the benefit of relying on the aerodynamic technology
develo pment initiated through EPA’s voluntary SmartWay program. The Panel is aware that EPA is planning to propose a simplified compliance program for all manufacturers, in which aerodynamic device manufacturers have the opportunity to test and register their d evices with EPA as technologies that can be used by trailer manufacturers in their trailer certification. This pre

approved technology strategy is intended to provide all trailer manufactures a means of complying
with the standards without the burden of t esting. At the time of this report, it is unclear if this strategy will be available indefinitely, or if it will be an interim flexibility to allow manufacturers to ease into a testing

- only compliance program. In the event that this strategy is limited t o the early years of the trailer program for all manufactures, the Panel recommends that small manufacturers continue to be given the option to use pre

- approved devices in lieu of testing.

In the event that small trailer manufacturers adopt pre

- approved aerodynamic technologies and the appropriate tire technologies for compliance, the Panel does not believe it is necessary to require the use of a vehicle emissions model, such as GEM, for certification. Instead, the Panel believes it could be possible for manufacturers to simply report to EPA that all of their trailers include approved technologies.

4Non

- Box Trailers

The Panel recommends that EPA not require the installation of aerodynamic devices for non

box trailers. Some of the non

- box trailer manufac turers SER have seen prototype

- level demonstrations of aerodynamic devices on non

- box trailers. However, most non

- box trailer SERs identified unique operations in which their trailers are used that preclude the use of those technologies and many that they have seen used on box trailers today.

Some non

- box trailer manufacturers have experience with lower rolling resistance ( LRR )
tires and automatic tire inflation ( ATI ) systems. However, the non

- box trailer manufacturer SERs indicated that LRR tires are not currently available for some of their trailer types. The SERs noted that tire manufacturers are currently focused on box trailer applications and there are only a f ew LRR tire models that meet the needs of their customers. The Panel believes EPA should ensure appropriate availability of these tires in order for it to be deemed a feasible means of achieving these standards and recommends a streamlined compliance proc ess based on the availability of technologies. The Panel suggests that the best compliance option from a small business perspective would be for EPA to pre

- approve tires once they are available in sufficient quantities on the market, similar to the approa ch being proposed for aerodynamic technologies, and to maintain a list that could be used to exempt small businesses when no suitable tires are available. However, the Panel recognizes the difficulties of maintaining an up

- to

- date list of certified techno logies. The Panel recommends that, if EPA does not adopt the list

- based approach, the agency consider a simplified
letter

- based compliance option that allows manufacturers to petition EPA for an exemption if they are unable to identify tires that meet the LRR performance requirements on a trailer family basis.

Trailers with Unique Use Patterns

The Panel recommends excluding all trailers that spend a significant amount of time in off

road applications. These trailers may not spend much time at highway s peeds and aerodynamic
device s may interfere with the vehicle’s intended purpose . Additionally, tires with lower rolling resistance may not provide the type of traction needed in off

- road applications

.

General Flexibilities for All Small Trailer Manufactur ers

The Panel recognizes that some manufacturers, who have diverse product lines and high sales volumes, may benefit from an emissions averaging, banking and trading (ABT) strategy. However,
due to the custom

- order nature of the trailer industry, SERs hav e expressed their concern that ABT may provide an opportunity for historically loyal customers or customers with large fractions of a manufacturer’s business to bargain for the portion of a manufacturer’s sales that have minimal requirements. Based on the low volume of sales and niche market of many small business trailer manufacturers, small businesses in particular may have little leverage in this situation and risk losing their customers to larger manufacturers who have credits to spare. In addition, t he accounting and reporting burdens of ABT may preclude small businesses from participating in the flexibility.

Due to the potential for reducing a small business’s competitiveness compared to the larger manufacturers, as well as the ABT record

- keeping b urden, the Panel recommends EPA consider

5small business flexibilities to allow small entities to opt out of ABT without placing themselves at a competitive disadvantage to larger firms that adopt ABT, such as a low volume exemption or requiring only LRR wh ere appropriate. EPA should also consider flexibilities for small businesses that would ease and incentivize their participation in ABT, such as streamlining the tracking requirements for small businesses. In addition, the Panel recommends that EPA request comment on the feasibility and consequences of ABT for the trailer program and additional flexibilities that will promote small business participation.

In addition, for all trailer types that will be included in the proposal, the Panel recommends a 1

- year delay in implementation for small trailer manufacturers at the start of the proposed rulemaking to allow them additional lead time to make the proper staffing adjustments and process changes and possibly add new infrastructure to meet these requi rements. In the event that EPA is unable to provide pre

- approved technologies for manufacturers to choose for compliance, the Panel recommends that EPA provide small business trailer manufacturers an additional 1

- year delay for each subsequent increase in stringency. This additional lead time will allow these small businesses to research and market the technologies required by the new standards.



### Alternative Fuel Engine Converters

To reduce the compliance burden of small business engine converters who conv ert engines in previously

- certified complete vehicles, the Panel recommends allowing engine compliance to be
sufficient for certification. This would mean the converted vehicle would not need to be recertified
as a vehicle. This flexibility would elimina te the need for these small manufacturers to gather all of the additional component

- level information in addition to the engine CO 2 performance necessary to properly certify a vehicle with GEM (e.g., transmission data, aerodynamic performanc e, tire rolling
resistance ). In addition, the Panel recommends that small engine converters be able to submit an engineering analysis, in lieu of measurement, to show that their converted engines do not increase
N 2 O emissions. Many of the small engine converters are conv erting SI

- engines, and the catalysts in these engines are not expected to substantially impact N 2 O production. Small engine converters that
convert CI

- engines could likely certify by ensuring that their controls require changes to the SCR dosing strategie s.

Based on the comments received from SERs, the Panel does not recommend separate standards for small business natural gas engine manufacturers. The Panel believes this would discourage entrance into this emerging market by adding unnecessary costs to a technology that has the potential to reduce CO 2 tailpipe emissions. In addition, the Panel believes additional leakage requirements beyond a sealed crankcase for small business natural gas

- fueled CI engines and requirements to follow industry standards fo r leakage could be waived for small businesses with minimal impact on overall GHG emissions.

Finally, the Panel recommends that small engine converters receive a one

- year delay in implementation for each increase in stringency throughout the proposed rul e. This flexibility will provide small converters additional lead time to obtain the necessary equipment and perform calibration testing if needed.

6

### Vocational Chassis Manufacturers

The Panel recommends interim reduced requirements for these small manufa cturers with stringencies that include technologies that fit the applications of these vehicles.

Emergency Vehicles

One of the vocational chassis SERs was a fire truck manufacturer. Fire trucks, and many other emergency vehicles, are built for high leve l of performance and reliability in severe

- duty applications. Some of the CO 2

- reducing technologies listed in the materials could compromise the fire truck’s ability to perform its duties and many of the other technologies simply provide no benefit
in rea l

- world emergency applications. The Panel recommends proposing less stringent standards for emergency vehicle chassis manufactured by small businesses. The Panel believes it is feasible for
small manufacturers to install a Phase 2

- compliant engine, but r ecommends EPA request comment on whether the use of LLR tires will provide enough CO 2 benefits to justify requiring small business emergency chassis manufacturers to adopt them. In addition, the Panel recommends a simplified certification approach for sm all manufacturers who make chassis for emergency vehicles that reduces the number of inputs these manufacturers must obtain for GEM. Emergency vehicles make up less than one percent of the annual vocational vehicles sold, and the Panel anticipates these

r educed requirements would have a minimal impact on the overall CO 2 reductions of the program.

Off

- Road Vocational Vehicles

EPA is planning to propose to continue the exemptions in Phase 1 for off

- road and low

- speed
vocational vehicles (s ee generally 76 FR 57175 ) . These provisions currently apply for vehicles that are defined as “motor vehicles” per 40 CFR 85.1703, but may conduct most of their operations off

road. Vehicles qualifying under these provisions must comply with the applicable engine standard,
b ut need not comply with a vehicle

- level GHG standard

. The Panel believes this exemption is sufficient to cover the small business chassis manufacturers who design chassis for off

- road
vocational vehicles.

Custom Chassis Manufacturers

The second vocational SER manufactures chassis for specialty operations and that SER has very small annual sales volumes. He provided a summary of his products that indicate his company has a limited ability to adopt many of the technologies described in the materials. The P anel recommends proposing a low volume exemption based on the volume of sales. Similar to the recommendation for emergency vehicle chassis manufacturers, the Panel believes it is feasible to require installation of a Phase 2

- compliant engine and recommend s that EPA request comment on the benefits of LRR tires in this market segment. At this time, the Panel doesn’t have enough information to recommend a sales volume, but recommends that EPA request comment on how to design a small business exemption by mea ns of a volume exemption and what sales volume would be an appropriate threshold.

7Glider Manufacturers

The Panel recognizes that EPA would like to reduce the use of glider kits, which have higher emissions of criteria pollutants like NOx than current en gines, and which could have higher GHG emissions than Phase 2 engines. However, the Panel believes that the number of vehicles produced by these small businesses is too small to have a substantial impact on the total heavy

- duty inventory.
The Panel also believes that there should be an allowance to produce some number of glider kits for legitimate purposes, such as for newer vehicles badly damaged in crashes. The Panel therefore recommends proposing an explicit allowance for existing small businesses to continue assembling glider vehicles without having to comply with the GHG requirements. The Panel recommends that any other limitations on glider production be flexible enough to allow sales levels as high as the peak
levels in the 2010

- 2012 timeframe.

8

# Final Report
of the Small Business Advocacy Review Panel on EPA’s Planned Proposed Rule

Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium

- and Heavy

- Duty Engines and Vehicles: Phase 2

January 1 5 , 201 5

### TABLE OF CONTENTS

1 Introduction

................................ ................................ ................................ ............................. 1

2 Background

................................ ................................ ................................ ............................. 2

2.1 Background and Regulatory History

................................ ................................ ..... 2

2.2 Description of the Rule and its Scope

................................ ................................ ... 3

2.3 Related Federal Rules

................................ ................................ ............................ 4

3 Overview of Proposal Under Consideration

................................ ................................ ........... 6

3.1 Potential Requirements and Guidelines of the Proposal

................................ ....... 6

3.1.1 Engines

................................ ................................ ................................ ............ 6

3.1.2 Tractors

................................ ................................ ................................ ............ 6

3.1.3 Vocation al Vehicle Chassis

................................ ................................ ............. 7

3.1.4 Complete Pickup Trucks and Vans

................................ ................................ . 7

3.1.5 Trailers

................................ ................................ ................................ ............ 7

4 Applicable Small Entity Definitions

................................ ................................ ....................... 8

5 Small Entities that May Be Subject to the Proposed Regulation

................................ ............ 8

6 Summary of Small entity Outreach

................................ ................................ ......................... 9

6.1 Pre

- Panel Outreach Meeting with Potential Small Entity Representatives

........ 10

6.1.1 Pre

- Panel Outreach Meeting Summary

................................ ......................... 11

6.2 SBAR P anel Outreach to Small Entity Representatives

................................ ..... 12

6.2.1 Trailer Manufacturers

................................ ................................ .................... 12

6.2.2 Alternative Fuel Engine Converters

................................ .............................. 15

6.2.3 Vocational Vehicle Chassis Manufacturers

................................ .................. 16

7 List of Small Entity Representatives

................................ ................................ ..................... 17

8 Summary of Comments from Small Entity Representatives

................................ ................ 18

8.1 Summary of Written Comments Following Pre

- Panel Outreach Meeting

......... 18

8.1.1 Trailer Manufacturers

................................ ................................ .................... 18

8.1.2 Vocational Vehicle Chassis Manufacturers

................................ .................. 20

8.1.3 Alternative Fuel Engine Manufacturers

................................ ........................ 20

8.2 Summary of Written Comments following Panel Outreach Meeting

................. 22

ii8.2.1 Trailer Manufacturers

................................ ................................ .................... 22

8.2.2 Alternative Fuel Engine Converters

................................ .............................. 28

8.2.3 Vocational Chassis Manufacturers

................................ ................................ 33

8.2.4 Potential Reporting, Recordkeeping and Compliance Burdens

.................... 34

8.2.5 Suggested Flexibilities

................................ ................................ .................. 34

9 Panel Findings and Discussion

................................ ................................ ............................. 35

9.1 Number and Types of Entities Affected

................................ .............................. 35

9.2 General Potential Reporting, Recordkeeping and Compliance Burdens

............ 35

9.3 Trailers

................................ ................................ ................................ ................ 35

9.3.1 Feasibility of Proposed Technologies

................................ ........................... 35

9.3.2 Potential Reporting, Recordkeeping and Compliance Burdens

.................... 36

9.3.3 Suggested Flexibilities

................................ ................................ .................. 37

9.4 Alternative Fuel Engine Converters

................................ ................................ .... 39

9.4.1 Feasibility of Proposed Technologies

................................ ........................... 39

9.4.2 Potential Reporting, Recordkeeping and Compliance Burdens

.................... 40

9.4.3 Suggested Flexibilities

................................ ................................ .................. 40

9.5 Vocational Chassis Manufacturers

................................ ................................ ...... 41

9.5.1 Feasibility of Proposed Technologies

................................ ........................... 41

9.5.2 Potential Reporting, Recordkeeping and Compliance Burdens

.................... 41

9.5.3 Suggested Flexibilities

................................ ................................ .................. 41

Appendix A

................................................... ............................................. . A1

Appendix B ................................................................................................. B1

iii

### 1 INTRODUCTION

This report is presented by the Small Business Advocacy Review Panel (SBAR Panel or Panel) convened for the proposed rulemaking “Greenhouse Gas Emissions and Fuel Efficiency Standards
for Medium

- and Heavy

- Duty Engines and Vehicles: Phase 2” (or “Phase 2” ) that is currently being developed by the U.S. Environmental Protection Agency (EPA). Under section 609(b) of the Regulatory Flexibility Act (RFA) as amended by the Small Business Regulatory Enforcement Fairness Act of 1996 (SBREFA), EPA must convene a Pa nel prior to publication of the initial regulatory flexibility analysis (IRFA) that the agency may be required to prepare under the RFA. In addition to EPA’s Small Business Advocacy Chairperson, this particular Panel consists of the
Director of the Assessm ent and Standards Division of the EPA Office of Transportation and Air Quality, the Administrator of the Office of Information and Regulatory Affairs within the Office of Management and Budget, and the Chief Counsel for Advocacy of the Small Business
Admin istration.

This report includes the following:

• Background information on the proposed rule being developed;

• Information on the types of small entities that would be subject to the proposed rule;

• A description of efforts made to obtain the advice and recomm endations of representatives of those small entities; and

• A summary of the comments that have been received to date from those representatives.

Section 609(b) of the RFA directs the Panel to report on the comments of small entity representatives and make f indings on issues related to elements of an IRFA under section 603 of the
RFA. Those elements of an IRFA are:

• A description of, and where feasible, an estimate of the number of small entities to which the proposed rule will apply;

• A description of projecte d reporting, record keeping, and other compliance requirements of the proposed rule, including an estimate of the classes of small entities which will be subject to the requirement and the type of professional skills necessary for preparation of the report or record;

• An identification, to the extent practicable, of all relevant Federal rules which may duplicate, overlap, or conflict with the proposed rule;

• A description of any significant alternatives to the proposed rule which accomplish the stated objecti ves of applicable statutes and which minimize any significant economic impact of the proposed rule on small entities. This analysis shall discuss any significant alternatives such

as:

o the establishment of differing compliance or reporting requirements or t imetables that take into account the resources available to small entities;

o the clarification, consolidation, or simplification of compliance and reporting requirements under the rule for such small entities;

o the use of performance rather than design standards; and

1o an exemption from coverage of the rule, or any part thereof, for such small entities.

Once completed, the Panel Report is submitted to the EPA Administrator and is included in the rulemaking record. EPA considers the Panel’s findings when co mpleting the draft of the proposed rule. In light of the Panel Report, and where appropriate, EPA also consider s whether changes are needed to the IRFA for the proposed rule or the decision on whether an IRFA is required.

The Panel’s findings and discussio n are based on the information available at the time the final Panel Report is drafted. EPA will continue to conduct analyses relevant to the proposed rule, and additional information may be developed or obtained during the remainder of the rule developmen t process.

Any options identified by the Panel for reducing the rule’s regulatory impact on small entities may require further analysis and/or data collection to ensure that the options are practicable, enforceable, environmentally sound, and consistent wi th the Clean Air Act (CAA) and its
amendments.



### 2 BACKGROUND

2.1 Background and Regulatory History

Heavy

- duty vehicles are classified as those with gross vehicle weight ratings (GVWR) of greater than 8,500 lb. Section 202(a) of the Clean Air Act (CAA) allows EPA to regulate new vehicles and new engines by prescribing emission standards for pollutants which the Administrator finds “may reasonably be anticipated to endanger public health or welfare.” In 2009, EPA found that six greenhouse gases (GHGs) were anticipa ted to endanger public health or welfare, and new motor vehicles and new motor vehicle engines contribute to that pollution.

Acting under the authority of the CAA, EPA , in a joint rulemaking with National Highway Traffic Safety Administration (NHTSA), set the first phase of heavy

- duty vehicle GHG standards (Phase 1) and specified certification requirements for emissions of four GHGs emitted by mobile sources: carbon dioxide (CO 2 ), nitrous oxide (N 2 O), methane (CH 4 ), and hydrofluorocarbons (HFC)
in a final rule

, “Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium

- and Heavy

Duty Engines and Vehicles

, ” issued in September 2011. These rules marked the first greenhouse gas emissions (GHGs) and fuel efficiency standards for medium

- and heavy

- duty vehicles and engines, and together comprise a national program for fuel efficiency and GHG reductions for these vehicles and engines. The program addressed heavy

- duty’s increasing GHG contribution and fuel consumption increases through the adoption of perf ormance

- based standards that allowed manufacturers to determine the optimal mix of technologies to achieve the necessary reductions for their vehicle fleets and engines. The standards phase in from model year (MY) 2014 through MY 2018 (NHTSA’s fuel efficie ncy standards being voluntary during the first two of the model years) and remain fixed beyond MY 2018 until the next phase of regulations adjust that standard. Manufacturers meeting the applicable small business criteria in 13 CFR 121.201 were not subjec t to the GHG emissions standards in Phase 1.

2Due to the diversity of products in the heavy

- duty vehicle/engines industries, the Phase 1 rule divided heavy

- duty vehicles into three regulatory categories: heavy

- duty pick

- up trucks and vans (Class 2b and 3) , vocational vehicle chassis (Class 2b

– Class 8), and combination tractors (Class 7 and 8). In addition, the engines of the vocational vehicle chassis and combination tractors were regulated separately. Vocational body manufacturers, trailer manufacturers, fleet owners, and truck owner/operators were not regulated in Phase 1.

Class 2b and 3 pick

- up trucks and vans weigh less than 14,000 lb GVWR and are sold by vehicle manufacturers as complete vehicles. Under Phase 1, these pick

- up trucks and vans are certified by their manufacturers as complete vehicles using amended vehicle test procedures from EPA’s existing program for emissions such as NOx and PM for these vehicles.

Vocational vehicles frequently begin as incomplete chassis that can be us ed for a number of vocational applications. Chassis manufacturers install engines and transmissions and sell the chassis to final stage body manufacturers who add appropriate features for the vehicles’ final end

- use (e.g., dump bed, delivery box, or utilit y bucket).

Combination tractor manufacturers build their own tractor chassis and bodies and install an engine and transmission. The engines are either the manufacturers’ own or purchased from a separate engine manufacturer. The rule also created a new veh icle certification and compliance program for tractor manufacturers and vocational chassis manufacturers, which relies on a computer
simulation of vehicle CO 2 emissions rather than emissions testing. EPA did not establish standards
for new trailers and tra iler manufacturers were not regulated in Phase 1.

The Phase 1 rule also required that engines used in heavy

- duty vehicles greater than 14,000 lb GVWR be separately certified by their manufacturers to meet CO 2 , N 2 O, and CH 4 emissions standards using the s ame test procedures used to certify engines for other pollutants (NOx, PM, etc.). Phase 1 created separate GHG emissions standards for spark

- ignition (traditionally gasoline

- fueled) and compression

- ignition (traditionally diesel

- fueled) engines.
Alternat ive fuel engine converters, who obtain incomplete engines and install fuel systems to allow the engine to run on alternative fuels, were required to meet the applicable engine standard based on the architecture of the base engine.



### 2.2 Description of t he Rule and its Scope

The Administration’s 2013 Climate Action Plan instructed EPA and NHTSA to “once again partner with industry leaders and other key stakeholders to develop post

- 2018 fuel economy standards for heavy

- duty vehicles.” On February 18, 2014, the Pr esident further directed EPA and NHTSA to finalize these standards by March 31, 2016.

Similar to the Phase 1 rule, the proposed Phase 2 rule would significantly reduce GHG emissions associated with the transportation of goods across the United States post

- 2018. Phase 2 may include changes to existing engine and vehicle GHG standards, as well as regulatory standards and certification requirements for previously

- unregulated new trailers pulled by semi

- tractors. If such a rule is adopted, manufacturers of heav y

- duty engines, chassis, vehicles and trailers could be

3required to incorporate GHG

- reducing and fuel

- saving technologies. Many of these technologies are available in the marketplace already, but some may still be in development at this time.

Phase 2 will build upon the requirements in Phase 1 and could generally rely on the same basic certification and compliance structure. As part of the proposed rulemaking, EPA may consider increased stringency of engine and vehicle emissions standards based on engine an d vehicle manufacturers’ current projections of technology use, as well as EPA’s own assessment of the penetration of existing emission

- control technologies and potential for application of new, emerging technologies.

Manufacturers meeting the applicable small business criteria in 13 CFR 121.201 were not subject to the GHG emissions standards in Phase 1. EPA does not intend to extend such broad exemptions into Phase 2, but EPA may replace them with limited and targeted flexibilities. The
recommendations outlined in this SBAR Panel Report will be used to identify and implement appropriate flexibilities for these small businesses.



### 2.3 Related Federal Rules

The proposed Phase 2 rule under consideration builds on EPA’s Phase 1 GHG and fuel efficiency rule ( Federa l Register Vol. 76, p. 57106, September 15, 2011) . In addition, manufacturers are required to comply with all current standards set by EPA and other Federal and State agencies. EPA identified several standards related to the industries affected by this p roposed rulemaking.
These are listed in Table 1

.

The P anel recognizes that there is the potential for a tension between technologies to improve
fuel efficiency and some other Federal mandates, such as NHTSA safety regulations

, EPA emissions

st andards for criteria pollutants, and EPA transportation fuel blending requirements for biofuels

. EPA sought information from SERs on many of these tensions and flexibilities that could aid small businesses in complying with these multiple mandates and will continue to seek comment on them in the rulemaking development process . Nonetheless, i t is the responsibility of the manufacturers to ensure that they continu e to meet these requirements when adopting new technologies and strategies for the proposed Phase 2 rulemaking.

4Table 1 : Federal and State regulations related to the industries impacted by this rulemaking

Agency Rule Title

EPA 40 CFR 85 Control of Air Pollution from Mobile Sources

40 CFR 86 Control of Air Pollution from New and In

- Use Highway Vehicles and Engines

40 CFR 600 Fuel Economy and Greenhouse Gas Exhaust Emission of Motor
Vehicles

40 CFR 1036 Control of Emissions from New and In

- Use Heavy

- Duty Highway Engines

40 CFR 1037 Control of Emissions from New Heavy

- Duty Motor Vehicles

40 CFR 1039 Control of Emissions from New and In

- Use NonRoad Compression

Ignition Engines

40 CFR 1065 Engine

- Testing Procedures

40 CFR 1066 Vehicle Testing Procedures

40 CFR 1068 General Compliance Provisions for Highway, Stationary, and Nonroad Programs

California A RB AB 32 California Global Warming Solutions Act of 2006

NHTSA 49 CFR 523 Vehicle Classification

49 CFR 534 Rights and Responsibilities of Manufacturers in the Context of Changes in Corporate Relationships

49 CFR 535 Medium

- and Heavy

- Duty Vehicle Fuel Efficiency Program

49 CFR 565 Vehicle Identification Number (VIN) Requirements

49 CFR 566 Manufacturer Identification

49 CFR 567 Certification

49 CFR 568 Vehicles Manufactured in Two or More Stages

49 CFR 569 Regrooved Tires
49 CFR 573, 577, 579 Defect and Noncompliance

49 CFR 574 Tire Identification and Recordkeeping

49 CFR 575 Consumer Information

49 CFR 576 Record Retention

FMVSS 106 Brake Hoses

FMVSS 108 Lamps, Reflective Devices, and Associated Equipment

FMVSS 119 New Pneumatic Tires for Vehicles Other Than Passenger Cars

FMVSS 120 Tire Selection and Rims for Motor Vehicles Other Than Passenger
Cars

FMVSS 121 Air Brake Systems

FMVSS 223 Rear Impact Guards

FMVSS 224 Rear Impact Protection

FMVSS 303 Fuel System Integrity of Compressed Natural Gas Vehicles

FMVSS 304 Compressed Natural Gas Fuel Container Integrity

FHWA 23 USC 127 Vehicle Weight Limitations

– Interstate System

23 CFR 657 Certification of Size and Weight Enforcement

23 CFR 658 Truck Size and Weight, Route Designations

– Length, Width and Weight Limitations

5

### 3 OVERVIEW OF PROPOSAL UNDER CONSIDERATION

3.1 Potential Requirements and Guidelines of the Proposal

Building on the Phase 1 rule, this proposed Phase 2 rule will significantly reduce GHG emissions associated with the transportation of goods across the United States post

- 2018. The proposed Phase 2 rule making considers changes to existing engine and vehicle GHG standards, as well as regulatory standards and certification requirements for previously

- unregulated new trailers pulled by semi

- tractors. If such a rule is adopted, manufacturers of heavy

- duty en gines, chassis, vehicles and trailers could be required to incorporate GHG

- reducing and fuel

- saving technologies in order to comply with EPA’s performance

- based standards. The proposed Phase 2 standards would represent a more technology

- forcing approach t han the Phase 1 approach, effectively requiring manufacturers to apply both off

- the

- shelf technologies and potentially technologies still under development. Unlike the Phase 1 rulemaking

, EPA is not proposing to exempt small businesses
from the Phase 2 pr oposal

.

3.1.1 Engines

EPA is proposing to continue the basic Phase 1 structure for the Phase 2 engine standards. There would be separate standards and test cycles for tractor engines, vocational diesel engines, and vocational gasoline engines , including a propos ed revis ion to the test cycle for tractor engines to better reflect actual in

- use operation. EPA is proposing more stringent standards for all on

- highway diesel engines and gasoline engines used in pickup trucks and vans in the Class 2b and 3 weight categories. EPA is not planning to propose more stringent standards for gasoline engines used in
vocational vehicles. In Phase 2, alternative fuel converters will continue to be subject to engine and vehicle standards for GHG emissions. Small business alternative fuel converters of new engines may also be required to report and/or certify their engines and vehicles meet the GHG standards in addition to criteria pollutants.

3.1.2 Tractors

EPA is proposing to largely continue the Phase 1 tractor program but to propose new
standards. EPA project s that the proposed tractor standards could be met through improvements in the engin e, transmission, driveline, aerodynamic design, lower rolling resistance tires, extended idle reduction technologies, and other accessories of the tractor. EPA ’ s evaluation show s that some of these technologies are available today, but have very low a dopt ion rates on current vehicles, while others will require some lead time for development

. Similar to Phase 1, EPA is proposing to use the Greenhouse gas Emissions Model (GEM) vehicle simulation tool as the “test procedure” to certify the complete tractors. The proposed rule will include several updates to this model, including new vehicle categories, simulated test cycle improvements, and recognition of additional technologies. EPA is not aware of any tractor manufacturers who are small businesses.

63.1.3 Vocatio nal Vehicle Chassis

EPA is proposing to revise the Phase 1 vocational vehicle program and p ropose new standards. These proposed standards also reflect further sub categorization from Phase 1 , with separate proposed standards based on mode of operation: ur ban, rural, and multi

- purpose. EPA is also proposing alternative standards for certain low

- volume emergency vehicles. EPA project s that the proposed vocational vehicle standards could be met through improvements in the engine, transmission, driveline, lo wer rolling resistance tires, workday idle reduction technologies, and weight reduction. In Phase 1, EPA adopted air conditioning ( A/C ) refrigerant leakage standards for tractors, as well as heavy

- duty pickups and vans, but not for vocational vehicles. However, EPA now believes that it would be feasible to apply similar A/C refrigerant leakage standards for vocational vehicles in the Phase 2 proposal. Small business vocational vehicle chassis manufacturers may be required to report and/or certify their chassis meet the Phase 2 GHG
standards.

Gliders are new truck chassis that are intended to be combined with used engines, transmissions and/or axles. Traditionally, gliders were produced to improve vehicles damaged in
accidents or those that lost function with age. In these cases, often much of the powertrain was in working condition and gliders were a way to avoid the purchase of a completely new vehicle. Prior to 2011, fewer than 1000 glider kits were produced per year. In 2011 and 2012, sales spiked to almost 4000 per year. Many of the glider kits use pre

- 2002 engines, which have low fuel consumption and CO 2 emissions compared to current engines (the primary focus of this proposed rulemaking), but higher NOx and PM than current engines. EPA plans to include glider
manufacturers in the vocational vehicle chassis manufacturer requirements in Phase 2.

3.1.4 Complete Pickup Trucks and Vans

EPA is proposing to adopt new Phase 2 GHG emission and fuel consumption standards for complete heavy

- duty pickups and vans that would be applied in largely the same manner as the Phase 1 standards. These standards would effectively require the use of most existing technologies, but would stop short of requiring significant use of strong hybrid powertrain technology o r lean

- burn gasoline direct injection (GDI). EPA is not aware of any small businesses who manufacture heavy

duty pickup trucks or vans.

3.1.5 Trailers

EPA is , for the first time, proposing a set of GHG (as CO 2 ) emission and fuel consumption
standards for manu facturers of new trailers pulled by Class 7 and 8 tractors

. The proposed standards would gradually require trailer manufacturers to achieve incrementally greater aerodynamic and/or tire improvements and cover more trailer types as the program phases in. Many of the existing CO 2

- reducing technologies have been evaluated and verified through EPA’s SmartWay Transport Partnership. Adoption of and demand for these technologies continues to rise due to fleet participation in the voluntary SmartWay program, as w ell as enactment of California’s Assembly Bill 32 (AB32), which required aerodynamic equipment and lower

- rolling resistance tires on most tractors and trailers operating in California. Many trailer manufacturers are small businesses.

7EPA is proposing tha t Phase 2 r egulate manufacturers of on

- highway dry van and refrigerated van (reefer) trailers. These trailer types constitute over 60% of the heavy

- duty truck trailer market and have the greatest potential for application of aerodynamic technologies to red uce CO 2 emissions. Container chassis, which are used to transport intermodal containers, as well as some configurations of flatbed and tank trailers, could also be considered for inclusion in the aerodynamic requirements of the regulation. EPA is also cons idering requirements for tire technologies (e.g.,
lower

- rolling resistance tires and automatic inflation systems) on nearly all on

- highway trailers. Similar to the tractor program, trailers would not be expected to measure CO 2 emissions through testing. Instead, EPA’s vehicle simulation model, GEM, would be used to calculate an emissions rate. Some testing is expected to be required to obtain the inputs needed for the vehicle model.



### 4 APPLICABLE SMALL ENT ITY DEFINITIONS

The Regulatory Flexibility Act (RFA) defines small entities as including “small businesses,” “small governments,” and “small organizations” (5 USC 601) and references the Small Business Act for the definition of “small businesses” using size standards based on the North American Industr y Classification System (NAICS) (13 CFR 121.201). The standards being considered by EPA for this rulemaking are expected to affect a variety of small businesses. A listing of the NAICS codes identified as relevant to the potential rulemaking, along with th eir respective SBA size thresholds, is
located in Table 2 in Section 5, below.



### 5 SMALL ENTITIES THAT MAY BE SUBJECT TO TH E PROPOSED
REGULATION

EPA expects the same indus tries affected by the Phase 1 rulemaking will also be affected by the proposed Phase 2 rulemaking. In addition, small businesses and trailer manufacturers are also expected to be included in the proposed Phase 2 rule. EPA used the criteria for small enti ties developed by the Small Business Administration (SBA) as a guide to identifying Small Entity Representatives (SERs) for th is proposed rulemaking. Table 2 below lists industries potentially directly affected by the regulation. The NAICS Code and size t hreshold are shown as well.

Table 2 : Industry Sectors Potentially Affected by EPA’s Planned Action

Industry Expected in Rulemaking NAICS
Code NAICS Description SBA Size
Threshold

Alternative Fuel Engine Converters 333999 Misc. General Purpose Machinery 500 employees

811198 All Other Auto Repair & Maintenance $7.0M (annual receipts)

HD Pick

- up Trucks & Vans 336111 Automobile Manufacturing 1,000 employees
Vocational Chassis,
Class 7 & 8 Tractors 336120 Heavy

- Duty Truck Manufacturing 1,000 employees

Trailers 336212 Truck Trailer Manufacturing 500 employees

333924 Ind. Truck, Trailer & Stacker Machinery 750 employees

HD Engines 336310 Motor Vehicle Gasoline Engine & Engine
Parts 750 employees

8Using this information, with EPA’s certification data and employment information from the Hoover’s Online business information database, EPA determined that only three of these affected
industries contained small businesses: vocational chassis manufacture rs, alternative fuel engine converters and trailer manufacturers, as described below. EPA believes there are about 115 trailer manufacturers and 100 of these manufacturers qualify as small entities with 500 employees or less.
EPA identified 21 alternat ive fuel engine converters from previous certification data and 18 of these converters are considered small entities. Currently, 20 manufacturers who make chassis for vocational vehicles certify with EPA under the Phase 1 program. Three vocational chassi s manufacturers contacted EPA to request an exemption from Phase 1 based on their small entity status. Gliders are a subset of vehicles is being considered for regulation under the proposed Phase 2 rulemaking. Glider manufacturers traditionally manufactu re new vehicle bodies (vocational vehicles or Class 7 and 8 tractors) for use with older powertrains. EPA is aware of four glider manufacturers
and three are small entities.



### 6 SUMMARY OF SMALL ENT ITY OUTREACH

Before beginning the formal SBREFA process, E PA actively engaged in outreach with entities that would potentially be affected by the upcoming rulemaking. EPA held phone conferences
and face

- to

- face meetings with many of these companies to discuss the upcoming proposed rulemaking and to provide these contacts with an early opportunity to ask questions and discuss their concerns with the upcoming rulemaking.

Prior to convening the Panel, EPA conducted outreach with small entities that will potentially be affected by these regulations. On April 2, 2014, EPA issued a press release to solicit potential small entity representatives (SERs) to participate. Eleven e ligible representatives from eight small businesses or organizations volunteered to participate as potential SERs. Two additional SERs volunteered later in the process.

EPA conducted a meeting and teleconference with potential small entity representatives (SERs) on June 19, 2014. This outreach meeting was held to solicit feedback from the potential SERs on their suggestions for the upcoming rulemaking. To help these entities prepare for the meeting and teleconference, EPA sent materials on June 5, 2014 to each of the potential SERs via email. A list of the materials shared with the potential SERs during the pre

- Panel outreach meeting is contained in Appendix A. For the June 19, 2014 pre

- Panel outreach meeting with the potential SERs, EPA also invited repres entatives from the Office of Advocacy of the Small Business Administration and the Office of Information and Regulatory Affairs within the Office of Management and Budget. A total of 10 potential SERs participated in the pre

- Panel outreach meeting. EPA pre sented an overview of the SBREFA process, an explanation of Phase 1 and the planned rulemaking, and other background information. EPA asked the potentials SERs to provide written comments by July 7, 2014. Comments discussed during the June 19 outreach mee ting and written comments submitted by the potential SERs are summarized in Section 8 of this document.

9The Panel convened on October 22, 2014 and EPA distributed additional information to the SERs for their review and comment in preparation for another outreach meeting. On November 5

- 6,
201 4, the Panel met with the SERs to discuss the outreach materials and receive feedback on EPA’s proposed approaches and possible flexibilities detailed in the outreach packet s

. The first meeting

was held on November 5, 2014 for trailer manufacturers , followed by two separate meetings on November 6, 2014 with the alternative fuel engine converters and vocational chassis manufactures. The Panel also met with trailer manufacturer SERs on October 28, 2014 , prior to the off icial meeting
on November 5

. The SERs were asked to provide written feedback on ideas under consideration for the proposed rulemaking and responses to questions regarding their experience with existing CO 2

- reducing technologies. The Panel received written comments from the SERs in response to the discussions at these meetings and we have summarized them in Section 8 . Their full written comments are also attached (see Appendix B). In light of these discussions and comments, the Panel considered the regulat ory flexibility issues specified by RFA/SBREFA and developed the findings
and discussion summarized below.



### 6.1 Pre

- Panel Outreach Meeting with Potential Small Entity Representatives

A Pre

- Panel Outreach Meeting was conducted for the potential Small Entity Repr esentatives. The meeting included an overview of the Panel Process lead by EPA’s Office of Policy. The program office, EPA’s Office of Transportation and Air Quality, delivered a presentation introducing the proposed Phase 2 Heavy

- Duty Greenhouse Gas Em issions Standards, followed by questions and a discussion.

Meeting Attendance

• Lanelle Wiggins, EPA Office of Policy (OP)

• Peter Nagelhout, EPA

- OP

• Jessica L. Brakora, EPA Office of Transportation and Air Quality (OTAQ)

• Glenn W. Passavant, EPA

- OTAQ

• Tad Wyso r, EPA

- OTAQ

• Nathan Ranns, ORISE Intern for the EPA

- OTAQ

• David Rostker, SBA Office of Advocacy (OA)

• Charley Maresca, SBA

- OA

• Christine Kym n , SBA

- OA

• Chad Whiteman, OMB Office of Information and Regulatory Affairs (OIRA)

• Karen Teslovich, CNG One Source, Inc.

• Jan Hoover, Diamatrix (phone)

• Fred Pearson, E

- One, Inc. (phone)

• Bradley Shrock, E

- One, Inc. (phone)

• Adam Jump, Indiana

- Phoenix, Inc. (phone)

• Neil Johnson, Spartan Truck Company (phone)

• Andy Suhy, Power Solutions International, Inc. (phone)

• Bill Harp, Engin e Certification Organization (representing CleanFUEL USA and helping Power Solutions International, Inc.) (phone)

10• Jeff Sims, Truck Trailer Manufacturers Association (phone)

• John Freiler, Truck Trailer Manufacturers Association (phone)

6.1.1 Pre

- Panel Outreach Meeting Summary

Lanelle Wiggins of EPA’s Office of Policy delivered a presentation titled “An Overview of the Small Business Advocacy Review Panel Process”

. David Rostker of SBA’s Office of Advocacy emphasized the goals of the Panel and the role of the SE Rs in the process. Jessica Brakora of the

p rogram o ffice (EPA’s O ffice of T ransportation and Air Quality) delivered a presentation titled
“Medium

- and Heavy

- Duty Vehicle Greenhouse Gas Rule (Phase 2)

– SBAR Pre

- Panel Outreach Meeting”

. The presentation o ffered an overview of the Phase 1 regulation, a timeline of the Phase 2 program, and expected details of the new rulemaking

.

EPA was asked when t he NPRM for Phase 2 is expected, and EPA responded that it is expected in March 2015 . When asked if regulated entities would have to comply with both the EPA and NHTSA regulations separately or together , EPA noted that EPA houses the certification process
for both and that when an entity certifies with EPA, the info rmation is transferred to NHTSA, so complying with one indicate s compliance with the other

.
A trailer manufacturer asked if the criteria for trailer regulations would be the reduction of
CO 2 , a drag coefficient, or something else , and EPA described that the input to the vehicle
simulation w ould be a drag coefficie nt and rolling resistance value and that the result that is shared
with EPA is a CO 2 emissions rate (g/ton

- mi).

A vocational chassis manufacturer asked EPA if it would be able to trade credits between divisions if they fall into dif ferent segments of the regulations . SBA as ked the manufacturer to notify the Panel of how an ABT program could best work for its product line.

An alternative fuel converter asked if small companies could sell credits to large manufacturers to help them comply . EPA responded that c onceptually, yes . Ho wever, the potential ABT program needs to be evaluated and the potential issue of “windfall credits” needs to be
considered . SBA added that t rading to a competitor is rare in ABT programs since it gives a n advantage to competitors. A veraging and banking of credits is generally more valuable for companies.

An alternative fuel converter stated the importance of knowing what requirements are in the works as soon as possible to minimize the number of times ope rations are adjusted to comply . OM B asked EPA to consider existing renewable fuel standards when developing the Phase 2 program

. SBA asked EPA to elaborate on whether it is thinking of promulgating different standards for different fuel types or a single standard for each engine class . EPA replied that the Phase 1

sta ndards were by engine type only. F or Phase 2, it is still under consideration whether specific rules for specific fuels will be developed

.

11

### 6.2 SBAR Panel Outreach to Small Entity Representative s

6.2.1 Trailer Manufacturers

Since the trailer industry as a whole has never been regulated by EPA, the Panel wanted to ensure that the SERs had a thorough unde rstanding of the materials in order to facilitate a constructive meeting during the official Panel Ou treach meeting on to be held on November 5. On October 28, 2014, the Panel offered a supplementary outreach meeting for the trailer SERs via
conference call and video conference . The purpose of the meeting was to present the materials and answer any clar ifying questions regarding the materials or the Panel process.

6.2.1.1 Summary of the Supplementary Meeting, October 28

Meeting Attendance

• Lanelle Wiggins, EPA Office of Policy (OP)

• Bill Charmley, EPA Office of Transportation and Air Quality (OTAQ)

• David Rostker, SBA Office of Advocacy

• Chad Whiteman, OMB Office of Information and Regulatory Affairs (OIRA)

• Jessica Brakora, EPA OTAQ

• Tad Wysor, EPA OTAQ

• Tia Sutton, EPA OTAQ

• Dennis Johnson, EPA OTAQ

• Peter Nagelhout, EPA OP

• Steve Silverman, EPA Office of General Council (OGC)

• Patrick Delehanty, SBA Office of Advocacy

• Jan Hoover, Diamatrix/Strick

• John Freiler, Truck Trailer Manufacturers Association

• Jeff Thompson, Timpte

• Steven Fairbanks, XL Specialized Trailers

• Shannon Richardson, XL Specialized Trailers

• D avid de Poincy, East Manufacturing

During the meeting, EPA presented the materials and solicited feedback on topics that could be further expanded during the official Outreach Meeting. SBA encouraged the SERs to provide specific information about their p roducts physical characteristic and use patterns to help EPA effectively identify appropriate flexibilities and exemptions if necessary. Following the meeting, two SERs provided feedback to guide the discussion during the November 5 meeting.

The SER fro m Diamatrix/Strick provided descriptions of some trailer characteristics that my not be amenable to the technologies listed in the materials and asked for more information on how
trailer families would be defined. He believes testing would be a “huge expe nse” and that his company would benefit from a chance to pick from approved devices. He asked for clarification on

12what is required during each stage of the certification process in order to determine the amount of time and resources that would be require d. He also confirmed that he would like access to the GEM simulation tool to test its functionality. In terms of the record keeping, he asked what type of data was required and how long the records were required to be kept. Finally, he stated that he wou ld appreciate a workshop similar to the one held for tractors in Phase 1 in order to better prepare his company for regulation.

The SER from Timpte also sent comments prior to the Outreach Meeting. He described his company and product line and his experie nce with the technologies listed in the materials. He noted that he was unsure how well the technologies would be accepted by his customer s and that each trailer is custom built and that their customers “are reluctant to allow us to add anything to the tr ailer that they didn’t specify.” He is also concerned that significant changes to the products may cause his customers to delay purchasing the products, particularly for aerodynamic devices. Requirements to install new components could require additional space in their facility as well as a need to hire more employees, which can be difficult in their rural community.

6.2.1.2 Outreach Meeting, November 5

Meeting Attendance

• Lanelle Wiggins, EPA Office of Policy

• Bill Charmley, EPA Office of Transportation and Air Qu ality

• David Rostker, SBA Office of Advocacy

• Chad Whiteman, OMB Office of Information and Regulatory Affairs

• Jessica Brakora, EPA OTAQ

• Tad Wysor, EPA OTAQ

• Tia Sutton, EPA OTAQ

• Chuck Moulis, EPA OTAQ

• Patrick Delehanty, SBA Office of Advocacy

• Karl Simon, EPA OTAQ

• Dennis Johnson, EPA OTAQ

• Nathan Ranns, ORISE intern with EPA OTAQ

• Peter Nagelhout, EPA OP

• Steve Silverman, EPA OGC

• Joan Rogers, EPA Office of Small Business Programs (OSBP)

• Jan Hoover, Diamatrix/Strick (by phone)

• John Freiler, TTMA (by phone)

• Steven Fairbanks, XL Specialized Trailers (by phone)

• Shannon Richardson, XL Specialized Trailers (by phone)

• David dePoincy, East Manufacturing (by phone)

• Andy Grove, East Manufacturing (by phone)

• Gary Christen, E.D. Etynre (by phone)

13During the Trailer SER O utreach M eeting, EPA’s Office of Policy described the Panel process and the role of the SERs. The remaining portion of the alloted time was used for discussion of the materials. Diamatrix/Strick asked if businesses could have an opportunity to report to EPA more frequently than once at the end of the year to ensure their accounting was correct. EPA offered that it was possible to allow more frequent check

- in opportunities if a company found value in them, though it would only require a single official re port at the end of the year.

Several SERs asked for clarification of the “model year” definition and EPA explained the definition that is used for many of its regulatory programs. Most manufacturers ’ current model year strategies fit EPA’s definition, t hough many agreed that a regulatory model year that aligned with a calendar year manufacture date would be the easiest to understand.

In terms of technologies, two of the SERs who make flatbed and specialty trailers noted that very few LRR tires were ava ilable in the sizes and ratings required for their trailers’ applications. Many of the SERs had experience with automatic tire inflation (ATI) systems, but they commented that they most certainly did not get the same prices that the larger manufacturers w ere receiving. They also mentioned that some ATI systems are only compatible with certain suspension systems and were not always interchangeable with the specifications of a given trailer.

XL Specialized was concerned about ABT, since his company produc ed small volumes of just flatbeds. If a company produced dry vans or reefers that got a lot of credits, that company might be able to put zero technologies on their flatbeds. EPA stated that ABT averaging sets could be restrictive (e.g., flatbeds only) o r very broad and requested the SERs provide feedback on their preference, since some companies may prefer to have very broad averaging sets.

East Manufacturing, who manufacturers bulk commodity trailers, commented that their
trailers are not in EPA’s Sma rtWay program and XL Specialized confirmed the same for his flatbeds. Diamatrix/Strick noted his concern with testing and that he would prefer a vender

- based option. East agreed that testing would be difficult to do. They sell so limited volumes of high ly variable trailers and it would be difficult to group them to test.

Timpte asked how trailer families would be developed. EPA responded that trailers would be grouped based on their design and the performance they could achieve. The tractor program

a llowed families to be grouped according to the devices that were added. EPA requested descriptions of the SERs technologies (noting EPA’s strict CBI provisions) and asked for objective physical characteristics that may help distinguish the trailers’ use p atterns.

Finally, the SERs commented that ATI systems seemed to be available to meet their current demand. LRR tires are less available in some applications. SBA asked if they provide tires or if
the customers choose them. East noted that its standa rd option has “tried

- and

- true” options at a good cost. Some customers will request other tires for specific needs, but there is not a lot of demand for LRR tires on East’s trailers. Timpte commented that the tire manufacturers started in the van market

w here there is the most demand and it is just now trickling down to the other trailer sectors.

146.2.2 Alternative Fuel Engine Converters

6.2.2.1 Summary of the Outreach Meeting, November 6

Meeting Attendance

• Lanelle Wiggins, EPA Office of Policy (OP)

• Bill Charmley, EPA O ffice of Transportation and Air Quality (OTAQ)

• David Rostker, SBA Office of Advocacy (Advocacy)

• Chad Whiteman, OMB Office of Information and Regulatory Affairs (OIRA)

• Jessica Brakora, EPA OTAQ

• Tad Wysor, EPA OTAQ

• Tia Sutton, EPA OTAQ

• Chuck Moulis, EPA OTAQ

• Alan Stout, EPA OTAQ

• Patrick Delehanty, SBA Advocacy

• Peter Nagelhout, EPA OP

• Paula Hoag, EPA, Office of Small Business Programs (OSBP)

• Michael DeGain, Engine Certification Organization (by phone)

• Todd Trauman, Engine Certification Organization (by pho ne)

• Josh Pietek, Engine Certification Organization (by phone)

• Karen Teslovich, CNG One Source (by phone)

• Andy Suhy, Power Solutions International (by phone)

The Outreach Meeting for Alternative Fuel Engine Converter (AFC) SERs began with a presentation by EPA’s Office of Policy describing the Panel process and the role of the SERs. EPA then stepped through the meeting materials. The SER from PSI asked if it was possible to trade credits from natural gas (NG) engines with gasoline or diesel engines in an ABT system. EPA responded that there is nothing restricting EPA from allowing a very broad definition of averaging sets, particularly for small businesses. PSI commented that he did not support a lower standard for natural gas engines as was suggested in the NAS report. He felt that it negated any advantage that they might have with their NG engines. CNG One Source commented that their company also does not support lower standards for NG with no lower standards for the other alternative fuels. She highl ighted that it is already difficult for them as a small business.

The AFC SERs asked EPA to expand on the OBD requirements for NG engines. EPA responded that for Phase 1, OBD requirements were limited to leak detection in the evaporative system and did not require measurement of CO 2 or methane. ECO stated that OBD requirements will be particularly difficult for converters since they do not have access to the algorithms developed by the base engine’s OEM. Small businesses in particular, who don’t have a direct connection with the large manufacturers, will have a difficult time writing new algorithms without access to the diagnostics from the OEM. CNG One Source stated that NHTSA already has leakage requirements for component failures tied to the pressur e regulator and that other OBD requirements that are tied to

15fuel characteristics will be hard for NG engines, since the fuel is so variable depending on the

source.

In terms of N 2 O requirements, ECO stated that currently labs are only just now getting set to measure N 2 O and he estimated that measurement from a contracted test facility could cost around $2000 . Since there is little N 2 O expected from spark

- ignition (SI) engines, he supports the use of “engineering analyses” to show that the N 2 O emissions ar e unchanged from a compliant base engine. However, a full waiver would be well received from the smalls his company represents. The SER from PSI commented that his company has control of the catalyst formulation for his compression

ignition (CI) engines, but that he doesn’t expect much change from a compliant CI engine either. He would advocate for allowing the engineering analysis as well. PSI also asked if engine manufacturers could receive credit for hybrid technologies, such as start

- stop, that are a ssociated with the engine. EPA stated that currently hybrid technologies are recognized at the vehicle level,
but it could be considered.

The AFC SERs asked if they could participate in the vocational vehicle outreach meeting
later in the afternoon and EPA responded that they were welcome to join the call.

6.2.3 Vocational Vehicle Chassis Manufacturers

6.2.3.1 Summary of the Outreach Meeting November 6

Meeting Attendance

• Lanelle Wiggins, EPA Office of Policy (OP)

• Bill Charmley, EPA Office of Transportation and Air Qua lity (OTAQ)

• David Rostker, SBA Office of Advocacy (Advocacy)

• Chad Whiteman, OMB Office of Information and Regulatory Affairs (OIRA)

• Jessica Brakora, EPA OTAQ

• Tad Wysor, EPA OTAQ

• Tia Sutton, EPA OTAQ

• Chuck Moulis, EPA OTAQ

• Lauren Steele, EPA OTAQ

• Patrick Delehanty, SBA Advocacy

• Peter Nagelhout, EPA OP

• Lillian Harris, EPA Office of Small Business Programs (OSBP)

• Adam Jump, Indiana

- Phoenix (by phone)

• Kevin Kelly, Indiana

- Phoenix (by phone)

• Rand Smith, Sutphen Corporation (by phone)

• Karen Teslovich, CNG One S ource (by phone)

• Andy Suhy, Power Solutions International (by phone)

16EPA’s Office of Policy presented a description of the Panel process and described the role of
SERs to the vocational vehicle chassis manufacturers. Two of the AFC SERs were also in

atte ndance for this meeting. EPA began by asking if the SERs were able to go through the materials prior to the meeting and they confirmed that did. The meeting began with SBA asking about the chassis manufacturers’ experience with LRR tires. Sutphen, the f ire apparatus manufacturer SER, stated that LRR tires are the most appropriate technology for their industry. They do have special, knobby tire s, but there are some LRR available. SBA recommended that the SERs provide written
comments with how much of th eir production need non

- LRR tires for their applications (off

- road, snow, etc)

.

In terms of transmissions, all fire trucks are automatics with PTO. Idle reduction is not feasible, because if they’re stopped, they’re in neutral. Sutphen has worked with axle manufacturers to improve gearing for performance (take

- off and acceleration), but not for fuel economy. EPA noted that axle improvements could be through lubricants, which Sutphen responded would be easy to implement, but it doesn’t provide a very la rge improvement. APUs could be of use for on

- scene applications, but those engines aren’t much cleaner. Hybrids do not have the power or PTO for emergency applications. Sutphen also noted that fire trucks shift from an axle driver to a pump
driver and s tay in gear to pump the water. Also, emergency vehicle purchase special engines and transmissions that have special calibrations for their applications. They are “certified” engines, but they were produced as part of the engine OEM’s ABT program.

India na

- Phoenix, the SER who manufacturers cement mixers, indicated that a hydraulic pump turns the drum through PTO and when it gets to the job site, the vehicle has to be at an elevated idle to move the shoot. He has asked tire manufacturers for LRR data, bu t they do not provide it to him. All of Indiana

- Phoenix’s chassis use super single tires that are a cog

- type tire. He asked the number of axles that would be represented in GEM. EPA responded that there would be a “representative” vehicle, which may not have the same number of axles, but it would not affect compliance if a company’s production has more or fewer. He noted that 100% of his chassis products are rear engines and that they may be on the highway to get to a construction site, but spend

most of their time sitting.

Both chassis SERs indicated that they believe they have limited ability to take advantage of ABT since their production volumes are so low and they sell very specific, custom chassis. SBA asked about air conditioning. Indiana

- Ph oenix stated that only about 10% of their sales ask for A/C and it takes about 20 feet of tubing to connect the A/C system from the rear engine to the cab. Sutphen said all of their fire trucks have A/C installed and they are very high capacity system.
N either company was familiar with the SAE J2727 leakage calculation standard for vehicles, but they committed to ask their engineers.



### 7 LIST OF SMALL ENTITY REPRESENTATIVES

Table 3 lists the small entity representatives (SERs) that participated in the SBAR Panel for the Heavy

- Duty Greenhouse Gas Phase 2 proposed rulemaking.

17Table 3 : List of Sm all Entity Representatives

Name Industry/Sector Business Name & Address
Michael DeGain, Bill Harp , Josh Pietak Engine Certification (on behalf of Engine Converter) Engine Certification Organization Rocklin, CA 95677

Karen Teslovich Alternative Fuel Engine Converter CNG One Source, Inc. Erie, PA 16505

Andy Suhy Secondary Engine Manufacturer Power Solutions International, Inc. Wood Dale, IL 60191

Adam Jump Vocational Chassis Manufacturer (Cement Mixer) Indiana

- Phoenix, Inc. Avilla, IN 46710

Rand Smith Vocational Chassis Manufacturer (Fire Apparatus Chassis) Sutphen Corporation Chassis Division Springfield, OH 45501

Jan Hoover Trailer Manufacturer (Dry Van, Container, Specialty) Diamatrix Fairless Hills, PA 19030

Neil Johnson Trailer Manufacturer (Transfer, Pup) Spartan Truck Company Sun Valley, CA 91352

Trey Gary Trailer Manufacturer (Flatbed, Dry Bulk) Dorsey Trailer Elba, AL 36323

Steven Fairbanks Trailer Manufacturer (Flatbed) XL Specialized Trailers Manchester, IA 52057

Jeff Thompson Trailer Manufacturer (Dump, Grain) Timpte Inc. Denver, CO 80203

Gary Christen Trailer Manufacturer (Flatbed, Heavy

- Haul) E.D. Etnyre Oregon, IL 61061

Dave de Poincy Trailer Manufacturer (Flatbed, Dump, Refuse) East Manufacturing Randolph, OH 44265

Jeff Sims
, John Freiler Trailer Manufacturer Trade Assoc. Truck Trailer Manufacturers Assoc. Gainesville, VA 20155



### 8 SUMMARY OF COMMENTS FROM SMALL ENTITY
REPRESENTATIVES

8.1 Summary of Written Comments Following Pre

- Panel Outreach Meeting

At the conclusion of the Pre

- Panel Outreach Meeting, potential SERs were asked to submit written questions and comments to EPA. Five of nine entities submitted written materials to EPA. The following subsections summarize these submissions.

8.1.1 Trailer Manufa cturers

One trailer manufacturer su bmitted written comments to EPA following the Pre

- Panel Outreach Meeting. EPA received comments from Diamatrix on July 1, 2014.

188.1.1.1 Feasibility of Proposed Technologies

Diamatrix (holding company for Strick Trailers and Evan s Trailers) discussed its range of specialty trailers, including drop

- frame dry freight van trailers and trailers with belly boxes that may not be compatible with currently available GHG

- reducing technologies (side skirts, etc.). Diamatrix expressed that b eing required to implement these technologies on these trailer types could result in a compliance issue or increased burden on the company. It expects to both acquire technologies from vendors and develop its own technologies in

- house. Diamatrix also state d that it does not have any experience with customer response to current California requirements. Diamatrix primarily has customers east of the Mississippi River.

8.1.1.2 Potential Reporting, Recordkeeping and Compliance Burdens

Diamatrix had several questions regarding EPA’s Greenhouse Gas Emissions Model (GEM).
It asked if computer simulation and GEM were synonymous and expressed interest in seeing a demonstration of the software. Diamatrix expressed interest in learning more about the program in general and t he overall compliance process. Diamatrix also asked how the compliance workshop
materials from Phase 1 contained in slide 37 of the Pre

- Panel Outreach Meeting presentation related
to trailers.

D iamatrix indicated a lack of understanding regarding the Avera ging, Banking, and Trading (ABT) program. Diamatrix asked EPA to further explain this program and how it may affect trailer
manufacturers.

Diamatrix expressed that it is unsure of the upcoming rule’s full impact on its operations given the preliminary sta tus of the process. However, Diamatrix did state that it anticipates unique legal, administrative and record keeping burdens as a result of compliance since it currently does not engage in any such reporting.

Diamatrix also discussed the issue of finding space to store and install any new GHG

reducing technologies that it may need to meet requirements. Diamatrix anticipates having to create a new space for these technologies, as well as increased labor. However, Diamatrix expressed that it anticipates pass ing these labor costs on to the customer.

Diamatrix did not foresee any sector

- unique business or competitive issues and was unsure of which flexibilities could serve its operations best given the preliminary nature of the rulemaking

process.

8.1.1.3 General Comme nts

Diamatrix shared concern regarding an NTSB recommendation that NHTSA proposes a “Side Underride” regulation. Diamatrix stated that it is unsure of how this regulation and the upcoming Phase 2 rule will affect each other.

198.1.2 Vocational Vehicle Chassis Manu facturers

Two vocational chassis manufacturers submitted written comments following the Pre

- Panel Outreach Meeting

. EPA received comments from E

- One on July 3, 2014 and Indiana

- Phoenix on July 7 , 2014.

8.1.2.1 Feasibility of Proposed Technologies

Indiana Phoenix, Inc. discussed the niche market it serves through the manufacturing of front discharge cement mixers. The company explained that technologies such as aerodynamics and tire inflation systems will be impractical for these vehicles as they frequently operate off road.

Indiana Phoenix, Inc. also stated that it does not currently produce any vehicles subject to Phase 1 requirements. The company has not had any experience with lower rolling resistance tires, tire inflation systems, or light weighting components . However, the company does use Cummins ISX12 engines, which do comply with Phase 1 standards. Indiana Phoenix, Inc. finds lower rolling resistance tires moderately feasible, inflation systems not very feasible, light weighting not very feasible, and Phase 1 engines moderately feasible.

8.1.2.2 Potential Reporting, Recordkeeping and Compliance Burdens

Indiana Phoenix, Inc. anticipates that the potential regulations could require the company to add additional staff, acquire FEA software, and update computers. The c ompany also mentioned potential administrative and record

- keeping burdens could arise from the potential rulemaking. Indiana Phoenix, Inc. also expressed concern that the potential regulations could overwhelm its engineering development process.

Indiana Ph oenix, Inc. mentioned that a partial exemption, partial delayed compliance and/or less stringent compliance could help the company comply. Indiana Phoenix, Inc. also asked if any grant money would be available to assist the company with compliance. The com pany also stated that the length of time given to engineer in the requirements and the stringency of compliance would affect which flexibilities would be most helpful.

E

- One Inc. commented on the diversity of its product line. E

- One Inc. expressed that it is concerned regarding the ability to be able to trade credits between different vehicle types within the same class of vehicles. The company expressed that having ABT between different vehicle types is imperative to its business model and potential future growth.

8.1.3 Alternative Fuel Engine Manufacturers

Two alternative fuel converters/secondary engine manufacturers submitted written comments
to EPA following the Pre

- Panel Outreach Meeting. EPA received comments from CNG One Source
and Power Solutions International (PSI) on July 7, 2014

.

208.1.3.1 Feasibility of Proposed Technologies

Power Solutions International stressed that GHG

- reducing technologies all impact the design
and co nstruction of the long engine block assembly. As a secondary engine manufacturer, Power Solutions International states that it, along with other small business secondary engine manufacturers, have very little ability to influence the content of the new lon g engine block assemblies purchased from automotive companies. Furthermore, the company states that it receives very little support from the long block engine manufacturer for challenges faced when developing and applying the long block engine assembly int o new applications.

In order to comply, Power Solutions International says it will need to invest in developing new and additional internal technological capability to be able to accommodate the more stringent standards. Also, small business secondary eng ine manufacturers will require additional time beyond that required by a large entity to adapt to more stringent standards.

8.1.3.2 Potential Reporting, Recordkeeping and Compliance Burdens

CNG One Source expressed that it is unlikely to manufacture a high percen tage of its CNG engines for medium

- and heavy

- duty use. Therefore, the company feels the great expense of research and development coupled with the high costs of formal emissions testing could limit the commercial availability of new CNG engine designs.

C NG One Source asked which specific testing would be required for each age category for
medium

- and heavy

- duty CNG engines. CNG One Source also asked if any alternative testing methods could accomplish the same goals (portable emissions testing equipment, s tate emissions testing, etc.).

CNG One Source also discussed the disproportionate certification expenses in relation to larger companies. The company warned that this could hinder the development of new and innovative natural gas engine technologies. CNG One Source stated that small businesses will have little resources to develop their ideas which could lead to further curtailment of the industry. CNG One Source cites the Department of Energy’s (through NREL) refusal to fund small businesses as a
reason f or this lack of resources.

Power Solutions International stated that small secondary engine manufacturers will need time to adjust and comply with the potential regulations. The company indicates that small
businesses will need to invest in human resource s and increased technological capabilities. These adaptations will require time. Power Solutions International also states that small businesses will likely never evolve to have the capability of a large automotive company. Furthermore, the company

states that small entities will struggle to support the required investment to move toward these more stringent standards.

218.1.3.3 General Comments

CNG One Source emphasized the distinction between an engine with emissions certification and a safe, durable engine. CNG O ne Source stressed that consumers pay high prices for natural gas engines for medium

- and heavy

- duty applications (partly due to the initial certification costs passed on to the consumer) and are subject to high costs for ongoing maintenance. Consumers, ho wever, believe that these high costs automatically designate the engine as safe and durable. CNG One Source argues that any CNG engine will likely pass emissions testing on the dynamometer, but will not always perform in the field. CNG One Source would lik e to see the development of a designation of a quality engine beyond merely meeting EPA standards.

CNG One Source asked about the incentive for emerging companies to follow regulations when there is a lack of EPA enforcement. The company cited shade tree m echanics offering conversions that are not EPA compliant and other small businesses thriving by performing “illegal” conversions as a reason for CNG One Source’s disadvantage in the market. CNG One Source states that companies performing illegal conversion s offer cheaper conversions, and companies such as CNG One Source that do not tamper are unable to compete. CNG One Source states that if front

- end costs of compliant systems were lower, it would recommend an annual or every three year emissions inspection which could facilitate continued maintenance on the systems and improve durability. As an example, the company cites the lack of follow through to maintain valve adjustments, which adversely impacts performance, durability, and emissions.



### 8.2 Summary of Writ ten Comments following Panel Outreach Meeting

EPA received comments from five manufacturers that included confidential business information (CBI) related to their product lines or their business practices. This information is not
included in the discussi on to follow, but will be used by EPA to develop the proposed rulemaking

.

8.2.1 Trailer Manufacturer s

The following comments from Trailer Small Entity Representatives were received:

• Timpte

– October 24, 2014

• Timpte

– November 10, 2014

• Diamatrix

– October 29, 2 014

• Diamatrix

– November 19, 2014

• East Manufacturing

– November 4, 2014

• East Manufacturing

– November 20, 2014

8.2.1.1 Number and Types of Entities Affected

Diamatrix provided production information for its company, stating that its d r y f r e i g ht v a n plant bui l ds 2500 to 3000 uni t s p e r y ea r and estimating that 50% are 53’ a nd lo n g e r v a n s , 25% are 28’ va ns , 15% are other l e n g th vans and 10% are d r op f r a me a nd s p ec ial v a ns, including b e l l y bo x e s, et c

.

228.2.1.2 Feasibility of Proposed Technologies

8.2.1.2.1 Aerodynamic Devices

Timpte stated that they have not installed any side skirts on their trailers. They only build bulk commodity trailers

– primarily used to move grain, aggregate, and other free flowing materials

– and a large portion of these materials are discharged into augers that are “swung” into position underneath of the trailer. As such, use of side skirts would preclude the ability of their customers to unload the trailers. Side skirts are not a practical solution for their style of trailer.

A ll of Timpte trailers have a portion of the trailer referred to as the Hopper Assembly which fills the majority of the space below the lower rail and between the tractor tires and the trailer tires. This Hopper Assembly would negate most of the positive impact of add ing siding skirts to their trailers, even if it was practical to do so, as their trailers do not experience the same air turbulence pattern that traditional dry freight trailers generate. Most of them do not operate at highway speeds
for other than short periods of time.

T impte has also not had any experience with rear air skirts/fairings. Timpte do es not see a practical reason why they could not be physically attached. They would interfere with the current access system that is mounted on the rear of th e trailer, wh ich is used to inspect the load. It may be possible to de sign a solution to that issue and to insure that the rear fairings did not interfere with the statutorily required lighting on the rear of the trailer.

The trailers built by Timpte are used to haul bulk commodity, any additional weight associated with adding any aerodynamic devices would be seen as a negative and result in resistance from the marketplace as it will reduce the amount of “product” that they can haul per load. If the requi red change included side skirts, Timpte stated that their business would be devastated as the customer base simply would not purchase the trailers at all. Those that would still buy the trailers would remove the side skirts as soon as they purchased the t railer as the skirts would prevent them from being able to unload the trailer. Timpte also stated that their trailers are unloaded out of the bottom of the trailer and typically into an auger system which is “swung” into place underneath of
the trailer. The auger would reside and travel through the same space as the space the side skirts would be installed. That is why they are not a practical solution for thei r particular type of trailer.

East Manufacturing provided comments that stated d ue to the spec ific applications of thei r trailer types they fear that adding aerodynamic side fairings, front and rear fairings could create unsafe conditions, higher warranty costs and product liability issu es if required to be installed. In addition, a high percentag e of the products East build s a re specified with 4 or more axles up to 8.
East Manufacturing feel s that none of the a erodynamic device currently used today would be able to be installed and if they could

, would be of little to no effect. Also, t here may be possible trailer
len gth law issues associated with b oat tails on their r efuse trailers.

Diamatrix provided comments that stated they have experience with side and rear fairings. They commented that they have not seen any benefits with the i m pl e m entation of these technologies as they are not the end user. They have heard fr o m custo m ers that t h ey s ee a b enefit
in fuel re d uction b u t those nu m bers are not concrete.

23Diamatrix commented that they build s o m e special trailers such drop fra m e dry freight van trailers and tr a i lers with belly boxes that they may not be able to use existing technologies (side skirts) for reduction of CO2. This could create an issue of co m pliance or increased burden on us. What they will b e specifically, if any, is un clear at this ti m e. They also commented that t railer options or m odels that would preclude the use of s o m e aero devices:

• Rear and side m ounted liftgates or si m il a r devices. Belly boxes and si m ilar
devices. Belly boxes are m ounted under the trailer and can be used for storing tools or eq ui p m e n t nece s sary to the freight being hauled.

• Trailers with heater u n its or s i m ilar options installed w ould not per m it
the installation of nose m o u nted aero devices.

• Vents specified at the front and rear. V e nts are usually used to pro v ide
air f low through the trailer while it is running on the highway. These m ay produce interference with nose or rear m ounted aero devices.

• Side door steps. Steps are used to per m it t h e entry into the tr a iler through the
side door. The structure of and bracing of the s e steps m ay preclude the use of
certain side aero devices.

• Trailers with m ore than three axles or tr a il er s with s p r e ad axl e s. W ith these configurations there would be no room or very little room for side and underbelly devices to be installed.

• Trailers for inter m odal use h a ve u n derneath clearance criteria and lift p ads that may cause issues with s pecific aero devices.

• Drop f ra m e tr a il e rs. Drop f ra m es trail e rs h a ve a drop in the floor at or near the landing gear. The trailers or tr a il e rs si m ilar to them would not be
conducive to so m e aero devices.

• They build so m e trailers where they build a “shell” that their custo m er m a y convert into a portable office or add m achinery t o. The modifications that are
done m a y require the re m oval of aero devices, if in s t all e d, or p recl u de the use
of them altogether

• Contain e r c h a ss i s, including extendible and specialty

• F latb e d tr a i le rs, including extendable; t y pi c a l l y fl a t b e ds h a ve win c h e s

moun t e d und e r the side r a il that c ould p rec lude the u s e of some side
fa iri n g s.

Diamatrix commented that they will ne ed to dete r m ine a pla c e in the p l a nt t h at they can i n st a l l a nd st o re the aero devices. Depending upon the devices they m ay actu a lly have to
restructure thei r line stations to accom m odate t h ere a s se m bly/installation. Diamatrix also provided
cost estimates for side f a irin g s (skirts) and r a nge f r om a rou n d $600 to $800 not i n c lud i ng ins t a l l a t i on or F ET. I ns t a l l a t i on is a round $300. They stated that p ri c ing d o e s s e e m to be c om i ng down.

8.2.1.2.2 LRR Tires

Timpte has been installing almost exclusively Low Rolling Resistance Tires for the past two

years.

24East Manufacturing commented that the only tires currently applicable to their product types

are r olling resistant dual tires, w ide base single tires

. LRR tires today are limited in availability, sizes and certain applications. It is unknown if they may have an a dverse effect to tire wear on
f latbed and multi

- axle end dumps that are subjected to “High Scrub” tire situations which could

cau se owners to buy more tires in a shorter time period. This will increase the usage of materials and drive operating cost up and profitability down for Owner operators and Fleet owners.

East Manufacturing purchases tires from several manufacturers, but the re are limited sizes available from each of them for their applications. East provided CBI related to the cost and volumes of tires installed in their trailers. Their concern is that if low rolling resistance tires and tire inflation systems were mandate d for every trailer, then they would not be able to purchase the tires or inflation systems competitively compared to the large trailer manufacturers, such as Wabash, Great Dane, and Utility and it would put East in a non

- competitive situation.

Diamatrix h as experience with LRR tires. They commented that they have not seen any benefits with the i mpl e m entation of these technologies as they are not the end user. They have
heard fr o m custo m ers that t h ey s ee a b enefit in fuel re d uction b u t those nu m bers are not concrete. Diamatrix also provided feedback that the $320 incremental cost for LRR tires is good for an
average

- some manu fac tu r e rs a re l e ss and some th a t a r e mo r e

.

8.2.1.2.3 ATI Systems

Timpte has been installing automatic tire inflation systems for approximately a dozen years and currently have about a 3% adoption rate.

East Manufacturing commented that t he only devices currently applicable to their product types are t ire pressure monitoring systems and automatic t ire i nflation systems. East provided a list
of t he types of tire monitoring and inflation systems that they install on their trailers as part of a CBI
submittal.

Diamatrix provided estimated costs for A T I S

, r a n g ing from $500 to $700 n ot including
ins t a l l a t i on or F ederal E xcise T ax

. I nstall a t i on v a ri e s d e p e ndi n g on the s y stem a nd wh a t c a n be

p r e pp e d a h ea d of tim e

.

8.2.1.2.4 General Technology

Timpte raised a concern regarding the acceptance of the additional equipment by the end
user. Each of their trailers is built uniquely to the customer’s specification and they are reluctant to
allow Timpte to add anything to the trailer that they didn’t specify. Timpte has this same issue with any aspect of the trailer that is required by statute.

Timpte also commented that a ny significant change in the weight or cost of the trailer will cause a dramatic reduction in sales for a several year period of time as customers will defer purchasing the units with the additional aerodynamic devices as long as they can. They would more readily accept the increased cost than the increased weight.

25Timpte stated that d epending on what the requirements end up being, they would have to try and hire additional employees to handle the installation of the additional componentry, which is difficult to do in the small, rural community in which they are located. In addition, depending on the requirements, they would most likely have to invest in enlarging their facility to allow space for the
installation of the additional devices.

Timpte would hope to be able to acquire technologies from vendors. As they are used to haul
bulk commodities

– weight and strength are the t wo most important features of thei r trailers. They

are built primarily of aluminum. Thei r most popular models

– the 40’ and 42’ overall lengt h units

– weigh only about 9000 pounds . Customers have the ability

– and do

– to buy options to reduce the weight such as aluminum wheels, lightweight hub & drum and other aluminum structural components. That said, being bulk commodity trailers, they will always fill them to achieve the legal loaded limit but the lighter the trailer, the more commodity that they will move per trip and hence the lower the number of trips.

Diamatrix stated that t here will b e enginee r i n g, purchasi n g and m aterial handling costs associated with any device added to the trailers. Engineering will need to evalu a te options, cr e ate drawings a nd bills of m aterials, e nsure co m p lian c e of other co mponents (lights, etc.) and to avoid
int e rferences with other ite m s on the trailers. Purchasing will have to buy the additio n a l ite m s, receive the ite m s and process the invoices. Material handling will have these additional ite m s to

sto r e and deliver to the line. They m ay also be req u ired to hire shop per s onnel to install the aero
devices.

East Manufacturing stated that they would have to acquire technologies from vendors as they do not have the resources for a full R&D study. East anticipate s Product Liability law suits on dump
and refuse trailers due to ca using potential trailer rollovers and/or damage to equipment in landfills
and construction sites.

8.2.1.3 Potential Reporting, Recordkeeping and Compliance Burdens

Timpte commented that their units are highly configured. They sell primarily to farmers and
owner/o perators and they all have different opinions on what they want from an appearance and functionality standpoint. Timpte’s average order size is for 1.3 trailers. It would be impractical for us to try and certify their product on a basis that required act ual aerodynamic testing. The cost
would exceed their revenue.

East Manufacturing noted that t hese regulations would require East to add additional clerical staff, more Direct labor and additional Material Handing/indirect labor. Trailers serving n iche

ma rkets are too small in annual production to affect the overall output of GHG CO 2 emissions. Since averaging probably will not work for small entities some other method of leveling the playing field between large and small manufacturers should be developed.

Diamatrix ant ic ipates that they will ha ve unique legal, a d mi nis tr ative an d record
ke eping burden s a s a resul t o f c omplianc e sinc e they d o no t currentl y hav e an y suc h reporting. W hat spec ifi cally these will b e is un cl ea r at this t im e. Diamatrix is not qui t e su r e a t th i s t i me wh a t the i m p ac t would b e to their c o mpa n y or if they would n ee d to a dd e quip m e nt or

26sta f f. They d e finite l y will h a ve to s p e nd w h a t se e ms l i ke a si g nifi ca nt a mount of t i me with

c e rtifi ca t i ons a nd r e porti n g. I f th i s is the c a se a nd they will l i k e l y h a ve to a dd st a f f

.

Diamatrix will have increa s ed costs associated with engineering

, purchasing and
material handling at the pla n t le v el. They will also ha v e i n crea s ed co st s, either at the pla n t or a t the corporate level, for certific a tion and reporting. They could also have increased costs if they are

r equi r ed to do te s ting rath e r than using a pre

- approved aero device list.

Diamatrix commented that a erodyna m i c testing will be a huge expense, not only to s m all businesses, if they are required to do this. It would be beneficial if they could pick devices from

an app r oved m enu or list. If they are required to test and verify every device it would be a huge
burden on s m all business and m i ght put them out of business.

8.2.1.4 General Comments

8.2.1.4.1 Model Year

Timpte also commented i n reference to Certification Year, tying the certification to the model year is more difficult for trailer builders than was described for automobile manufacturers.

Model Year designation is all over the board. Each manufacturer can decide when to change year models within two years. In the past most manufacturers changed over in June or July of each year. Today most change over January 1 st of each year. This was driven by Fleet and customer requests. There is currently no government mandate regulating the timing of year model change for trailers. (Example: Today on January 1, 2015 most manufacturers will be building 2016 year model trailers). Conversely, there is nothing to keep manufacturers from pushing off t he change to a year model out one or even two years at this point. Thereby delaying the mandate to comply with these regulations.

Diamatrix noted that th eir m odel y ear changes, officially, on January 1. However, if they
have an or d er that starts in Dece m b er and will f i nish in Ja n uary, that e n ti r e or d er will b e of the new model year.

8.2.1.5 Suggested Flexibilities

Timpte commented that the f lexibilities that they believe that would be he lpful would
include:

• Alternatives to compliance that did not include the use of side skirts.

• Alternatives to compliance that did not require us to do actual aerodynamic testing as they could not afford that expense.

Timpte also stated that d ue to the low volume of construction of any given configuration of trailer, it is difficult for them to see how Averaging and Banking would benefit smaller manufacturers. It could easily put them at a disadvantage to larger trailer builders, especially th ose that might build a variety of different styles of trailers.

27East Manufacturing proposed the following flexibilities:

• Full or partial e xemption for their product types.

• Products spec’d with more than 4 axle s should be fully exempted from this program.

E ast Manufacturing stated that Averaging, Banking and Trading will most likely not be
available to East Mfg or other s mall b usiness manufacturers simply due to the small number of trailers built annually of each product type. This inability to use Averagin g, Banking and Trading will put small manufacturers at a market disadvantage compared to large business
manufacturers.

East would like to see the time extended for compliance for all small business manufacturers
so that they have more time to study the req uirements and they associated perceived benefits. Extending the start date for small business entities will allow us to evaluate technology and the
effects of the cost associated on their businesses.

Diamatrix proposed the following f lexibilities that co u l d r e duce s m all entity b u rden:

• Exe mpt s m all busi n esses co mpletely.

• Exe mpt s m a ll businesses for a period of ti m e.

• R e du c e the l e v e l of c om p l i a n c e f or small busin e s s e s.

• Allow manu fac tur e rs to pick ae ro d e vic e s f r om a p r e

- a ppro v e d l i st r a t h e r than h a ving to
test them s e lv e s. I t is un d e rstood that manu fac tu r e rs would te s t if th e y c ome up w i t h a
d e vi c e t h a t i s not on the a ppro ve d l i st.

Diamatrix also commented b ased on w hat they percei v e that EPA will p ropose, they do not

t h ink t h at additional lead time will be req u ired. That i s , if they are per m itt e d to pick f rom approved

ae r o devices a n d not to have to t e st t h ere sh o uld be no a d ditio n al l ead ti m e. They a l so think that they would be able to figure out the reporting and record keeping prior to the effective date.
W orkshops for reporting and certification would be greatly beneficial.

8.2.2 Alternative Fuel Engine Converters

The following comments from Alternative Fuel Small Entity Representatives were received:

• Power Solutions International

– November 19, 2014

• CNG One Source

– November 20, 2014

8.2.2.1 Number and Types of Entities Affected

Power Solutions International would l i ke t o rec om mend t hat th e es t ablish m ent o f a c om pan y ’s ability to use “small” business provisions of G H G stand a rds be b ased on one of two c r iteria. Currently, the establishment of “small business” is based on the business siz e stan d ards specified in
13 CFR 1 21. 2 0 1. They w o uld like E P A t o g i ve c o nsider a tion, in futu r e GHG rules, to also allo w the

es t ablis h men t of “s m all vol u me m an u facturer ” based on to t al n u m b er of units sold. Such allowances

28are provided in t he criteria section 40 CFR 86

. 0 9 4

‐ 1 4(b) ( 1) o n th e b asis of 10,000 or fewer units. This would allow companies to qualify to use “small business volume” provisions of the new rule by
either means.

8.2.2.2 Feasibility of Proposed Technologies

8.2.2.2.1 Engine Long Blocks

Power Solutions International stated that i mposi n g m ore stringen t GHG regu l atio n s on

sec o ndary man u fac t urers, especially those t h at fi t into the category of small businesses

– which
most do

, makes it very difficult to a r c hitect b ase e ngi n e specif i c technol o g y

. The GHG reducing technologies all impact the design and construction of the long engine block assembly.
Small businesses / secondary eng in e ma n u f actur e rs hav e v ery little ability to influence the

conten t of t h e n ew lo n g e ngi n e bloc k eng i ne ass e mblies purc h ased fr o m a u tomot i ve companies. Small businesses/secondary engine manufacturers receive very little support from the long block engine manufacturers for challenges faced when developing and applying the long block engine assembly into new applications. The small business / secondary engine manufacturer will

nee d to i n vest i n d evelopi n g new/additi o nal in t ernal t echnol o g ical capabilit y to be abl e to

a c com m odat e more stri n g e nt standards.

Alternative fuel converters have l i m i t e d a bi l i t y to cont r ol fea tu r e s of b a se e n g ine a r c hi t ec t u re in t he inco m plete e n g i n e s that th e y c onv e r t , whi c h si g nifi ca nt l y r e du ce s t h e opt i ons for r e d u c ing

e m i ss i ons. I mpro v e ments c ould d e finite l y be ma d e on the b a s e e n g i n e s whi c h would be h e lpful for

a su p e rior n a tur a l g a s e n g i n e d e s i g n . Ho we v e r, it a pp e a rs th a t the O EM ca nnot j ust i f y the e x p e nse invo l v e d in making these c h a n g e s, a s th e y a re not n e ce ss a r y f o r running the e n g ines on d i e s e l fu e l.
Th e r e f o r e , s ec ond a r y m a nufa c tur e rs a nd a l t e rn a t i ve fu e l c onv e rt e rs a r e l i m i ted in t he a mount of

c h a n g e s that ca n be ma d e

. S mall enti t ies c ould comp l y with e m i ss i on st a nd a rds w i t hin a ra n g e o f
the ori g inal e n g i n e ’s e m i ss i ons. W h e n the indust r y i m pr o v e s, OEMs wi l l be more l i k e l y to

m a nufa c ture blocks th a t b e t t e r suppo r t natu r a l gas f u e l.

CNG One Source also commented that the N A S 2014 re port r e c om m e nd ed s e p a r a te C O 2
stand a rds f or n a tur a l g a s fu e led e n g i n e s. N A S did not r e c om m e nd n e w re qui r e ments for e n g ines
th a t use ot h e r a l t e rn a t i ve f u e ls. This l i m i t a t i on is unn ec e ssa r y a nd un f a ir l y ta r g e ts the n a tur a l g a s indust r y

. I n f a c t, h a ving s e p a r a te stand a rds is punit i ve to t he n a tur a l g a s indust r y , a nd w h y ? I t w a s ju s t i n M a rc h 2013 that the N AS s t a ted in t h e ir re port, “ T r a nsi t ions t o Alte r n a t i ve V e hic l e s a nd
F u e l s ” , that the ‘ C N GV e mphasis s ce n a rio ’

, i s the o n ly s ce n a rio w hich ac hiev e s 5 0 % r e d u c t i on in

p e trol e um use b y 2030. Unn ece s s a r y l i m i tations a re g oi n g to k i ll the n a tu r a l gas indus tr y b e fo r e it

e v e n h a s a c h a n c e to b e c ome w ide l y a dopted. At th i s t i me, th e re is no sound r ea son to i m plem e nt d i f fe r e nt s t a n d a rds f or n a tur a l g a s e n g ines. Th e s e l i m i tations a re b a rr ie r s a nd will c omp l e t e l y st i fle

a n a lr ea d y str u g g l i n g indust r y a t a ti m e wh e n the t ec hnol o g y a nd ma r k e t a dopt i on n ee d to g ro w

.

8.2.2.2.2 Engine Calibration

CNG One Source stated that EPA b e l i e v e s mo s t of the G H G stand a rds ca n be met wi t h

prop e r tuni n g of f u e l and e m i ss i on c ontrol s y stems r e quiri n g the c ost of so m e a ddi t ional

29e n g i n ee ri n g t i me. “ T he c ost of some a ddi t i o n a l e n g ine e ri n g t i me” is l i k e l y hund re ds o f thous a nds
of dol l a rs w h e n y ou c onsid e r a ll of the p ropos e d c h a n g e s in s t a nd a rds. I n c re a sing r e strictions on

e m i ss i ons ca n c ompromise the int e g ri t y a nd longevi t y of the e n g ine. D u r a bi l i t y of the e n g ine
should be b a lan ce d with emissions stand a rds.

8.2.2.2.3 On Board Diagnostics (OBD) Requirements

CNG One Source commented that the P h a se 2 pr o pos a l m a y in c lude a ddi t ional

re quir e ments f or n a tur a l g a s

- fu e led e n g in e s to c ontrol m e thane e m i ss i o ns and O B D r e quir e m e nts for C NG a nd L NG meth a n e le a ks. Methane le a ks a re p r e s e nt l y not known to be si g nifi c a nt a s f a r a s

e m i ss i ons a re c on ce r n e d. A g a in, t his r e quir e ment is puni t ive to the n a tur a l g a s indust r y . Cur re nt l y the most c o m mon c a use of meth a ne le a k a g e is a f a u lt y pr e ss u re re g ulato r

. W h e n the re gulator f a i l s, the e n g i n e c e a s e s to op e r a te, e v e n if in mo t ion on t he hi g hw a y

. W hi l e th i s is a hu g e s a f e t y c on c e rn,

a s i s a s the fl a m m a bi l i t y c on c e rn, it is not pr e s e nt l y a si g nifi ca nt e n v iro n m en t a l c on ce rn. M e thane

g a s c omposi t ion va r ies g re a t l y d e p e ndi n g on w e ll g a s, l a ndfill g a s, a nd ut i l i t y g r a de g a s. E v e n

u t i l i t y g a s c h a n g e s in compos i t i on du r ing the winter mon t hs. Kno w ing th i s, how w i l l t he d a ta be

ac qui r e d for O B D? V e hicl e s runni n g on low qu a l i t y CNG (lo w e r p e r ce nt a ge of C H 4 ) will not be
d e te c ted a s r ea di l y a s v e hicl e s runni n g on h i g h qu a l i t y meth a n e (hi g h e r p e r ce nt a ge of C H 4 ).
F urth e r, if v e hicl e s run on low e r q u a l i t y g a s, the e n g i n e c omponents will b e d e te r io r a te much mo r e quick l y . H o w e v e r, to a void M I L l i g ht and O B D issu e s with t he EPA, op e r a tors c ould a nd wou l d

e x plo i t t h is s y stem. D e te c t i on of metha n e le a k a ge b y me a suri n g me r c a pt a n/o d or a nt is f a ul t y b eca us e :

1. I t does n ’t e x ist for L N G a s it tr a nsi t ions f r om l iqu i d to g a s. 2. Not a ll fu e l s t a t i ons use me rca ptan/od o r a n t

, e v e n thou g h it is r e quir e d b y N F P A

The e n g ine m a n u f a c tu r e r or c onv e r t e r m i g ht a c hie v e d e si r e d EPA st a nd a rds f o r ce rtifi c a t i on. Ho we v e r, unt i l t he qu a l i t y stand a rd is bui l t for CNG r e fu e l i n g station s , the O EM or AFC will

c ont i nue to foot the bi l l t o theo re t i ca l l y c omp l y during testi n g but wi l l n o t in r ea l l ife a ppl i ca t i ons.

8.2.2.2.4 N 2 O Emission Standards

CNG One Source commented that N 2 O m ea sur e ment m a y r e quire a ddi t ional e quip m e nt i n some test f ac i l i t ies. EPA is c onsid e ri n g the option of a l l owing A F Cs to use “e n g ine e ring a n a l y si s ”
to d e monstr a te th a t t he b a s e e n g i n e did not e x cee d the N 2 O ca p a nd their c onv e rsion pro c e ss would

not i m p a c t N 2 O.

CNG One Source stated that EPA b e l i e v e s N 2 O me a sur e ment d e vic e s c a n be pur c h a s e d, if

n e c e ssa r y , f or ~$100,000. Th e se pri c e s will e i t h e r b e incu rr e d b y small busin e ss or p a ssed a lo n g to

s m a ll busin e ss. I s th i s n e ce ssa r y for A F C or s ec ond a r y manu fac tu r e rs? How much w i l l f ac i l i t ies

c h a r g e to t a k e N 2 O me a sur e ments? Ev e n ce r t i fi ca t i on c ompani e s c on t r a c t wi t h a th i rd p a rti e s for
testi n g

. W i l l t h e re be a b a c klog with t he number of e n g ine manu fac tu r e rs h a vi n g to use a l i m i ted
numb e r of f a c i l i t ies? An e n g ine e ri n g a n a l y sis would be a ppro p ri a te, a l t hou g h th i s will a dd

e n g i n ee ri n g e x p e ns e s a s w e l l

.

308.2.2.2.5 CH 4 Leak Reduction

CNG One Source commented that EPA is c onsid e ring mo r e strin g e nt C O 2 e m i ss i on stand a rds, in c lud i ng CH 4 a nd N 2 O ca ps for a ll e n g i n e t y p e s. A cc ordi n g to t he EPA ’ s Inv e nto r y of
U

. S . G ree nhou s e G a s Em i ss i ons a nd S inks: 1990

– 20 1 2 publ i sh e d Ap r il 15, 2014, m e thane

e m i ss i ons a re not known to be s i g nifi c a nt i n the t ra nsport a t i on s ec t o r. More stringent st a nd a rds a re
not n ece ss a r y for n a tur a l g a s e n g i n e s.

CNG One Source also commented that the P h a se 2 st a nd a rds h a v e n ot be e n s e t y e t. C H 4

m a y be mo r e c h a l l e n g i n g for n a tur a l g a s e n g i n e s. I mprop e r f u e l i n g c a n r e sult in h i g h lev e ls of

u n burn e d C H 4 e m i ss i ons. Conv e rt e d C I (di e s e l) e n g ines would n ee d to e nsure the c r a n k ca se is

c l os e d with a suit a ble v e nt i lation s y stem installed to r e d u c e bl o w

- b y CH 4 e m i ss i ons. C H 4 stand a rds should not be more r e strictive. There is no c le a r e vi d e n c e to s u pport that mobile m e thane

use f r om natu r a l gas v e h i c les si g nifi c a nt l y a f f

ec ts C H 4 e m i ss i ons. I mpro p e r f u e l i ng should not i mpa c t t he e n g ine ’ s e m i ss i ons. F urth e r r e strictions on m e thane e m i ss i ons a re un w a r r a nted.

CNG One Source stated that i f the b a se e n g ine f o r c onv e rsion is a C I e n g ine with a n op e n

c r a nk c a s e , they e s t i mate a c losed c r a nk c a se v e nt i l a t i on s y stem to c ost ~$500. This desi g n will

a f

f

ec t e n g ine du r a bi l i t y a s t h e b y prod u c ts of the n a tu r a l g a s s y stem will det e rio r a te the e n g ine

c om p on e nts. F or e x a mp l e , H 2 S c omb i n e d with C O 2 will c r e a t e fissur e s in t he st e e l. M e thane

e m i ss i ons o cc u rring in a c losed s y stem would l i k e l y c r ea te a n u n s a fe a nd po t e nt i a l l y h a z a rdous
situ a t i on. Allow op e n c r a nk ca s e f o r t w o r e a sons: (1) M e thane e m i ss i ons a re n o t known to be
si g nifi c a nt i n n a tur a l g a s v e hicl e s. (2) M a in t a in vehi c le s a f e t y b y e l i m i n a t i ng potential l y h a z a rdous

c losed “ v e nt i lation” s y st e m.

8.2.2.3 Potential Reporting, Recordkeeping and Compliance Burdens

CNG One Source commented that s mall bus i n e sses a re dispropo r t i on a te l y b u rden e d b y

ce rtifi c a t i on e x p e ns e s c o mpa re d to l a rge busin e sses a nd h a ve f e w f undi n g oppo r tun i t ie s for r e s e a r c h

a nd d e v e lop m e n t. S mall bus i n e sses must u s e a h i g h e r p e rc e nt a g e o f their budg e t for r e s e a r c h a nd
d e v e lop m e nt and c o s ts a ssoci a ted w i t h c e rtifi ca t i on. CNG One Source stated that t he g ov e rnm e nt h a s sp ec ifi ca l l y to l d them th a t t h e y h a ve no in t e r e st i n funding small busin e sses invo l v e d with

en g ine d e v e lop m e nt. Th e r e fo r e , the bu r d e n is entir e l y on the e n g ine m a nu f ac tu r e r. L ar g e r

c ompani e s with g r ea t e r re sou r ce s not on l y sp e nd a small e r sh a re o n r e s e a r c h a nd d e v e lop m e n t, t h e y

a re a lso ca ndidat e s for f e d e r a l fundi n g . This e x c ludes small busines s e s f r om r ea l i st i ca l l y c ompe t ing
in t he ma r k e tp l ace

. I f re g ulations bur d e n sm a ll busin e sses, EPA should id e nt if y a nd provide

r e al i st i c r e sou r c e s to assist s mall busin e sses ac hie v e c e rtifi ca t i on. The EPA c ould provide

p e rsonn e l t o a ss i st s mall enti t ies in the ce rtifi c a t i on pro c e ss r a ther than r e dir e c t the sm a ll e nt i t i e s to

cost l y th i rd p a r t y c ompan i e s

.
CNG One Source commented regarding their c on ce rn o ve r l ac k of e nfo r c e ment a g a inst

c ompani e s that do not c e rti f y their c onv e rt e d e n g ines. The majo r i t y o f n a tu r a l gas v e hicl e s in t he
United S tat e s a re not E P A c om p l i a nt. The EPA h a s not provid e d a d e q u a te e n fo r c e ment, a nd the r e is no re a l inc e nt i ve for c ompani e s t o c omp l y with E P A re g ulations. B y c hoosi n g to r e g is te r w i t h
the E P A a nd f o l l ow a ll re g ulatio n s, C NG One S our c e is at a hu g e dis a dv a nt a g e

. Their c ompa n y will b ea r the burd e n of e x p e nse on the r e s e a r c h a nd d e v e lop me nt, ce rtifi c a t i on, a nd use of t i m e a nd

r e sou r ce s to s a t i s f y the g o v e rnm e nt. I n r ea l l ife a ppl i ca t i ons, c onsum e rs a nd tru c ki n g c ompani e s

31a re findi n g w a y s to con v e rt their v e hicl e s t o run a n a t ur a l gas b e ca use o f the f u e l c ost s a vin g s. T h e y l i te r a l l y w e i g h out t he risk a nd c ost of f ines f rom the E P A w i t h the p r ice of E P A c omp l iant e n g i n e s. CNG One Source has fi e lded s u c h phone ca l ls

, a nd un f o rtun a te l y , c ontr a r y to their

r e c om m e nd a t i o n s, the tr u c king c ompani e s ul t i m a te l y opted to pu rc h a se no n

- EPA c omp l iant

e n g i n e s

. I n a ddi t io n , CNG One Source h a s vis i ted w i t h c ompani e s who h a v e mod i fi e d the E P A

ce rtif i e d e n g i n e s to i mprove p e r f o rm a n ce

. S ome of t h e se c ompani e s h a ve e v e n ho l low e d out t he

ca ta l y t i c c onv e rt e r a s w e ll a s m a king other dr a matic mod i fi ca t i ons. Th e re is a lr ea d y a v e r y h i g h
lev e l o f no n

- c omp l ian ce , a nd the more stringent the re g ulations and the more e x p e nsive the e n g i n e s (not i ng that the pr i ce s of d e v e lop m e nt, i mprov e d c omponents, a nd c e rt i fi c a t i on will be p a ssed on to
the c onsum e r ) , the gre a t e r the d e g r e e of n o n

- c omp l ian ce . The on l y w a y to ch a n ge b e h a viors a nd

c r e a t e c omp l ian c e is t o pr o vide a d e q u a te e nfo r c e ment. On the sta t e lev e l, t h e r e h a ve b e e n discussions th a t en f o r ce m e nt will discour a ge the indu s t r y , whi c h s ee ms t o ind i ca te th a t t h e re is no
d e sire a n y w h e r e to provide e n f or c e ment. I f the r e is no re a l en f o r ce m e nt, wh a t i s the inc e nt i ve to

comp l y ? Col l ec t i ng fin e s f rom e n f or c e ment c ould provide r e v e nue to t he E P A to a ss i st small

ent i t i e s in a c hieving c e rtifi c a t i on.

CNG One Source commented that c onv e rt e rs w i l l ne e d to c e rti f y their e n g ine a nd a lso wo r k
with the v e hicle manu f ac tu r e r to e nsure their n e w v e hic l e me e ts the G HG stand a rds w i t h the

a l t e rn a t i ve f u e l e n g ine. W i l l se c ond a r y man u f a c t ur e rs a nd a l t e rn a t i ve fu e l c onv e rt e rs be r e q u ired to

wo r k with t he v e hicle manu fac tu r e r? This cou l d be a c umb e rsome pr oce ss for some small
busin e ss e s. I n a ddi t ion, wh e n the indust r y g ro w s a nd CNG e n g i n e s b ec ome c ompeti t ive in the

m a rket, OEM ’ s ca n e l i m i n a te t he small bu s iness “ p a rtn e r

. ” CNG One Source recommends EPA

a llow e n g i n e s to be c e rtifi e d indep e nd e nt l y so th a t t h e y c a n be us e d in dif fe r e nt v e hicl e s a nd

a p pl i ca t i ons.

CNG One Source commented that e n g ine m a n u fa c tur e rs m a y b e r e quir e d to provide e n g i n e fu e l map d a ta to v e hicle manu fac tu r e rs a s i n puts f or EPA ’ s v e hicle c e rtifi ca t i on model. W h a t data
will be tr ea ted a s C B I ? Could t his r e quir e ment e n c ou ra g e O EMs a nd v e hicle manu fac tu r e rs to take

t h e c onv e rsion p r o ce ss i n house a nd e x c lude the s mall bus i n e sse s ? CNG One S our c e would l i ke
info r mation on the p r o ce ss of b ec om i ng EPA c e rtifi e d to t a ke su c h me a su r e me n ts.

CNG One Source also stated that a ddit i on a l i n c r e ment a l i n c r e a s e in costs asso c iat e d with

t his prop o s e d rul e maki n g c o u ld include a t t orn e y f ee s to in t e rp re t r e g u l a t i ons, ac c ountant f e e s to

m a n a ge s a le a nd c omp l ian c e f i g u r e s, a dm i nis t r a t i ve sta f f f or re c ord k ee pi n g . Most c ompani e s in

t he a l t e rn a t i ve f u e ls i ndust r y a re strug g l i n g to m a ke a p ro f it a s it is st i ll a small nic h e ma r k e t. Ma n y

c om p a ni e s h a ve g one out of busin e ss or th e ir stocks a r e f a i l i n g. The a ddi t ional inc re ment a l costs
wi l l e x ce ss i v e l y bur de n the s m a ll busin e sses w ho a r e the o n e s wil l ing to comp l y with the E P A ’ s

r e g ulations a n d in t urn su f f

e r the di r ec t, ind i r e c t and indu ce d c os t s o f m ee t i ng a nd man a g i ng these stringent r e g ulatio n s.

8.2.2.4 Suggested Flexibilities

Power Solutions International commented that t he small business/secondary engine manufacturer will require additional time, beyond that required by a large entity, to adopt more stringent standards. Additionally, PSI w o uld be oppo s ed to mor e stringen t G H G regulat i ons for NG
f u eled eng i nes for t he fol lowing reasons:

32• As a s mall b usiness, they a re going to b e re q uired t o use A B T cr e dits to bri n g some of
their engine families i nto GHG compliance. Specifically, some of their gasoline eng i ne models will require c r edits to bring C O 2 into compliance. Wit h t he 6 2 7 g/hp

‐ hr standard,

t h ere are a go od am o unt of credits that c an be gener a ted fr o m their NG fueled e n g i n e families. These credits will help Power Solutions International bring othe r families i nto compliance. More stringent GHG standards for N G f u eled e ngi n es would i m pede their ability to bank credits.

• Further stringency on GHG standards for NG fuel may not incentivize vehicle manufacturers to adopt NG engine models for their products.

Power Solutions International also stated that t h e establishmen t o f a “ t echnol o gy” c redit to be applied to en g ine based G H G certification for us e o f s u ch technol og ies as S t art/Stop or o t h e r similar
h yb ridization. Currently, there is no ability fo r a n “e n gin e MOR” to r e a l ize an adv an tage f or suc h
techno l ogy based o n t esting over t h e e n g i ne dy na mo m eter b ased t r ansien t F T P cycle. An

es t a blishment o f a tec h nology credit based on t h e use of such t e chnology w ould i ncentiv i ze i mple m en t ation o f suc h technol o g y b y h e a v y dut y e n gin e c ompanies. It is recogn i zed t hat s o me

m e thod of establishi n g the l e vel o f a credit wou l d need t o b e d eveloped. There a r e many reports of hybridization based fuel effic i e n cy im prove m ents in th e h e av y duty vo c ational market s that cover a wide band of fuel effic i ency improvements. The type o f hybridization and duty c ycle use o f t h e

ve hicle ar e bo t h contribu to rs to th e m agnitude o f t h e f u el e conom y i m pro v em e nt.

CNG One Source commented above that f urth e r r e strictions on m e thane e missions a re

un w a rr a nted. They also suggested above that EPA c ould provide p e rsonn e l to a ssist small entities in
the ce rtific a tion pro c e ss r a ther than r e dire c t the sm a ll e ntiti e s to cost l y third p a r t y c ompan i e s

. CNG
One Source also recommends above that EPA a llow e n g i n e s to be c ertifi e d indep e nd e nt l y so th a t they c a n be us e d in dif fe r e nt v e hicl e s a nd a p pli ca tions. CNG One Source suggested that a n

e n g ine e ri n g a n a l y sis would be a ppro p ri a te in lieu of measuring N2O emissions

, a lthou g h th i s will

a dd e n g i n ee ri n g e x p e ns e s a s w e ll.

CNG One Source stated that s mall bus i n e sses w i l l r e quire a ddi t ional t i me to invest i n

r e sour c e s r e qui r e d to ad o pt new stand a rds. S mall bus i n e sses w i l l have to have more ca pi t a l i n ord e r
to c omp l y with t he n e w r e g ulations. C h a n g e s in g ov e rn m e nt r e g ulatio n s is discou ra g i n g t o

c usto m e rs a nd investors. Allow a ddi t ional t i me ( one y e a r ) f or i m plem e ntation b y small entit i e s.

CNG One Source also stated that A B T a l l ows a manu f a c t u r e r to in t e rn a l l y a v e ra g e si m i l a r models ( b y e n g ine a r c hi t ec t ure or e n g ine si z e ), g e n e r a te c r e di t s for futu r e u s e if th e y ov e r

- c omp l y ,
a nd s e ll b a nk e d c r e di t s to o t h e r un der

- c omp l y i n g manu fac tu r e rs or b u y a n other manu fac tu r e r ’ s b a nk e d cr e di t s to cov e r th e ir o w n d e fi c i t s. Althou g h th i s s y stem th e or e t i ca l l y ca n b e n e f i t s m a ll

e nt i t i e s, the s y stem h e a vi l y f a v o rs l a r ge c orpo ra t i ons. Most of t h e se pro p os e d re g ulations s e rious l y f

a vor l ar g e c o rpor a t i ons a nd a r e d a ng e rous l y c lose to c re a t i ng a monopo l y in t he indust r y

. S mall
enti t ies a re l i k e l y t o sp ec i a l iz e in l i m i ted t y p e s of e n g ines on l y

.

8.2.3 Vocational Chassis Manufacturers

The following comments from a Vocational Chassis Manufacturer Small Entity Representative were received summarizing comments made during the teleconference:

33• Indiana Phoenix

– November 19, 2014

8.2.3.1 Feasibility of Proposed Technologies

8.2.3.1.1 LRR Tires

Indiana Phoenix stated that all of the trucks they build are 6X6 configuration with up to two tag axles and two pusher axles. The majority of the trucks they build use wide based single tires on the rear drive axles and all use super single on the steer a xle. Most of their customers use a cog type traction tire since they spend a lot of time on construction sites.

8.2.3.1.2 Engine Improvements

Indiana Phoenix commented that their customers deliver usually within 25 miles of the batch plant due to the cure time of t he concrete. The drum must be turning anytime there is concrete in it. Hydraulic pumps are either on

- engine or FEPTO (power take

- off) driven and the only power used through the transmission is to move the truck. The on

- engine hydraulic pump is commonly used for both power steering and discharge chute control.

8.2.3.1.3 Weight Reduction

Indiana Phoenix commented that weight reduction as a means of achieving compliance is ineffective since their customers are payload driven.

8.2.3.1.4 A/C Leakage

Indiana Phoenix commented tha t the take rate on the air conditioning option is about 10%
and it is assembled in

- house. Since these vehicles are front cab, rear engine configuration the refrigerant lines are approximately 20 feet long. Indianan Phoenix has not evaluated their A / C syst em for compliance to SAE J2727.

8.2.3.1.5 Other Technologies

The SERs did not provide written comments regarding idle reduction, transmission improvements, axle improvements, or hybrids. However, some of their verbal comments are noted in the summary of the meeting s described in Section 6.

8.2.4 Potential Reporting, Recordkeeping and Compliance Burdens

Indiana Phoenix did not provide any comments related to compliance burdens.

8.2.5 Suggested Flexibilities

Indiana Phoenix did not provide any suggestions for flexibilities.

34

### 9 PANEL FINDINGS AND D ISCUSSION

9.1 Number and Types of Entities Affected

EPA identified 115 trailer manufacturers and 100 of them are small. Currently 24 vocational chassis manufacturers have registered with EPA under the Phase 1 rulemaking and three have
conf irmed small entity status to obtain an exemption for MY 2014. Twenty alternative fuel engine converters are currently registered with EPA to certify their converted HD engines for criteria pollutants. Eighteen of those engine converters are small. EPA i s aware of four glider manufacturers and three of these companies are small businesses.



### 9.2 General Potential Reporting, Recordkeeping and Compliance Burdens

For any emission control program, EPA must have assurances that the regulated products
will meet the standards. The program that EPA is considering for manufacturers subject to this proposal will include testing, reporting, and recordkeeping requirements. Testing requirements for these manufacturers could include use of EPA’s Greenhouse gas Emissions Mod el (GEM) vehicle
simulation tool to obtain the overall CO 2 emissions rate for certification of vocational chassis and trailers, aerodynamic testing to obtain aerodynamic inputs to GEM for some trailer manufacturers and engine dynamometer testing for altern ative fuel engine converters to ensure their conversions meet the proposed CO 2 , CH 4 and N 2 O engine standards. Reporting requirements would likely include emissions test data or model inputs and results, technical data related to the vehicles, and
end

- of

- year sales information. Manufacturers would have to keep records of this information for eight years.



### 9.3 Trailers

9.3.1 Feasibility of Proposed Technologies

9.3.1.1 Aerodynamic Devices

Diamatrix/Strick, the box trailer manufacturer SER , has some experience installing side skirts. However, many of their box trailers have unique physical features that limit the use of aerodynamic devices that cover the underside of the trailer. Th is company does not have experience with rear fairings or boat tail aerodynamic devices.

None of the non

- box trailer manufacturers had experience with aerodynamic technologies and cited several common use patterns for their specific trailer types that would damage or eliminate
the benefit of these devices.

9.3.1.2 LRR Tires

Most SERs have some experien ce with lower rolling resistance ( LRR ) tires, though they expressed concern that they have not been able to obtain LRR data from the tire manufacturers.

35Several SERs indicated that there were limited LRR tires available for their non

- box trailers at this time, since most tire manufacturers are focusing on developing lower rolling resistance tires for long

- haul box trailers where operators will see the greatest benefit. Other manufacturers, whose
trailers are used in off

- road or he avy

- haul applications, were concerned about the performance and durability of LRR tires, since so few are currently being use d in conditions that have heavy loads, high scrubbing potential, or the need for additional traction.

One SER also expressed conc ern that if it w ould be required to install LRR tires or tire inflation systems on all of their trailers, it would not be able to purchase them competitively compared to their larger counterparts, which the SER said would put the company at a competitive
d isadvantage.

9.3.1.3 Automatic Tire Inflation ( ATI ) Systems

Most trailer SERs have experience installing ATI systems on some of their trailers, but ATI systems are not installed as a standard feature on any of the SERs’ current products. The non

- box
trailer ma nufacturers have installed tire inflation systems on some trailers, but indicate that the customers are reluctant to purchase the systems because of the added cost. In addition, the manufacturers noted that inflation systems are often tied to a particular suspension system and they cannot be applied universally.

9.3.2 Potential Reporting, Recordkeeping and Compliance Burdens

Trailer manufacturers are currently not regulated by EPA and do not have experience with recordkeeping, reporting, or compliance. EPA is p roposing that trailer manufacturers certify their trailers using EPA’s Greenhouse gas Emissions Model (GEM) vehicle simulation tool to obtain the
overall CO 2 emissions rate . Some manufacturers would need aerodynamic inputs to run GEM

, which could be obtai ned through aerodynamic testing

. EPA is proposing a voluntary vendor

- based testing program in which aerodynamic technology manufacturers could perform the required testing and have their technologies pre

- approved with EPA for trailer manufacturers to use

. This is similar to how many technology vendors have been verified by the existing voluntary EPA SmartWay Program. Reporting requirements for trailer manufacturers would likely include emissions test data (model inputs and results), technical data relate d to the trailers, and end

- of

- year sales information. Manufacturers would have to keep records of this information for eight years.

Two SERs stated that emissions averaging, banking and trading ( ABT ) would be difficult since their companies have very specific product lines and relatively low sales volumes. Larger manufacturers, who have greater diversity of products and much higher sales

, would have a significant advantage in averaging and banking.

The SERs have emphasized that their industry is highly custom

- order and most trailers are designed to specifications identified by the customer. One SER noted that it is difficult to add anything to the trailer that his customer did not specify, includin g components “required by statute”.
He is concerned that some customers would simply refuse to buy from them or would defer sales as long as possible to avoid the requirements.

36Additionally, all of the SERs expressed concern over the prospect of require ments to perform aerodynamic testing on their trailers. The cost and resources required for a single test would be a significant burden and requirements to do annual testing of multiple trailers could add enough cost to
end their business.

Finally, all trailer manufacturers noted that they expect to need to hire additional staff to be able to comply with any new requirements, including administrative staff to help with recordkeeping and reporting, as well as technical staff to evaluate and install new te chnologies. One SER also
indicated that their physical facilities would require significant changes to the storage capacity and possibly the installation process, to accommodate the new devices and installation stages.

9.3.3 Suggested Flexibilities

Comments fr om trailer manufacturer SERs indicate that these companies are familiar w i th most of the technologies described in the materials, but have no experience with EPA certification and do not anticipate they could manage the accounting and reporting requirement s without additional staff and extensive training. Performance testing, which is a common requirement for many of EPA’s regulatory programs, is largely unfamiliar to these small business manufacturers and the SERs believe the cost of testing would be a si gnificant burden on their companies

. In light of this feedback, the Panel recommends a combination of streamlined compliance , which minimizes tracking and testing requirements, and targeted exemptions for these small businesses. The Panel
believes these strategies will achieve many of the benefits for the environment by driving adoption
of CO 2

- reducing technologies, while significantly reducing the burden that these new regulations
would introduce on small businesses.

9.3.3.1 Box Trailers

Box trailer manufacturer s have the benefit of relying on the aerodynamic technology development initiated through EPA’s voluntary SmartWay program. The Panel is aware that EPA is planning to propose a simplified compliance program for all manufacturers, in which aerodynamic
devi ce manufacturers have the opportunity to test and register their devices with EPA as technologies that can be used by trailer manufacturers in their trailer certification. This pre

approv ed technology strategy is intended to provide all trailer manufactur es a means of complying with the standards without the burden of testing. At the time of this report, it is unclear if this strategy will be available indefinitely, or if it will be an interim flexibility to allow manufacturers to ease into a testing

- only compliance program. In the event that this strategy is limited to the early years of the trailer program for all manufactures, the Panel recommends that small manufacturers continue to be given the option to use pre

- approved devices in lieu of testing.

In the event that small trailer manufacturers adopt pre

- approved aerodynamic technologies and the appropriate tire technologies for compliance, the Panel does not believe it is necessary to require the use of a vehicle emissions model

, such as GEM

, for certification. Instead, the Panel believes it could be possible for manufacturers to simply report to EPA that all of their trailers include approved technologies.

379.3.3.2 Non

- Box Trailers

The Panel recommends that EPA not require the installation of aerod ynamic devices for non

box trailers. Some of the non

- box trailer manufacturer s SER have seen prototype

- level
demonstrations of aerodynamic devices on non

- box trailers

. However, most non

- box trailer SERs identified unique operations in which their trailer s are used that preclude the use of those technologies and many that they have seen used on box trailers today

.

Some non

- box trailer manufacturers have experience with LRR tires and ATI systems. However, the non

- box trailer manufacturer SERs indicated t hat LRR tires are not currently available for some of their trailer types. The SERs noted that t ire manufacturers are currently focused on box trailer applications and there are only a few LRR tire models that meet the needs of their customers.
The Panel believes EPA should ensure appropriate availability of these tires in order for it to be deemed a feasible means of achieving these standards and recommends a streamlined compliance process based on the availability of technologies. The Panel suggests th at the best compliance option from a small business perspective would be for EPA to pre

- approve tires once they are available in sufficient quantities on the market , similar to th e approach being propos ed for aerodynamic technologies , and to maintain a lis t that could be used to exempt small businesses when
no suitable tires are available . However, the Panel recognizes the difficulties of maintaining a n up

to

- date list of certified technologies

. T he Panel recommends that , if EPA does not adopt the list

ba sed approach, the agency consider a simplified letter

- based compliance option that allows manufacturers to petition EPA for an exemption if they are unable to identify tires that meet the LRR performance requirements on a trailer family basis

.

9.3.3.3 Trailers with Unique Use Patterns

The Panel recommends excluding all trailers that spend a significant amount of time in off

road applications. These trailers may not spend much time at highway speeds and aerodynamic
device s may interfere with the vehicle’s intended purpose . Additionally, tires with lower rolling resistance may not provide the type of traction needed in off

- road applications

.

9.3.3.4 General Flexibilities for All Small Trailer Manufacturers

The Panel recognizes that some manufacturers, who have diverse product lines and high sales volumes, may benefit from an emissions averaging, banking and trading ( ABT ) strategy. However,
due to the custom

- order nature of the trailer industry, SERs have expressed their concern tha t ABT

may provide an opportunity for historically loyal customers or customers with large fractions of a manufacturer’s business to bargain for the portion of a manufacturer’s sales that have minimal requirements. Based on the low volume of sales and nich e market of many small business trailer manufacturers, small businesses in particular may have little leverage in this situation and risk losing their customers to larger manufacturers who have credits to spare. In addition, the accounting and reporting b urdens of ABT may preclude small businesses from participating in the flexibility.

Due to the potential for reducing a small business’s competitiveness compared to the larger manufacturers, as well as the ABT record

- keeping burden, the Panel recommends E PA consider

38small business flexibilities to allow small entities to opt out of ABT without placing themselves at a competitive disadvantage to larger firms that adopt ABT, such as a low volume exemption or requiring only LRR where appropriate. EPA should also consider flexibilities for small businesses that would ease and incentivize their participation in ABT, such as streamlin ing the tracking requirements for small businesses. In addition, the Panel recommends that EPA request comment on the feasibility and consequences of ABT for the trailer program and additional flexibilities that will promote small business participation. In addition, for all trailer types that will be included in the proposal, the Panel recommends a 1

- year delay in implementation f or small trailer manufacturers at the start of the proposed rulemaking to allow them additional lead time to make the proper staffing adjustments and process changes and possibly add new infrastructure to meet these requirements. In
the event that EPA is unable to provide pre

- approved technologies for manufacturers to choose for compliance, the Panel recommends that EPA provide small business trailer manufacturers a n additional 1

- year delay for each subsequent increase in stringency . This additional lead time will
allow these small businesses to research and market the technologies required by the new standards.



### 9.4 Alternative Fuel Engine Converters

9.4.1 Feasibility of Proposed Technologies

9.4.1.1 Engine Testing and Measurement

The feedback received from the Alternative Fuel Engine Converter (AFC) SER comments suggests that the testing procedures for CO 2 and CH 4 are relatively straightforward and the small businesses expect to be able to test and report those emissions to EPA. However, N 2 O measurement
is more challenging and requires a separate, costly measuring device. For the small converters who currently do testing in

- house, the expense of purchasing one of these instruments would be a significant burden. The other converters, who contract their test ing to outside facilities, believe
those facilities would have N 2 O measurement capabilities by the start of this propose rulemaking and the added expense of including N 2 O measurements is expected to be manageable. However, none of
the SERs believe the cha nges they are making to their engines significantly impact N 2 O production compared to the base engine and they support the use of engineering analysis to demonstrate compliance with N 2 O standards.

In addition, the SERs expressed concern that, if they are required to perform vehicle certification in addition to their own engine testing, they do not believe they will be able to obtain the necessary vehicle information , such as detailed information abo ut transmissions or computer
controls

. According to the SERs, the large OEMs that provide these vehicles have little incentive to provide any vehicle information to the small engine converters and these converters have no control over many of the vehicle characteristics.

9.4.1.2 Engine Calibration and Catalyst Tuning

The AFC SERs expressed concern about their ability to meet on

- board diagnostic (OBD) requirements, since they do not always have access to the diagnostic algorithms and calibrations of

39the base engi nes they convert from other manufacturers. Finally, N 2 O is not expected to be high for converted spark

- ignition (SI) engines, but can be a concern for converted compression

- ignition (CI) engines if the dosing of their aftertreatment devices is not properl y calibrated with the new fuel. Similar to OBD, these small engine converters often have very little information about the catalysts’ dosing and the calibration of the aftertreatment devices.

9.4.1.3 CH 4 Leak Reduction and More Stringent Standards for Natural G as Engines

Most of the engine converters believe their converted engines would be capable of meeting engine CO 2 standards that are more stringent than Phase 1. Engine converters who convert engines to run on natural gas do not support separate standards f or natural gas

- fueled engines citing the difficulties they already have in succeeding in the engine market.

9.4.1.4 Enforcement

One SER’s comments indicated that many small businesses are converting engines and not making the effort to comply with EPA’s regulati ons. This company believes they are at a competitive disadvantage with these companies who are converting engines with a focus on performance, but with little concern for durability or the effect on the environment. The SER suggested EPA provide incentiv es for compliance and increase enforcement to create a more level playing field.

9.4.2 Potential Reporting, Recordkeeping and Compliance Burdens

EPA expects that the recordkeeping, reporting, and compliance provisions of the proposed
rule for alternative fuel en gine converters will be similar to those in place today for heavy

- duty engine criteria pollutant requirements. SERs did not provide comments to suggest an increased burden due to recordkeeping and reporting to EPA, but noted that the option of conducting an engineering analysis for N 2 O in lieu of testing would reduce their burden.

9.4.3 Suggested Flexibilities

To reduce the compliance burden of small business engine converters who convert engines in previously

- certified complete vehicles , the Panel recommends allowing engine compliance to be
sufficient for certification. This would mean the converted vehicle would not need to be recertified
as a vehicle. This flexibility would e liminate the need for these small man ufacturers to gather all of
the additional c omponent

- level information in addition to the engine CO 2 performance necessary to properly certify a vehicle with GEM (e.g., transmission data, aerodynamic performance, tire rolling resistance, etc.) . In addition, the Panel recommends that small engine con verters be able to submit an engineering analysis, in lieu of measurement, to show that their converted engines do not increase
N 2 O emissions. Many of the small engine converters are converting SI

- engines, and the catalysts in these engines are not expecte d to substantially impact N 2 O production. Small engine converters that
convert CI

- engines could likely certify by ensuring that their controls require changes to the SCR dosing strategies.

40Based on the comments received from SERs, the Panel does not recom mend separate standards for small business natural gas engine manufacturer s. The Panel believes this would discourage entrance into this emerging market by adding unnecessary costs to a technology that has the potential to reduce CO 2 tailpipe emissions

. In addition, the Panel believes additional leakage requirements beyond a sealed crankcase for small business natural gas

- fueled CI engines and requirements to follow industry standards for leakage could be waived for small businesses with minimal impact on overall GHG emissions.

Finally, t he Panel recommends that small engine converters receive a one

- year delay in implementation for each increase in stringency throughout the proposed rule. This flexibility will provide small converters additional lead ti me to obtain the necessary equipment and perform calibration testing if needed.



### 9.5 Vocational Chassis Manufacturers

9.5.1 Feasibility of Proposed Technologies

The vocational chassis SERs who participated in the Panel produce specialized vehicles with use patterns that are not amenable to most of the GHG

- reducing technologies outlined in the
materials. SERs commented that LRR tires would be feasible if appropriate tires were available for their applications , though limited LRR tires are available at this time. Id le reduction technologies

may not be feasible since their products have operational requirements (i.e., turning a cement mixer or pumping water) when they are stopped. The transmissions and axles are also uniquely developed for performance in their very s pecialized applications and many of the improvements to these components for CO 2 reduction will not be appropriate for these applications. The SERs also suggested that h ybrid technologies may not be feasible for these use patterns.

9.5.2 Potential Reporting, Recordkeeping and Compliance Burdens

The Panel recognizes that many of the small vocational chassis manufacturers offer a narrow set of products that are very custom to a specific application and that they have very low sales
volumes. These manufacturers have limited ability to take advantage of an averaging credit program and have limited resources for recordkeeping and reporting.

9.5.3 Suggested Flexibilities

The Panel recommends interim reduced requirements for these small manufacturers with stringencies th at include technologies that fit the applications of these vehicles.

9.5.3.1 Emergency Vehicles

One of the vocational chassis SERs was a fire truck manufacturer. Fire trucks, and many other emergency vehicles, are built for high level of performance and reliability in severe

- duty applications. Some of the CO 2

- reducing technologies listed in the materials could compromise the

41fire truck’s ability to perform its duties and many of the other technologies simply provide no benefit
in real

- world emergency app lications. The Panel recommends proposing less stringent standards for emergency vehicle chassis manufactured by small businesses. The Panel believes it is feasible for
small manufacturers to install a Phase 2

- compliant engine, but recommends EPA request comment on whether the use of LLR tires will provide enough CO 2 benefits to justify requiring small business emergency chassis manufacturers to adopt them. In addition, the Panel recommends a simplified
certification approach for small manufacturers who make chassis for emergency vehicles that
reduces the number of inputs these manufacturers must obtain for GEM. Emergency vehicles make up less than one percent of the annual vocational vehicles sold, and the Panel anticipates these reduced requirements w ould have a minimal impact on the overall CO 2 reductions of the program.

9.5.3.2 Off

- Road Vocational Vehicles

EPA is planning to propose to continue the exemptions in Phase 1 for off

- road and low

- speed
vocational vehicles (s ee generally 76 FR 57175 ) . These provis ions currently apply for vehicles that are defined as “motor vehicles” per 40 CFR 85.1703, but may conduct most of their operations off

road. Vehicles qualifying under these provisions must comply with the applicable engine standard,
but would not need to comply with a vehicle

- level GHG standard

. The Panel believes this exemption is sufficient to cover the small business chassis manufacturers who design chassis for off

road vocational vehicles.

9.5.3.3 Custom Chassis Manufacturers

The second vocational SER manufac tures chassis for specialty operations and that SER has very small annual sales volume s . He provided a summary of his products that indicate his company
ha s a limited ability to adopt many of the technologies described in the materials. The Panel recommends proposing a low volume exemption based on the volume of sales . Similar to the recommendation for emergency vehicle chassis manufacturers, the Panel believ es it is feasible to require installation of a Phase 2

- compliant engine and recommends that EPA request comment on the benefits of LRR tires in this market segment . At this time, the P anel doesn’t have enough
information to recommend a sales volume , but r ecommends that EPA request comment on how to design a small business exemption by means of a volume exemption and what sales volume would be an appropriate threshold.

9.5.3.4 Glider Manufacturers

The Panel recognizes that EPA would like t o reduce the use of gli der kits , which have higher emissions of criteria pollutants like NOx than current engines, and which could have higher GHG emissions than Phase 2 engines . However, the Panel believes that the number of vehicles produced by these small businesses is too s mall to have a substantial impact on the total heavy

- duty inventory. The Panel also believes that there should be an allowance to produce some number of glider kits for legitimate purposes, such as for newer vehicles badly damaged in crashes. The Panel t herefore recommends proposing an explicit allowance for existing small businesses to continue assembling glider vehicles without having to comply with the GHG requirements. The Panel recommends that

42any other limitations on glider production be flexible e nough to allow sales levels as high as the peak
levels in the 2010

- 2012 time f rame

.

43

## Appendix A: List of Materials EPA shared with Small Entity Representatives

• Agenda for Pre

- panel meeting, June 19, 2014

• Power Point Presentation: “An Overview of the Small Business Advocacy Review Panel
Process, ” June 19, 2014

• Power Point Presentation: “Medium- and Heavy

- Duty Vehicle Greenhouse Gas Rule (Phase 2)

– SBAR Pre

- Panel Outreach Meeting, ” June 19, 2014

• Fact Sheet: “ EPA and NHTSA: Joint Rulemaking, Different Responsibilities ”

• “Outreach Document for Potentia l Small Entity Representatives: Heavy

- Duty Vehicle GHG Phase 2 Rulemaking (Phase 2), ” June 19 2014

• “Flexibility Concepts from Current and Previous EPA Regulations”

• ICCT Whitepaper: “Costs and Adoption Rates of Fuel-Saving Technologies for Trailers

in the North Americal On

- Road Freight Sector ”, February 2014

•

• Agenda for Panel Outreach meeting, February 20, 2014

• List of SERs

• Power Poin t Presentation: Small Business Advocacy Review Panel Process Recap, February 20, 2014

• Information from Farmers Branch, Texas on PCBs in light ballasts (included as written comment in Appendix B)

• Power Point Presentation: PCB Use Authorization Update Rule. Small Business Advocacy Review Panel Outreach Meeting, February 20, 2014

## Appendix B: Written Comments Submitted by Small Entity Representatives

T he U.S. Environmental Protection Agency (EPA) conducted a pre- panel outreach meeting with potential Small Entity Representatives (SERs) on June 19, 2014. EPA, along with Panel partners, Small Business Administration’s Office of Advocacy (SBA), and Office of Management and Budget’s Office of Information and Regulation Affairs (OMB), hosted one supplementa ry outreach conference ca ll for the trailer manufacturer SERs on October 28 th , 2014, and three separate Panel outreach meeting s with SERs from the three separate sectors on November 5 and 6, 2014.

A fter the June 19th pre

- panel outreach meeting, potential SERs s ubmitted five sets of written comments, which are provided in this appendix. The following people submitted the comments:

• Jan Hoover, Diamatrix

• Adam Jump, Indiana-Phoenix, Inc.

• Brad Schrock, E-One Inc. (later determined was not a small entity and therefore did not particip ate as a SER in the formal Panel outreach meetings)

• Karen Teslovich, CNG CNG One Source, Inc.

• Andy Suhy, Power Solutions International , Inc.

F or the October 28 th and November 5 th and 6th P anel outreach meeting s, the following six SERs submitted written comments, which are provided in this appendix:

• Jeff Thom pson, Timpte Inc. (submitted two sets, one before the 10/28 meeting and one after the 11/5 meeting)

• J an Hoover, Diamatrix (submitted two sets, one after the 10/28 meeting and one after the 11/5 meeting)

• David de Poincy, East Manufacturing Corp. (submitted two sets, one after the 10/28 meeting and one after the 11/5 meeting)

• Adam Jump, Indiana-Phoenix, Inc.

• Andy Suhy, Power Soluti ons International, Inc.

• Karen Teslovich, CNG One Source, Inc.B1: Written Comments from Potential Small Entity Representatives following 6/19/2014
Pre

- panel Outreach MeetingFrom: Jan Hoover

To: Wiggins, Lanelle Subject: RE: follow up from EPA"s Pre-panel Outreach Meeting

Date: Tuesday, July 01, 2014 12:00:08 PM

Attachments: image001.png image002.png image003.png image004.png 20140701 Written Response & Questions.pdf

Lanelle,

Attached is a pdf with some questions I have along with answers to the questions in the GHG SER

Outreach document. Some of the questions I cannot answer because, as a trailer manufacturer, I do

not fully understand what the process or requirements will be.

If you have any questions regarding my questions or answers please let me know.

Thank you,

Jan Hoover

Diamatrix

215-949-4790

From: Wiggins, Lanelle [mailto:Wiggins.Lanelle@epa.gov]
Sent: Monday, June 23, 2014 4:24 PM
To: Adam Jump; Andy Suhy; Bill Harp; Bradley Schrock; Fred Pearson; Jan Hoover; Jeff Simms; Josh Pietak; Karen Teslovich; Neil Johnson; Trey Gary Cc: Brakora, Jessica; Passavant, Glenn; Ranns, Nathan; Wysor, Tad; Rostker, David J.; Whiteman, Chad Subject: follow up from EPA's Pre-panel Outreach Meeting

Dear Potential Small Entity Representatives (SERs),

Thanks to those who participated in Thursday’s Pre-panel Outreach Meeting. My apologies once again for the technical difficulties we experienced at the beginning of the meeting.

As promised by EPA’s Glenn Passavant, the following link is for the National Research Council of the

National Academies report, “Reducing the Fuel Consumption and Greenhouse Gas Emissions of

Medium- and Heavy-Duty Vehicles, Phase Two: First Report” : http://www.nap.edu/catalog.php?
record_id=18736I am also resending OTAQ’s powerpoint presentation (see attached). At least one of you told me
that you could not open the most recent version that I sent to you on 7/18. The only difference

between it and the version you were sent on 6/4 is the title page (date and place).

Finally, just a reminder that you may submit optional written comments and/or questions over the

next two weeks to my email ( wiggins.lanelle@epa.gov ). Any comments/questions will be used to update the materials, and shape the discussion for the formal Panel Outreach meeting. Those
comments/questions are due COB Monday July 7 th

.

Please do not send me confidential business information (CBI). If you do have CBI that you would

like to share with EPA, please prepare and submit to me a redacted version with CBI removed and

indicate that you have a CBI version you would like to also submit. I will help you submit it directly

to an EPA/OTAQ staff person equipped to handle CBI.

At this time, we are hoping to hold the formal Panel Outreach meeting sometime in September.

Lanelle Bembenek Wiggins

RFA/SBREFA Team Leader US EPA - Office of Policy (1803A) - 1200 Penn Ave NW - Washington DC - 20460

202.566.2372

### To: Lanelle Wiggins ‐ EPA

From: Jan Hoover

– Diamatrix, 215

‐ 949

‐ 4790

Questions I have

 Reference slide 11 in presentation regarding the comment “....continue to rely on
computer simulation.....”. How and what does this mean to trailers and trailer

manufacturers? Is it GEM simulation?

 Would it be possible to see the GEM simulation run, even if not for a trailer? What is the

basis for the GEM simulation?

 Is the GEM simulatio n a certification tool? What is the process? Latter may be answered

with the question above.

 How would the items on slide 37 of the presentation affect trailer manufacturers? Or

what would be required of trailer manufacturers relating to the contents of this slide?

 I really do n’t understand the ABT Program. Would it be possible to receive an explanation of it and how that might affect trailer manufacturers?

 On the conference call one of the people at your location stated that it would be good

to have a separate call with the trailer manufacturers to explain mor e in detail the

current processes. Is that something that can be arranged?

Answers to question for all SER’s

1. Unsure at this time what the impact would be to our company or if we would need to
add equipment or staff.

2. Unsure at this time what flexibilities could reduce the burden on small entities.

3. I am not sure I can answer this question at this time as I do not fully understand what
will be requi red of us. One concern I have is that NTSB has recommended to NHTSA that they consider establishing a Side Underride regulation. I am not sure how a Side
Underride regulation and the GHG regulation will mesh with one another if both are instituted.

4. We build so me special trailers such drop frame dry freight van trailers and trailers with belly boxes that we may not be able to use existing technologies (side skirts) for
reduction of CO2. This could create an issue of compliance or increased burden on us. What they will be specifically, if an y, is unclear at this time.

5. I cannot answer this question at this time.

6. I am unsure if additional lead time would be necessary.7. At this time I cannot think of any sector

‐ unique business or competitive issues that you should understand.

8. Yes, I anticipate that we will have unique legal, administrative and record keeping
burdens as a result of compliance since we do not currently have any such reporting.
What specifically these will be is unclear at this time.

Answers to questions to trailer manufacturers

1. Yes, we have experience with side and rear fairings along with LRR tires. We have not

seen any benefits with the implementation of these technologies. One drawback is
where in our facility we can store and install fairings. In limited quantities it has not really been an issue, but if done on most or all of our production, it could require us to

creat e a location in which store and install these.

2. We possibly could experience a hardship in creating an area in which to install fairing in

our facility as mentioned above. Aside from that we will have increased labor, but assuming we can pass that on to our customers, I do not anticipat e any additional hardships.

3. See questions 1 and 2 regarding considerations that would need to be made.

4. I am unsure at this time what flexibilities would be helpful.

5. I would expect that we would both acquire technologies from vendors along with developing technologies in

‐ house.

6. We do not have any specific experience re garding a response to the California requirements and do not have many customers in the western part of the country. Most
of our customers and our major customers are located east of the Mississippi.**Questions for All SERs (**  **Indiana Phoenix Inc. Answers in red)**  1. How do you anticipate the potential regulations would affect your business? For example, would this require the purchase of any unique equipment or the hiring of additional staff? We would need to add additional staff and depending on the ruling, FEA software and updated computers.

2. What flexibilities do you believe may reduce small entity burden (or, can flexibilities be structured in a way to better provide assistance to small entitie s in reducing potential burdens)? Depending on the ruling, partial exemption, partial delayed compliance and/or less stringent compliance.

3. Do you anticipate any significant issues or circumstances not addressed in the materials provided? Will there be grant money available to help offset cost of compliance at any level?

4. If you serve a niche market or are located in a unique geographical location, do you anticipate any specific burdens and/or issues resulting from the potential rulemaking? Our niche market is Front Discharge Cement Mixers. A ruling including technologies such as aerodynamics or tire inflation system will likely be cumbersome for the end user or damaged as these vehicles are commonly in off road circumstances.

5. Do your answers to any of the above question differ depending on the start date or stringency level of the standards? Yes, the length of time available to engineer in the requirements as well as the volume of engineering required.

6. Do you believe that additional lead time would be necessary for you to comply with new standards? Depending on what the ruling is and when it occurs. Yes.

7. Are there any sector

- unique business or competitive issues that we should understand? Aerodynamic requirements would not be pract ical on a front discharge cement mixer.

8. Do you anticipate any unique legal, administrative or record

- keeping burdens associated with compliance? Administrative and record

- keeping.**Questions for Manufacturers of Vocational Vehicle Chassis**
1. W hat GHG

- reducing technologies does your business implement already? We were exempt for model year 2014 and now exempt for model year 2015. To date, we have not sold any new vehicles that would be subject to these GHG reducing requirements.

2. Do you have any specific experience with lower rolling resistance drive and steer tires? No. With tire inflation systems? No. With light weighting of components? No. With engines certified to the heavy

- duty Phase 1 standards (e.g., MY2014 engines)? Yes, Cummins ISX12

3. How feasible do you find each of the aforementioned technologies? LLR tires: moderately feasible. Inflation system: Not very feasible. Light Weighting: Not very feasible. Phase 1 Engines: Moderately feasible.

4. Have you experienced any effects (manufacturing changes, consumer responses) from these technologies? (move down) No. See response to question number 1.

5. How do you anticipate the proposed standards will affect your engineering development process? Depending on the ruling, it will likely overwhelm our engineering development process.

Thank you,

Adam Jump /Engineering Manager Kevin Kelly /Project EngineerFrom: Schrock, Brad

To: Wiggins, Lanelle Subject: E-One Comments on Phase 2 of Greenhouse Gas Emissions for Heavy Duty Vehicles

Date: Monday, July 07, 2014 3:38:48 PM

Ms. Wiggins,

I, on the behalf of E-One Inc. would like to make a comment on the phase two ruling of the greenhouse gas emissions regulations for heavy duty vehicles. We are concerned on the ability to be able to trade credits between different vehicle types within the same class of vehicles. Being able to trade between different vehicle types is imperative to our business model and potential future growth.

We would like to be able to discuss this in future meetings with the EPA.

Sincerely,

Brad Schrock Manufacturing Engineer
E-One Inc. (352) 861-3429

On Jul 3, 2014, at 11:57 AM, "Wiggins, Lanelle" < Wiggins.Lanelle@epa.gov > wrote:

Hello potential SERs,

I just wanted to send a reminder that any written comments you wish to submit in response to the June 19 meeting are due by close of business (COB) Monday, July 7. You can think of these initial written comments as a way to let EPA know of any issues that were not clear or that you’d like more information on during the formal Panel outreach meeting. You will also have the opportunity to submit written comments after the formal Panel outreach meeting.

The presentation given on June 19 was meant to be introductory. Most of the material highlighted requirements for large manufacturers in Phase 1 (2014-2018) an example of the topics we’re considering for Phase 2. As small businesses, you continue to be exempt from certifying for 2014-2018. However, EPA is investigating the option to include small businesses in the second phase of this rulemaking, which would begin

after 2018. The purpose of the SBREFA process is to give you an opportunity to tell EPA how you think regulations would impact your business and help us identify appropriate flexibilities that will keep the rule from having a significant economic
impact on your company. The ChartofFlexibilitiesfromPreviousRulemakings.pdf file lists some small business flexibilities implemented in previous rulemakings, which included options such as delayed implementation, reduced stringencies, and reduced testing burdens.Your comments from the first presentation will be helpful as we prepare for our second meeting in September. During this meeting we will provide more details about Phase

2 and it will be much more of a discussion. We provided a list of questions in the outreach document (GHG SER Outreach Doc.pdf) that will give you an idea of the information we hope to gain in our second meeting. We understand that you may not have enough information at this point to be able to answer them with certainty, but they can be used as a guide for the written comments you’re generating from the first
presentation. We welcome general comments, questions about things that were confusing during the presentation, or requests for specific information we should provide in the second meeting to help answer the questions.

Please don’t hesitate to contact us at any time if you have questions.

Stay cool and enjoy the holiday this weekend!

Lanelle

Lanelle Bembenek Wiggins

RFA/SBREFA Team Leader US EPA - Office of Policy (1803A) - 1200 Penn Ave NW - Washington DC - 20460

202.566.2372phone: 814.835.0200 | fax: 814.835.0201 | 1620 Harper Drive, Erie 16505 | www.cngonesource.com



### Preliminary Comments Following the June 19, 2014 Meeting with the EPA

CNG One Source intends to submit further written comments following the formal Panel Outreach Meeting

CNG One Source anticipates the potential regulations to impose burdens on its small business. Not only is CNG One Source a small business, but we are likely to manufacture a very small percentage of CNG engines for medium and heavy duty. That being said, the great expense of research and development coupled with the high costs of formal emission testing will limit the commercial availability of new CNG engine designs.

CNG One Source would like to ask specifically what testing will be required for each age category for medium and heavy duty CNG engines. For very small entities such as CNG One Source, could alternative methods accomplish the same goals? For example, could portable emission testing equipment satisfy the requirements? Could state emission testing be sufficient?

Our company is committed to not only achieving the best emissions possible, but to designing a safe and durable engine system as well. Having an engine receive emissions certification does not suggest that the engine is safe or durable. This is confusing to consumers. Consumers pay

h igh prices for natural gas engines for medium and heavy duty applications, and many times later discover that the maintenance costs are even higher. Part of that initial expense is the cost of certification that is passed to the customer. It appears that n ew customers often believe that because the engines are expensive, that they are also safe, durable, and require little maintenance.

CNG One Source would like to see a way to show that the engines are also made of safe and durable components. Any CNG engine can likely pass emissions testing on the dyno. But when that engine is put into the field, it may not perform. At this point in time, the only thing that

customers look for in a “ quality ” system, is whether or not the engine or conversion system is EPA approved. They don ’ t understand the difference.

CNG One Source has never tampered with emissions, and does not intend to do so. However, we would like to ask about enforcement of the existing EPA regulations. If the EPA is not going to enforce the anti-tampering regulations, then what incentive is there for emerging companies to follow the regulations? The shade tree mechanics already offer conversions that are not EPA compliant. Other small businesses have thrived performing what we call “ illegal ” conversions,July 7, 2014

Page 2

while CNG One Source has “ walked the straight and nar row ” to our own detriment. Our competition is the myriad of companies doing what they want and are ignoring the regulations. Those are the companies that are selling the most conversions. If there is no enforcement, the country will continue to be the Wild Wild West with CNG. CNG One Source experiences the uneven playing field due to the lack of enforcement. Companies not following regulations offer much less expensive systems, and companies such as CNG One Source cannot come close to competing with them. However, if the front end costs of compliant systems were lower, CNG One Source would recommend an annual or every three year emissions inspection which would

facilitate continued maintenance on the systems and improve long term durability. As an example, once the engine is installed, there is no follow through to maintain valve adjustments, which adversely impact performance, durability, and emissions. Finally, by reducing costs up front and adding emissions testing, the industry will improve its products as a whole.

In addition, CNG One Source experiences the uneven playing field by having to pay expenses for certification that are disproportionate to what big business has to pay. New and innovative technologies to improve natural gas engines will continue to be stymied if this continues. Furthermore, other government agencies, such as the Department of Energy through NREL, has stated to us that they will never fund a small business again. So small businesses will have little resources to develop their ideas which will further curtail the industry.

CNG One Source would like to explore these issues further, contribute more with this process, and provide more detailed feedback during the next comment period. We sincerely appreciate

th e opportunity to work with you on these issues.

Th ank you,

Karen Teslovich201 Mittel Drive , Wood Dale, IL 60191

1.630.350.9400 (Main)

– 1.630.350.9900 (Fax)

www.psiengines.com Lanelle Wiggins, RFA/SBREFA Team Leader EPA Office of Policy
1200 Penn Ave NW Washington DC - 20460
202

- 566 -2372 wiggins.lanelle@epa.gov

RE: Comments from June 19, 2014 Pre-Panel Meeting on GHG Phase 2

Dear Lanelle:

Thank you for providing our company with an opportunity to participate in this process. We look forward to the next steps in this process and will likely have more to add as the process proceeds further into the details about GHG Phase 2.

We have reviewed all of the material presented during the pre-meeting and have also
reviewed and consider ed the “Questions for All SERs” provided. Below are some general comments considering both the review of information and the questions for SERs.

Our company would generally fall into the category of being a Secondary Engine Manufacturer. We mostly purchase “new” incomplete long block engines and fit them with the fuel and emission control system. We then certify the completed engine assembly to the appropriate regulatory standard for the given market. Further, our company specializes in OHHD engines that are spark ignited and are fuel by alternative fuels (LPG and CNG). We do plan to offer gasoline fueled OHHD engines in the near future as well.

As a result of being a secondary engine manufacturer we do not control the design and content of the long block engine assembly. In the GHGPhase2SBAR_Panel_FINAL 2014- 06

- 17.pdf slide deck presented during the meeting, there was a slide which displayed “Engine
GHG

- Reducing Technologies.” For Spark -Ignition, this slide presented Reduced Friction, and Stoichiometric Gasoline Direct Injection as technologies. Similarly, technologies were presented for Compression-Ignition Engine. The GHG Reducing technologies all involve improving the overall efficiency of combustion which will directly reduce GHG emissions.
All of these GHG -reducing technologies apply directly to the design and construction of the long block engine assembly. The specific spark ignited engine technology of Stoichiometric Gasoline Direct Injection provides a much greater benefit with gasoline as a fuel than it does
with LPG or CNG fuel.

Small businesses, especially secondary engine manufacturers, are at a disadvantage when it comes to applying new technologies to their engine products. Secondary engine manufacturers purchase new incomplete long block engine assemblies from large automotive companies, typically, and these long engine blocks are always design for the specific applications of the automotive manufacturer’s vehicle products. As such, the secondary engine manufacturer has no ability to control or influence the content of the long block engine assembly.201 Mittel Drive , Wood Dale, IL 60191

1.630.350.9400 (Main)

– 1.630.350.9900 (Fax)

www.psiengines.com The integration of leading edge GHG reducing technologies by the large automotive companies will present the small business entity with challenges and hardships to adopt. As mentioned above, the automotive companies develop their powertrain (engine) technologies specifically for their own vehicle applications. There is no consideration given for outside entity use of the technology.

Automotive companies do sell long engine blocks to secondary engine manufacturers. The development, certification and application of the long block is the complete responsibility of the secondary engine manufacturer. When applying a purpose designed long engine block into a different market, the secondary engine manufacturer can face challenges requiring redesign and reconstruction of certain aspects of the long block engine.

These challenges, in many cases, will require interaction between the secondary engine manufacturer and the automotive company (long engine manufacturer) in support of the changes required by the secondary engine manufacturer’s application/market needs. In many cases, the automotive company has no interest; motivation; resources or willingness to support the needs of the secondary engine manufacturer. There are many reasons for the automotive company not being able to support the secondary engine manufacturer, but the primary reasons are low volume, time and pending internal requirements.

The secondary engine manufacturer finds itself in a position of not being able to effectively pursue changes that may be required to apply current leading edge technology. The general point here is it takes the small business / secondary engine manufacturer time to adopt new technology, given the general lack of support from the entity that owns the technology.

Considering the current position of small businesses / secondary engine manufacturers, compliance with more stringent standards will require change over time. Small businesses will need to invest in human resources and more technological capability in order to comply with more stringent regulations, similar to large automotive entities. This capability will require time to adopt and evolve inside the small business. The small business will likely never evolve to have the capability of a large automotive company, but a closing of the gap will take time and financial resources. All of this will require a business case to support. The small entity will struggle to support the required investment to move toward more stringent standards; however, some movement can likely be accommodated by progressive
small businesses.

In summary, our current comments are stated in these points.

 The GHG reducing technologies all impact the design and construction of the long engine block assembly.

 Small businesses / secondary engine manufacturers have very little ability to influence the content of the new long engine block engine assemblies purchased from automotive companies.

 Small business es / secondary engine manufacturers receive very little support from the long block engine manufacturer for challenges faced when developing and applying the long block engine assembly into new applications.201 Mittel Drive , Wood Dale, IL 60191

1.630.350.9400 (Main)

– 1.630.350.9900 (Fax)

www.psiengines.com  The small business / secondary engine manufacturer will need to invest in developing new/additional internal technological capability to be able to accommodate more stringent standards.

 The small business / secondary engine manufacturer will require additional time, beyond that required by a large entity, to adopt more stringent standards.

We look forward to further participation in this process. Thanks for you time and
consideration.

Regards,

Andy Suhy Director, Emissions Development and ComplianceB2 : Written Commen ts from Small Entity Representatives for the 10/28/2014 and 11/5-
6/2014 P anel Outreach Meeting sLanelle Wiggins October 24, 2014

US- EPA – Office of Policy

1200 Penn Avenue NW Washington, DC 20460

In response to your questions posed on page 44 of the Small Business Trailer Manufacturers presentation that you supplied in your email dated ;

1. We have been installing almost exclusively Low Rolling Resistance Tires for the past two years.

We have been installing automatic tire inflation systems for approximately a dozen years and currently have ab out a 3% adoption rate.

We have not installed any side skirts on our trailers. We only build bulk commodity trailers – primarily used to move grain, aggregate, and other free flowing materials – and a large portion of these materials are discharged into augers that are “swung” into position underneath of the trailer. As such, use of side skirts would preclude the ability of our customers to unload the
trailers. Side skirts are not a practical solution for our style of trailer.

That said, all of our trailers have a portion of the trailer that we refer to as the Hopper Assembly which fills the majority of the space below the lower rail and between the tractor tires and the trailer tires. This Hopper Assembly would negate most of the positive impact of ad ding siding skirts to our trailers, even if it was practical to do so , as our trailers do not experience the same air turbulence pattern that traditional dry freight trailers generate. Most of them do not operate at highway speeds for other than short per iods of time.

We have also not had any experience with rear air skirts/fairings. I do not see a practical reason why they could not be physically attached. They would interfere w ith the current access system that is mounted on the rear of the trailer, w hich is used to inspect the load, but I am sure that we could design a solution to that issue. We would of course have to insure that the rear fairings did not interfere with the statutorily required lighting on the rear of the trailer.

2. Hardships that we would anticipate would be;

a. Acceptance of the additional equipment by the end user. Each of our trailers is built uniquely to the customer’s specification and they are reluctant to allow us to add anything to the trailer that they didn’t specify. We have this same issue with any aspect of the trailer that is required by statute.

b. As these trailers are used to haul bulk commodity, any additional weight associated with adding any aerodynamic devices would be seen as a negative and result in resistancefrom the marketplace as it will reduce the amount of “product” that they can haul per
load.

c. Any significant change in the weight or cost of the trailer will cause a dramatic reduction in sales for a several year period of time as customers will defer purchasin g the units with the additional aerodynamic devices as long as they can. They would more readily accept the increased cost than the increased weight.

d. If the required change included side skirts our business would be devastated as the customer base simply would not purchase the trailers at all. Those that would still buy the trailers would remove the side skirts as soon as they purchased the trailer as the skirts would prevent them from being able to unload the trailer.

3. Other considerations we would have to make in our manufacturing processes could include;

a. Depending on what the requirements end up being, we would have to try and hire additional employees to handle the installation of the additional componentry, which is difficult to do in the small, rural community in which we are located.
b. Again depending on the requirements, we would most likely have to invest in enlarging our facility to allow space for the installation of the additional devices.

4. Flexibilities that we believe that would be helpful wo uld include;

a. Alternatives to compliance that did not include the use of side skirts.
b. Alternatives to compliance that did not require us to do actual aerodynamic testing as we could not afford that expense.

5. We would hope to be able to acquire technologies from vendors.

6. Our customer base is located throughout the country but we have a much higher concentration of users in the Midwest. Our trailers are all shorter than those covered by the California
ordinance so we have no feedback from our customer base o n the California requirements.

In closing I would just like to explain our particular product briefly. As stated above, we build strictly bulk commodity trailers used to move free flowing commodities. They have an open top which is covered with a tarp w hen in transit. Externally they are shaped like a rectangular box. Internally they are shaped like a large funnel. Beneath the lower rail of the trailer

– between the tractor tires and the
tires of the trailer - is a hopper assembly. This hopper assembly is funnel shaped and extends to within about 15” of the ground and has trap doors on the bottom which are used to release the load out of the
trailer.

Over 85% of our production is trailers that are 42’ in length or shorter. None of our production is longer than 50’ in overall length. Most of our production is built to a 96” overall width and most have an overall height of 110” to 122” – so they fit inside of the envelope in the air cut by the tractor.

As they are used to haul bulk commodities – weight and strength are the two most important features of our trailers. They are built primarily of aluminum. Our most popular models – the 40’ and 42’ over all length units – weigh only about 9000#. Customers have the ability – and do – to buy options to reduce the weight such as aluminum wheels, lightweight hub & drum and other aluminum structuralcomponents. That said, being bulk commodity trailers, they will always fill them to achieve the legal loaded limit but the lighter the trailer, the more commodity that they will move per trip and hence the lower the number of trips.

Over 50% of our production is sold directly to farmers and they are used to mo ve grains out of the field and from the farm to market. The balance of the production is used by commercial firms to move bulk commodities between different processing centers.

Our units are highly configured. We sell primarily to farmers and owner/operators and they all have different opinions on what they want from an appearance and functionality standpoint. Our average
order size is for 1.3 trailers. It would be impractical for us to try and certify our product on a basis that required actual aerodynamic testing. The cost would exceed our revenue.

As mentioned above, our trailers are unloaded out of the bottom of the trailer and typically into an auger system which is “swung” into place underneath of the trailer. The auger would reside and travel through the same space as the space the side skirts would be installed. That is why they are not a practical solution for our particular type of trailer.I look forward in participating in the conference call next week and hope that my input will be of benefit to the process.

Thank you

Jeff Thompson
Vice President Timpte Inc.

### To: Lanelle Wiggins - EPA

From: Jan Hoover – Di amatrix, 215-949-4790

Input

 On slide 10, I would add 49 CFR 568 - VEHICLES MANUFACTURED IN TWO OR

MORE STAGES. Which manufacturer would be responsible for the reporting and

certification in this case?

 On slide 40 other costs to consider. There will be engineering, purchasing and material handling costs associated with any device added to the trailers. Engineering will need to evaluate options, create drawings and bills of materials, ensure compliance of other components (lights, etc.) and to avoid inte rferences with other items on the trailers. Purchasing will have to buy the additional items, receive the items and process the invoices. Material handling will have these additional items to stor e and deliver to the

line.

 Aerodynamic testing will be a huge expense, not only to small businesses, if we are required to do this. It would be beneficial if we could pick devices from an approved menu or list. If we are required to test and verify every device it would be a huge burden on small business and might put us out of business.

 Model year on slide 26. Our model year changes, officially, on January 1. However, if we

have an order that starts in December and will finish in January, that entire order will be of the new model year. I cannot speak for othe r manufacturers. You will need to contact them directly. Possibly TTMA could get that from their membership but it will not be all

inclusive.

 Trailer options or models that would preclude the use of some aero devices:

o Rear and side mounted liftgates or simila r devices. A liftgate is a work performing device that raises and lowers freight to and from the ground and the trailer.

o Belly boxes and similar devices. Belly boxes are mounted under the trailer and can be used for storing tools or equipmen t necessary to the freight being hauled.

o Trailers with heater units or simila r options installed would not permit the

installation of nose mo unted aero devices.

o Vents specified at the front and rear. Ve nts are usually used to provide airflow through the trailer while it is running on the highway. These may produce

interference with nose or rear mounted aero devices.o Side door steps. Steps are used to permit th e entry into the tra iler through the side door. The structure of and bracing of thes e steps may preclude the use of certain

side aero devices.

o Trailers with more than three axles or trailers with spread axles. With these configurations there would be no room or very little room for side and underbelly

devices to be installed.

o Trailers for intermodal use ha ve underneath clearance criteria and lift pads that MAY cause issues with specific aero devices.

o Drop frame trailers. Drop frames trailers ha ve a drop in the floor at or near the landing gear. The trailers or trailers similar to them would not be conducive to

some aero devices.

o We build some trailers where we build a “shell” that our customer may convert into a portable office or add machinery t o. The modifications that are done may require the removal of aero devices, if installed, or preclude the use of them altogether. How would these types of trai lers be handled under the regulation?

Questions I have that were not fully addressed on the call

 How are the trailer families defined? Slide 33 refers to “manufacturers define

families.....”

 On slide 33 there are the genera l certification steps. What is involved in each step and how do we accomplish each step? How is this affected by using a menu of pre-approved aero devices, if any? I am trying to get a feel for what kind of time is required.

 How is reporting done? Is it yearly, quarterl y, or other? Can reporting be done quarterly, if not currently set up that way.

 It was asked if we could get access to the existing GEM calc ulator for tractors. I think this would be helpful.

 On slide 27 there is a comment about mainta ining records of data. What data records need to be kept and maintained? How long do these records need to be kept?

 On the TTMA/EPA conference call on 10/17 it was suggested that EPA, Ann Arbor, could hold a meeting to go over the reporting/ GEM process with trailer manufacturers (not just small businesses). Is that still on the table?

Answers to question for all SER’s

1. I am still not quite sure at this time what th e impact would be to our company or if we would need to add equipment or staff. We defi nitely will have to spend what seems like a significant amount of time with certifications an d reporting. If this is the case and we will likely have to add staff. We may also be requ ired to hire shop pers onnel to install the aero
devices.
2. Flexibilities that could reduce small entity burden.

a. Exempt small businesses completely.
b. Exempt small businesses for a period of time.c. Reduce the level of compliance for small businesses.
d. Allow manufacturers to pick aero devices from a pre-approved list rather than having to test themselves. It is understood that manufacturers would test if they come up with a device that is not on the approved list.
3. The materials appear to address all issues.
4. We build some special trailers such drop fram e dry freight van traile rs and trailers with belly boxes that we may not be able to use existing technologies (side skirts) for
reduction of CO2. This could create an issue of compliance or increased burden on us. What they will be specifically, if any, is unclear at this time.
5. If stringency levels are too great to start and technology does not exist to meet those
levels it would be an issue. But I do not thi nk that it would change my answers to any of the questions above.
6. Based on what I perceive that EPA will propose, I do not think that additional lead time will be required. That is, if we are permitte d to pick from approved aero devices and not
to have to test there should be no additional l ead time. I also think that we would be able to figure out the reporting and record keeping prior to the effective date. Workshops for reporting and certification would be greatly beneficial.
7. At this time I cannot think of any sector-uni que business or competitive issues that you
should understand.
8. Yes, I anticipate that we will have unique legal, administrative and record keeping burdens as a result of compliance since we do not currently ha ve any such reporting. What specifically these will be is unclear at this time.
9. I am not aware of any potent ial regulatory conflicts.

Answers to questions to trailer manufacturers
1. Yes, we have experience with side and rear fairings along with LRR tires. We have not seen any benefits with the implementation of these technologies as we are not the end user. We have heard from customers that they see a benefit in fuel reduction but those
numbers are not concrete.
2. We will have increased costs associated with engineering, purchasing and material handling at the plant level. We will also have in creased costs, either at the plant or at the corporate level, for certifica tion and reporting. We could also have increased costs if we are required to do testing rather than using a pre-approved aero device list.
3. We will need to determine a place in the pl ant that we can install and store the aero devices. Depending upon the devices we may actua lly have to restructure our line stations to accommodate there assembly/installation.
4. See question 2 in previous section.
5. I would expect that we would both ac quire technologies from vendors along with developing technologies in-house.
6. We do not have any specific experience re garding a response to the California requirements and do not have many customers in the western part of the country. Most of our customers and our major customers are located east of the Mississippi.

### East Manufacturing Corp.

1871 State Route 44 Randolph, OH 44265

November 4, 2014

Re: Comments and Questions to the EPA - GHG Fuel Efficiency Standards (Phase 2)

• East design s and manufactures four basic types of All aluminum lightweight trailers.

o End Dump trailers

o End Dump truck bodies

o Platform Trailers (Flatbed and Dropdeck)

o Refuse Trailers (Tippers and Walking Floors)

• The total annual US Market for these four types of trai lers is very small compared to
Vans and Reefers.

o End Dump trailers/bodies are estimated to be 6,000 to 10,000 units annually.

o Platform trailers are estimated to be 15,000 to 28,000 units annually.

o Refuse trailers are estimated to be 3,000 to 4,000 units annually.

• None of the trailers East builds are covered under the EPA’s SmartW ay program

.
o The only devices currently applicable to our product types are Rolling resistant
dual tires , Wide base single tires, Tire pressure monitoring systems and
Automatic Tir e Inflation systems.

o LRR tires today are limited in availability, sizes and certain applications. It is unknown if they may have an adverse effect to tire wear on Flatbed and multi

axle end dumps that are subjected to “High Scrub” tire situations. Causing owners to buy more tires in a shorter time period. This will increase the usage of materials and drive operating cost up and profitability down for Owner operators and Fleet

owners.

• Averaging, Banking and Trading will most likely not be available to East Mfg or other
S mall Business manufacturers simply due to the small number of trailers built annually of each product type.

o This inability to use Averaging, Banking and T rading will put small manufacturers at a market disadvantage compared to large business
manufacturers.• Year Model designation is all over the board. Each manufacturer can decide when to change year models within two years . In the past most manufacturers changed over in June or July of each year. Today most change over January 1 st of each year. This was driven by Fleet and customer requests. There is currently no government mandate regulating the timing of year model change for trailers. (Example: Today o n January 1, 2015 most manufacturers will be building 2016 year model trailers). Conve rsely, there is nothing to keep manufacturers from pushing off the change to a year model out one or even two years at this point. Thereby delaying the mandate to comply with these regulations.

• Due to the specific applications of our trailer types we fear that adding aerodynamic side fairings, front and rear fairings could create unsafe conditions, higher warranty costs and product liability issues if required to be installed. (More discussion is needed here)

• A high percentage of the products we build a specified with 4 or more axles up to 8. We feel that none of the current Aerodynamic device currently used today would be able to be installed and if they could would be of little to no effect. (More discussion needed here)

o Products spec’d with more than 4 axels should be fully exempted from this

program.

The following are answers to the Questions to All SERs on page 42 of the document provided by
the EPA on 11/5/2014.

1. Yes these regulations would require East to add additional clerical staff, more Direc t labor and additional Material Handing/indirect labor.
2. Since averaging probably will not work for small entities some other method of leveling the playing field between large and small manufacturers should be developed.
3. We believe there will be many unkno wn adverse issues and circumstances not thought about today as a result of these regulations.
4. Trailers serving Niche markets are too small in annual production to affect the overall output of GHG CO2 emissions.
5. Extending the start date for small business entities will allow us to evaluate technology
and the effects of the cost associated on our businesses.
6. Yes we would like to see the time extended for compliance for all small business manufacturers so that we have more time to study the requirements and t hey associated perceived benefits.
7. Yes there should be more open discussion around all four of our product types.
8. Yes we anticipate Product Liability laws suits on dump and refuse trailers due to causing potential trailer rollovers and/or damage to equipment in landfills and construction sites.
9. There may be possible trailer length law issues associated with Boat tails on our Refuse
trailers.The following are answers to the Questions to All SERs on page 44 of the document provided by
the EPA on 11/5/2014.

1. No
2. Yes
3. Unknown at this point. Too early in the process.
4. Full or partial Exemption for our product types.
5. We would have to acquire technologies from vendors as we do not have the resources for a full R&D study.
6. (a) No (b) Most of our customers are located East of the Mississippi river.

We appreciate your consideration of our comments, questions and requests.

R egards,

David J. de Poincy President/COO

East Manufact uring Corp.
Office: 330

- 325

- 9921 Ext. 212
Cell: 817

- 948

- 5733

Fax: 330

- 325

- 7851 ddepoincy@eastmfg.comLanelle Wiggins November 10 , 2014

US- EPA – Office of Policy

1200 Penn Avenue NW Washington, DC 20460

To expand on the earlier response s to your questions of the Small Business Trailer Manufacturers ;

1. As to Annual Mileage, Speed and Life Span

We believe that the average life span of one of our trailers in about 20 years but has different stages of life and associated mileage similar to some of the information that you collected on dry vans and reefers

.

In the first 5 years of their life we believe that the average annual mileage for our trailers is
51,000 miles.

In the second 5 years of their life we believe that the average annual mileage for our trailers is
36,000 miles.

In the third 5 years of th eir life we believe that the average annual mileage for our trailers is 10,000 miles and in their last five years of life the average annual mileage would be 5,000 miles.

The average speed in the first five years would be 50 miles an hour and drop an aver age of 5 miles per hour for each of the next five year brackets.

2. Tractor type and utilization

Something else that is somewhat unique about our style of trailer is that they are typically
married to a tractor – unlike dry vans and reefers which frequently pull different trailers all of
the time.

As stated previously about ha lf of our sales are directly to farmers. In those applications the tractor is typically an older unit – commonly a tractor from the 80s or 90s. Our commercial customers commonly have later model tractors – say 1 to 8 years old.

3. Certification Year

In reference to the convers ation on Certification Year, as was discussed on the phone, tying the certification to the model year is more difficult for trailer builders than was described for
automobile manufacturers.I would suggest for our environment that tying the certification y ear to the calendar year would
work the easiest.

4. Averaging/Banking

Due to the low volume of construction of any given configuration of trailer, it is difficult for us to see how Averaging and Banking would benefit smaller manufacturers. It could easily put us at a disadvantage to larger trailer builders, especially those that might build a variety of different styles of trailers.

Thank you

Jeff Thompson
Vice President Timpte Inc.From: Adam Jump

To: Wiggins, Lanelle Subject: General comments made during conference call on Nov.6th 2014 12:30-2:30 pm (Eastern) - Panel Outreach Meeting with Vocational Chassis Manufacturer SERs

Date: Monday, November 17, 2014 2:19:40 PM

Attachments: Comments made during conference call.doc

Lanelle,
Please see attached comments made on Nov.6, 2014.

Thank you,

Adam Jump
Engineering Manager
Indiana Phoenix, Inc.
200 Dekko Drive,
Avilla, IN 46710

Work: 260-897-4651

Cell: 260-402-9348

Fax: 260-897-4646Comments made during conference call:

- All the trucks we build are 6X6 configuration with up to two tag axles and two pusher axles.

- The majority of the trucks we build use super single tires on the rear drive axles and all use super single on the steer ax le.

- Most of our customers use a cog type traction tire since they spend a lot of time on construction sites.

- The take rate on the air conditioning option is about 10% and it is assembled in

- house.

- Since these vehicles are front cab, rear engine configuration the refrigerant lines are approximately 20 feet long.

- Weight reduction as a means of achieving compliance is ineffective since our customers are payload driven.

- Delivery is usually within 25 miles of the batch plant due to the cure time of the concrete.

- The drum must be turning anytime there is concrete in it.

- Hydraulic pumps are either on

- engine or FEPTO driven and the only power used through
the transmission is to move the truck.

- The on

- engine hydraulic pump is commonly used for both power steering and discharge chute control.

- We have not evaluated our AC system for compliance to SAE J2727.

Questions:

- In the event that gliders are required to be compliant, what emissions level engines must be used?

- Since all the trucks we build have pusher and/or tag axles and commonly have different tires than the drive axles, how will these be handled in the GEM model?

### To: Lanelle Wiggins - EPA

From: Jan Hoover

– Diamatrix, 215-949-4790

Input

 Costs of aero devices.

o We see side fairings (skirts) range from around $600 to $800 not including installation or FET. Installation is around $300. Pricing does seem to be coming

down.

o We have no experience with rear fairings.

o LRR tires. The $320 you mention is good for an average. We have some

manufacturers that are less and some that are more.

o ATIS ranges $500 to $700 not including installation or FET. Installation varies depending on the system and what can be prepped ahead of time.

 Volume of production by family. Our dry freight van plant builds 2500 to 3000 units per year. The percentages shown following this are subject to change based on our customer’s needs. That is, we could easily build higher or lower percentages of any trailer type in any given year.

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.

 On slide 10, I would add 49 CFR 568 - VEHICLES MANUFACTURED IN TWO OR MORE STAGES. Which manufacturer would be responsible for the reporting and

certification in this case?

 On slide 40 other costs to consider. There will be engineering, purchasing and material handling costs associated with any device added to the trailers. Engineering will need to evaluate options, create drawings and bills of materials, ensure compliance of other components (lights, etc.) and to avoid interferences with other items on the trailers. Purchasing will have to buy the additional items, receive the items and process the invoices. Material handling will have these additional items to store and deliver to the

line.

 Aerodynamic testing will be a huge expense, not only to small businesses, if we are required to do this. It would be beneficial if we could pick devices from an approvedmenu or list. If we are required to test and verify every device it would be a huge burden

on small business and might put us out of business.

 Model year on slide 26. Our model year changes, officially, on January 1. However, if we have an order that starts in December and will finish in January, that entire order will be

o f the new model year. I cannot speak for other manufacturers. You will need to contact them directly. Possibly TTMA could get that from their membership but it will not be all

inclusive.

 Trailer options or models that would preclude the use of some aero devices:

o Rear and side mounted liftgates or similar devices. A liftgate is a work performing device that raises and lowers freight to and from the ground and the trailer.

o Belly boxes and similar devices. Belly boxes are mounted under the trailer and

can be u sed for storing tools or equipment necessary to the freight being hauled.

o Trailers with heater units or similar options installed would not permit the

installation of nose mounted aero devices.

o Vents specified at the front and rear. Vents are usually used to provide airflow through the trailer while it is running on the highway. These may produce

interference with nose or rear mounted aero devices.

o Side door steps. Steps are used to permit the entry into the trailer through the side door. The structure of and bracing of these steps may preclude the use of certain

side aero devices.

o Trailers with more than three axles or trailers with spread axles. With these configurations there would be no room or very little room for side and underbelly

devices to be installed.

o Trailers for intermodal use have underneath clearance criteria and lift pads that MAY cause issues with specific aero devices.

o Drop frame trailers. Drop frames trailers have a drop in the floor at or near the landing gear. The trailers or trailers similar to them would not be conducive to

some aero devices.

o We build some trailers where we build a “shell” that our customer may convert into a portable office or add machinery to. The modifications that are done may require the removal of aero devices, if installed, or preclude the use of them altogether. How would these types of trailers be handled under the regulation?

o Extendible container chassis.

o Container chassis in general.

o Specialty container chassis.

o Extendible flatbed trailers.

o Flatbed trailers in general.

 Typically flatbeds have winches mounted under the side rail that could preclude the use of some side fairings.Questions I have that were not fully addressed on the call

 On the conference call on the 5 th I asked about the pre-certification, certification application and end of year compliance. Specifically, I wanted to try to understand what is required through each step to make some determination as to what resources we will have to have in place. Unfortunately we got sidetracked a little and my question was not fully answered and I still do not have an understanding. Would it be possible to have someone explain the process to me? Is there somewhere I can look to get a better understanding?

 On the TTMA/EPA conference call on 10/17 it was suggested that EPA, Ann Arbor, could hold a meeting to go over the reporting/GEM process with trailer manufacturers (n ot just small businesses). Is that still on the table?

Answers to question for all SER’s

1. I am still not quite sure at this time what the impact would be to our company or if we would need to add equipment or staff. We definitely will have to spend what seems like a significant amount of time with certifications and reporting. If this is the case and we will likely have to add staff. We may also be required to hire shop personnel to install the aero
devices.
2. Flexibilities that could reduce small entity burden.

a. Exempt small businesses completely.
b. Exempt small businesses for a period of time.

c. Reduce the level of compliance for small businesses.
d. Allow manufacturers to pick aero devices from a pre-approved list rather than having to test themselves. It is understood that manufacturers would test if they come up with a device that is not on the approved list.
3. The materials appear to address all issues.
4. We build some special trailers such drop frame dry freight van trailers and trailers with belly boxes that we may not be able to use existing technologies (side skirts) for reduction of CO2. This could create an issue of compliance or increased burden on us. What they will be specifically, if any, is unclear at this time. In addition, container chassis and flatbeds could be an issue for using aero devices.
5. If stringency levels are too great to start and technology does not exist to meet those levels it would be an issue. But I do not think that it would change my answers to any of the questions above except for the one regarding flexibilities.
6. Based on what I perceive that EPA will propose, I do not think that additional lead time will be required. That is, if we are permitted to pick from approved aero devices and not
to have to test there should be no additional lead time. I also think that we would be able to figure out the reporting and record keeping prior to the effective date. Workshops for reporting and certification would be greatly beneficial.
7. At this time I cannot think of any sector-unique business or competitive issues that you
should understand.
8. Yes, I anticipate that we will have unique legal, administrative and record keeping burdens as a result of compliance since we do not currently have any such reporting. What specifically these will be is unclear at this time.9. For van type trailers I cannot think of any conflicts with regulations regarding addition of

aero devices. However, on container chassis the conspicuity tape is applied to the main rails of the trailer. If a side fairing is used the conspicuity tape will not be visible.

Answers to questions to trailer manufacturers
1. Yes, we have experience with side and rear fairings along with LRR tires. We have not seen any benefits with the implementation of these technologies as we are not the end user. We have heard from customers that they see a benefit in fuel reduction but those
numbers are not concrete.
2. We will have increased costs associated with engineering, purchasing and material handling at the plant level. We will also have increased costs, either at the plant or at the corporate level, for certification and reporting. We could also have increased costs if we are required to do testing rather than using a pre-approved aero device list.
3. We will need to determine a place in the plant that we can install and store the aero devices. Depending upon the devices we may actually have to restructure our line stations to accommodate there assembly/installation.
4. See question 2 in previous section.
5. I would expect that we would both acquire technologies from vendors along with developing technologies in-house.
6. We do not have any specific experience regarding a response to the California requirements and do not have many customers in the western part of the country. Most of our customers and our major customers are located east of the Mississippi.201 Mittel Drive, Wood Dale, IL 60191

1.630.350.9400 (Main)

– 1.630.350.9900 (Fax)
www.psiengines.com November	19,	2014 Lanelle	Wiggins RFA/SBREFA	Team	Leader EPA	Office	of	Policy

1200 Penn Ave NW Washington DC ‐ 20460 202‐566‐2372 wiggins.lanelle@epa.gov

RE:		Comments	from	November	6,	2014	SBAR	Panel	Meeting	on	GHG	P hase	2

Dear	Lanelle:

Thank	you	for	providing	our	comp any	with	an	opportunity	to	part icipate	in	this	process.		The	SBAR Panel	meetings	earlier	this	month	were	very	informative.

Immediately	below	are	a	summary	of	the	initial	comments	that	we made	from	the	Pre‐Panel meeting	back	in	June	of	this	year.		I	wanted	to	provide	them	by	way	of	review	because,	they	are definitely	a	barrier	that	second ary	engine	manufacturers	have	t o	deal	with.		Imposing	more stringent	GHG	regulations	on	seco ndary	manufacturers,	especially	those	that	fit	into	the	category	of small	businesses	–	which	most	do, makes	it	very	difficult	to	ar chitect	base	engine	specific technology.

Summary of Comments from June 2014 Pre

‐ Panel Meeting:

 The	GHG	reducing	technologies	a ll	impact	the	design	and	constru ction	of	the	long	engine block	assembly.

 Small	businesses	/	secondary	engi ne	manufacturers	have	very	lit tle	ability	to	influence	the content	of	the	new	long	engine	block	engine	assemblies	purchase d	from	automotive companies.

 Small	businesses	/	secondary	engi ne	manufacturers	receive	very little	support	from	the long	block	engine	manu facturer	for	challeng es	faced	when	develo ping	and	applying	the	long block	engine	assembly	into	new	applications.

 The	small	business	/	secondary	engine	manufacturer	will	need	to invest	in	developing new/additional	internal	technological	capability	to	be	able	to accommodate	more	stringent
standards.

 The	small	business	/	secondary	en gine	manufacturer	will	require additional	time,	beyond that	required	by	a	large	entity,	to	adopt	more	stringent	standa rds.

Below	are	a	summary	of	our	comments	derived	from	participating in	the	SBAR	Panel	meetings	on
November	6 th

.201 Mittel Drive, Wood Dale, IL 60191

1.630.350.9400 (Main)

– 1.630.350.9900 (Fax)
www.psiengines.com Summary of Comments from SBAR Panel Meetings on November 6, 2014:

 There	has	been	discussion	about	ma king	a	specific	GHG	standard for	NG	fuel	type	to	account
for	the	lower	carbon	c ontent	of	natural	gas.		We	would	be	oppos ed	to	more	stringent	GHG regulations	for	NG	fueled	engin es	for	the	following	reasons:

o As	a	small	business,	we	are	goin g	to	be	required	to	use	ABT	cre dits	to	bring	some	of our	engine	families	into	GHG	com pliance.		Specifically,	some	of our	gasoline	engine models	will	require	credits	to	b ring	CO2	into	compliance.		With the	627	g/hp‐hr standard,	there	are	a	good	amoun t	of	credits	that	can	be	genera ted	from	our	NG fueled	engine	families.		These credits	will	help	us	bring	other families	into compliance.		More	stringent	GHG standards	for	NG fueled	engines would	impede	our ability	to	bank	credits.

o Further	stringency	on	GHG	standa rds	for	NG	fuel	may	not	incenti vize	vehicle manufacturers	to	adopt	NG	engine	models	for	their	products.

 We	would	like	to	recommend	that the	establishment	of	a	company’ s	ability	to	use	“small” business	provisions	of	GHG	standards	be	based	on	one	of	two	cri teria.		Currently,	the
establishment	of	“small	business” is	based	on	the	business	size standards	specified	in	13 CFR	121.201.		We	would	like	EPA	to	give	consideration,	in	futur e	GHG	rules,	to	also	allow
the	establishment	of	“small	volu me	manufacturer”	based	on	total number	of	units	sold. Such	allowances	are	provided	in	t he	criteria	section	40	CFR	86. 094‐14(b)(1)	on	the	basis	of 10,000	or	fewer	units.		This	woul d	allow	companies	to	qualify	t o	use	“small business/volume”	provisions	of	the	new	rule	by	either	means.

 The	establishment	of	a	“technolog y”	credit	to	be	applied	to	eng ine	based	GHG	certification for	use	of	such	technologies	as	Start/Stop	or	other	similar	hyb ridization.		Currently,	there	is no	ability	for	an	“engine	MOR”	to	realize	an	advantage	for	such technology	based	on	testing over	the	engine	dynamometer	based	transient	FTP	cycle.		An	esta blishment	of	a	technology
credit	based	on	the	use	of	such	te chnology	would	i ncentivize	im plementation	of	such technology	by	heavy	duty	engine	c ompanies.		It	is	recognized	th at	some	method	of establishing	the	level	of	a	credit	would	need	to	be	developed. There	are	many	reports	of hybridization	based	fuel	efficien cy	improvements	in	the	heavy	d uty	vocational	markets	that
cover	a	wide	band	of	fuel	effici ency	improvements.		The	type	of hybridization	and	duty	cycle use	of	the	vehicle	are	both	contributors	to	the	magnitude	of	th e	fuel	economy	improvement.

Thanks	again	for	allowing	our	company	to	participate	in	this	pr ocess.		We	look	forward	to remaining	involved	in	this	rule	making	as	it	continues	through the	process.		Please	do	not	hesitate to	contact	me	directly	should	you have	any	questions	or	require clarification	on	any	of	our

comments.

Best	Regards,

Andy	Suhy Director,	Emissions	Devel opment	and	Complianc ePage 1 of 7 

## Medium and Heavy Duty Greenhouse Gas Emissions and Fuel Efficiency Standards

– Phase 2

Small Business

Alternative Fuel Converters

Response to HD GHG Phase 2 Proposal from CNG One Source, Inc. November 20, 2014

PPT PROPOSED RULE OR

COMMENT MENTIONED

IN SER POWER POINT IMPACT FLEXIBILITIES AND OTHER

COMMENTS

p.6 Small businesses are disproportionately burdened by certification expenses compared to large businesses and have few funding opportunities for research and development. Small businesses must use a higher percentage of their budget for research and development and costs associated with certification. The government has specifically told us that th ey have no interest in funding small businesses involved with engine development. Therefore, the burden is entirely on the engine manufacturer. Larger companies with greater resources not only spend a smaller share on research and development, they are a lso candidates for federal funding. This excludes small businesses from realistically competing in the marketplace. If regulations burden small businesses, the agencies involved should identify and provide realistic resources to assist small

businesses achieve certification.

The EPA could provide personnel to

assist small entities in the certification process rather than redirect the small entities to costly third party companies.

p.6 Limited ability to control

f eatures of base engine architecture in the incomplete engines that they convert, which significantly reduces the options for reducing emissions. Improvements could definitely be made on the base engines which would be helpful for a superior natural gas engine design. However, it appears that the OEM cannot justify the expense involved in making these changes, as they are not necessary for running the engines on diesel fuel. Therefore, secondary manufacturers and alternative fuel

converters are limited in the amount of changes that

can be made. Small entities could comply with emission standards within a range of the original engine’s emissions.

When the industry improves, OEMs wil l be more likely to manufacture blocks that better support natural gas fu el.Page 2 of 7 p.6 Small businesses will require

additional time to invest in resources required to adopt new

standards. Small businesses will have to have more capital in order to comply with the new regulations. Changes in government regulations is discouraging t o customers and investors. Allow additional time (one year) for implementation by small entities.

p.6 Concern over lack of enforcement against companies that do not certify their converted engines. The majority of natural gas vehicles in the United

States are not EPA compliant. The EPA has not provided adequate enforcement, and there is no real incentive for companies to comply with EPA regulations. By choosing to register with the EPA and follow all regulations, CNG One Source is at a huge disadvantage. Our company will bear the burden of expense on the research and development, certification, and use of time and resources to satisfy the government. In real life applications, consumers and trucking companies are finding ways to convert

their vehicles t o run a natural gas because of the fuel cost savings. They literally weigh out the risk and cost of fines from the EPA with the price of EPA compliant engines. We have personally fielded such phone calls , and unfortunately, contrary to our

recommendation s, the trucking companies ultimately opted to purchase non

- EPA compliant engines

. In addition , we have visited with companies who have modified the EPA certified engines to improve performance. Some of these companies have even hollowed out the catalytic

converter as well as making other dramatic

modifications. There is already a very high level of

non

- compliance, and the more stringent the regulations and the more expensive the engines ( noting that the prices of development, improved The only way to change behaviors and

create compliance is to provide adequate
enforcement. On the state level, there

have been discussions that enforceme nt
will disco urage the industry, which

seems to indicate that there is no desire anywhere to provide enforcement. If
there is no real enforcement, what is the incentive to comply?

Collecting fines from enforcement could provide revenue to the EPA to assist

small enti ties in achieving certification.Page 3 of 7 components, and cer tification will be passed on to the consumer), the greater the degree of non

compliance. p.14 Converters will need to certify their engine and also work with

the vehicle manufacturer to

ensure their new vehicle meets

the GHG standards with the alternative fuel engine. Will secondary manufacturers and alternative fuel

converters be required to work with the vehicle manufacturer? This could be a cumbersome pro cess for some small businesses. In addition, when the industry grows and CNG engines become competitive in the m arket, OEM’s can eliminate the

small business “partner”

. Allow engines to be certified independently so that they can be used in different vehicles and applications.

p.16 ABT allows a manufacturer to internally average similar models (by engine architect ure or engine size), generate credits for future use if they over

comply, and sell banked credits

to other under

- complying manufacturers or buy another

manufacturer’s banked credits

to cover their own deficits. Although this system theoretically can benefi t small entities, the system heavily favors large corporations. Most of these proposed regulations seriously favor large corporations and are dangerously close to creating a monopoly in the industry.

Small entities are likely to speci alize in limited t ype s of engine s only.

p.18 EPA is considering more stringent CO 2 emission standards, including CH 4 and

N 2 O caps for all engine types. According to the EPA’s Inventory of U.S.

Greenhouse Gas Emissions and Sinks: 1990

– 2012 published April 15, 2014, m ethane emissions are not known to be significant in the transportation sector. More stringent standards are not necessary for natural gas engines.

p.18 Engine manufacturers may be required to provide engine fuel map data to vehicle

manufacturers as in puts for

EPA’s vehicle certification

model. What data will be treated as CBI? Could this requirement encourage OEMs and vehicle manufacturers to take the conversion process in

house and exclude the small businesses?Page 4 of 7 p.19 N 2 O measurement may require additional equipment in some

test facilities. EPA is considering the option of allowing AFCs to use “engineering analysis” to

demonstrate that the base engine did not exceed the N 2 O cap and their conversion process would not impact N 2 O. “EPA believes N 2 O measurement devices can be purchased, if necessary, for ~$100,000.” PPT p.24. This expense will either be incurred by the small business or passed along to the small business. Is the measurement so critical at this point, that the expense is justifiable ?

How much will facilities charge to take N 2 O

measurements? Even certification companies

cont ract with a third parties for testing . Will there be a backlog with the number of engine manufacturers having to use a limited number of

facilities? An engineering analysis would be appropriate, although this will add engineering expenses as well.

CNG One Source would like information on the process of becoming EPA certified

to take such measurements.

p.20 Phase 2 standards have not been set yet. CH 4 may be more challenging for natural gas engines. Improper fueling can result in high levels of unburned

CH 4 emissions. Converted CI (diesel) engines would need to

ensure the crankcase is closed

with a suitable ventilation system installed to reduce blo w

by CH 4 emissions. CH 4 standards should not be more restrictive. There is no clear evidence to support that mobile methane use from natural gas vehicles significantly affects

CH 4 emissions.

Improper fueling should not impact the engine’s

emissions. Furt her restrictions on methane emissions

are unwarranted.

p.21 NAS 2014 report recommending separate CO 2 standards for natural gas fueled engines. NAS did not recommend new requirements for engines that use other

alternative fuels. This limitation is unnece ssary and unfairly targets the natural gas industry. In fact, having separate standards is punitive to the natural gas industry, and why? It was just in March 2013 that the NAS stated in their report, “Transitions to Alternative Vehicles and Fuels”, that the ‘CNGV emphasis scenario’, is

the only scenario which achieves 50% reduction in At this time, there is no sound reason to implement different standards for natural gas engines. These limitations are barriers and will completely stifle an already struggling industry at a time when the technology and market adoption need to grow.Page 5 of 7 petroleum use by 2030. Unnecessary limitations are going to kill the natural gas industry before it even has a chance to become widely adopted.

p. 21 Phase 2 proposal may include additional requirements for natural gas

- fueled engines to
control methane emissions; OBD requirements for CNG

and LNG methane leaks. As stated earlier, methane leaks are presently not known to be significant as far as emissi ons are concerned. Again, this requirement is punitive to the natural gas industry. Currently the most common cause of methane leakage is a faulty pressure regulator. When the regulator fails, the engine ceases to operate, even if in motion on the highway. While this is a huge safety concern, as is as the flammability concern, it is not presently a significant environmental concern.

Methane gas composition varies greatly depending on well gas, landfill gas, and utility grade gas. Even utility gas changes in composition during the winter months. Knowing this, how will the data be acqui red for OBD? Vehicles running on low quality CNG (lower percentage of

CH 4 ) will not be detected as readily as vehicles running on high quality methane (higher percentage of CH 4 ). Further, if vehicles run on lower quality gas, the engine components will b e deteriorate much more quickly. However, to avoid MIL light and OBD issues with the EPA, operators could and would exploit this

system.Page 6 of 7 Detection of metha ne leakage by measuring mercapta n /odorant is faulty

because:

1. It doesn’t exist for LNG as it

transit ions from liquid to gas.

2. Not all fuel stations use
mercaptan /odorant , even though it is required by NFPA 52.

The engine manufacturer or converter might achieve desired EPA standards for

certification . However , until the quality

standard is built for CNG refueling
stations, the OEM or AFC will continue to foot the bill to theoretically comply during testing but will not in real life applications. p.24 EPA believes N 2 O

measurement devices can be purchased, if necessary, for ~$100,000. These prices will either be incurred by small business or passed along to small business. Is this necessary for AFC or secondary
manufacturers? As stated above, an engineering analysis would be appropriate, although this will add engineering expenses as well. p.24 EPA believes most of the GHG

standards can be met with proper tuning of fuel and emission control systems requiring the cost of some additional engineering time. “the cost of some additional engineering time” is likely hundreds of thousands of dollars when you consider all of the proposed changes in standards

. Increasing restrictions on emissions can compromise the integrity and longevity of the engine. Durability of the engine

should be balanced with emissions

standards.

p.24 If the base engine for conversion is a CI engine with an open crankcase, we estimate This design will affect e ngine durability as the byproducts of the natural gas system will deteriorate Allow open crankcase for two reasons:Page 7 of 7

a closed crankcase ventilation system to cost ~$500. the engine comp onents. For example, H 2 S

combined with CO 2 will create fissures in the steel.

Methane emissions occurring in a closed system would likely create an unsafe and potentially

hazardous situation. 1. Methane emissions are no t known to be significant in natural gas

vehicles.

2. Maintain vehicle safety by eliminating potentially hazardous closed “ventilation” system. p.24 Additional incremental increase

in costs associated with this proposed rulemaking could include attorney fees to interpret regulations, accountant fees to manage sale and compliance figures,

administrative staff for record keeping. Most companies in the alternative fuels industry are struggling to make a profit as it is still a small niche market. Many companies have gone out of business or their stocks are failing. The additional incremental costs will excessively burden the small businesses who are the ones willing to comply with the EPA’s regulations and in turn suffer the direct,

indirect and induced costs o f meeting and managing these stringent regulations.



## Emissions

Safety

Costs DurabilityFrom: dePoincy, Dave

To: Wiggins, Lanelle Subject: East Mfg submitted CBI Information related to the EPA GHG Fuel Efficiency Standards Phase 2.

Date: Thursday, November 20, 2014 4:29:38 PM

Dear Ms. Wiggins,

Just a note indicating to you that I submitted Confidential CBI information for East Mfg today, related to the EPA GHG Fuel Efficiency Standards Phase 2.

It was requested that we share cost information and an indication of volumes used for LRR tires and Tire Pressure monitoring Systems. I have shared that information today in hopes that it will assist the EPA in writing a fair and balanced regulation considering the size and purchasing power of small

manufacturers.

You may note that we buy tires from several manufacturers, but there are limited sizes available from each of them for our applications. I have also given an indication of the high volume purchases and the number of LRR tires that not available for those applications.

Also at the bottom of the list we show the 3 types of Tire monitoring/inflation systems that we buy/use along with the volume.

Our concern is that even if LRR tires and Tire systems were mandated for every trailer we build we would not be able to purchase the tires or inflation systems competitively compared to companiessuch as Wabash/Transcraft/Benson, Great Dane and Utility and it would put East in a noncompetitive situation when quoting business against these companies.

Best regards,

David J. de Poincy President/COO

East Manufacturing Corp.

Office: 330-325-9921 Ext. 212

Cell: 817-948-5733

Fax: 330-325-7851 ddepoincy@eastmfg.com