Jeffrey M. Sims ● President 7001 Heritage Village Plaza ● Suite 220 ● Gainesville, VA 20155 ● 703-549-3010

October 16, 2014 Phase 2 HD GHG Trailer Team Attn: Tad Wysor 2000 Traverwood Dr Ann Arbor, MI 48105

Dear Sirs,

The Truck Trailer Manufacturers Association (TTMA) is an international trade association representing producers of over 90% of the trailers manufactured in the United States. We are pleased to be able to work with EPA as it considers trailer-related regulato ry strategies to implement the President’s directive to expand on gains of fuel economy/greenhous e gas emissions for heavy duty vehicles.

Fuel-saving/greenhouse gas reducing t echniques are best left to th e free market, where, along with cooperative government programs like SmartWay, trailer purchasers can best assess the real-world fuel/greenhouse gas savings and purchase thos e that will actually create savings.

When considering these fuel-saving/greenhouse-gas -reducing devices (GHG devices hereafter), the trucking industry has already seen where th ey are effective and where they are not.

Based on our experience, various types of heavy duty truck trailers could be classified into certain categories that ought to be consid ered separately. These are broa d categories in which there are considerable variations that are significant to fuel economy/greenhouse gas emissions, but it is a starting point. The categories are:

53’ or Longer Straight Floor Dry Vans – These are th e workhorses of long haul and most likely to be outfitted with GHG devices. Still, there are many applications where certain types of GHG devices are not worthwhile or are actually counte rproductive. For example, if a particular GHG device interferes with trailers made to work on rail cars in a trailer on flat car (TOFC) situation, it would result in freight being diverted from TOFC service and resu lt in a net increase in fuel consum ption and greenhouse gas releases.

Less than 53’ Straight Floor Dry Vans – These configurations are almost exclusively used in short haul service with a noteworthy exception being Doubles used between distribution centers of package delivery services (e.g. UPS, FedEx). Most of these trailers gain little benefit from Aerodynamic GHG devices as their average speed is too low.Reefers – These specialty vans often travel longer hauls than similar dry vans, however, given the density of the cargo they haul (food products tend to be relatively heavy), they run up against th e weight limit (weigh-out) often. In those cases, every pound of weight added to the trailer is one pound less of cargo it can carry. Any gains to be had from aerodynamic based GHG devices would be lost in extra trips required to haul the displaced cargo.

Cargo Tanks – A trailer equipped with a liquid tight vessel for carrying liquids or dry bulk products. These trailers are usually highly specialized to th e need of the commodity being hauled, and also frequently weigh-out. Extra trips with these trailers carry an additional risk, as they are often carrying
hazardous commodities.

Lowbeds – A lowbed trailer is a platform trailer c onstructed to provide mini mal ground clearance beneath the loading deck and designed to tr ansport heavy, often times concentr ated loads with high centers of gravity. Like Cargo tanks, these tr ailers are often highly specialized fo r the load/service they are in. Frequently, lowbed trailers are ha uling construction equipm ent to locations of in consistent terrain and generally for relatively short distances.

Flatbeds & Others – A trailer cha ssis consisting of load-carrying main frames and a flat loading deck without permanent sides or roof. Flatbed trailers often carry large/unusual obj ects, and other types of trailers are highly specialized for a particular ni che market that precludes extensive modification. Noteworthy among the other category is the intermodal chassis. A chassis is a skeletal structure on which a container is placed in order to provide transportati on from a ship or railcar across the road system. When the chassis is without its payl oad (container) the structure is narrow, about 40” wide. In order for an aero device to be functional with the cargo be ing carried, the device must extend from the main structure approximately 25”. During handling operations in the ship and rail yards, the chassis is handled
in the area where these structures woul d be mounted, precluding such devices.

We polled our members to assess market penetration of various GHG devices by type of trailer & device. Our findings are summarized in Figure 1.

Figure 1 53 or longer

van under 53 foot van refrigerated flat bed cargo tank lowbed/ heavyhauler all other aero side skirts 35.4%/34% 1.7%/1% 19.0%/20% 0.0%/0% 0.7%/0% 0.0%/0% 0.0%/0% boat tails 0.2%/0% 0.0%/0% 0.0%/0% 0.0%/0% 0.0%/0% 0.0%/0% 0.0%/0% gap reducers 0.0%/0% 0.0%/0% 0.0%/0% 0.0%/0% 0.0%/0% 0.0%/0% 0.0%/0% low rolling tire wide single 2.2%/2% 1.6%/2% 2.0%/2% 1.9%/1% 2.0%/0% 1.8%/0% 0.6%/0% low rolling tire duals 85.6%/82% 90.6%/95% 86.3%/82% 39.4%/16% 7.7%/0% 5.3%/0% 28.5%/4% ATIS 40.2%/40% 26.6%/29% 46.0%/46% 20.0%/10% 7.3%/5% 3.3%/5% 13.3%/10% under belly 1.9%/2% 0.5%/0% 0.9%/0% 0.0%/0% 0.0%/0% 0.0%/0% 0.0%/0% flow thru mud flaps 10.0%/11% 24.0%/9% 3.7%/0% 0.0%/0% 0.0%/0% 0.0%/0% 0.0%/0% wheel covers 0.0%/0% 0.0%/0% 0.0%/0% 0.0%/0% 0.0%/0% 0.0%/0% 0.0%/0% Manufacturer Observed Market Penetration Average/MedianOutside of the 53’ or longer van and refrigerated tra ilers segment, all adoption is solely due to market demands and thus reflects adoption of devices where they actually make economic sense. What we find is that gains to be had from Low Ro lling Resistance (LRR) dual tires in the most popular long haul vehicles are the ones that are most justified (highlighted in green). Other areas, highlighted in yellow, represent potentially effective gains or industry compliance w ith CARB regulations in th e case of long vans and reefers. The areas highlighted in re d indicate combinations that are not practical due to type of trailer, typical freight, or operating conditions.

The similarity in response between Flatbed and All Other trailers indicate that they ought to be considered in the same fashion, where LRR duals and Automatic Ti re Inflation Systems (ATIS) show some promise. The similarities in response be tween Cargo Tank and Lowbed manufacturers and their uniform low adoption rates indicate practical proble ms with GHG devices and indicate that these types of trailers ought to be exempt from the regulation.

Work Performing Equipment: In other areas of regul ation, DOT has recognized the need for regulatory flexibility when trailers are equipped with “work performing equipment” in areas where they might otherwise require devices to be mo unted. This would include lifting or handling locations, such as the main beam of an intermodal chassis, or lift points on TOFC service trai lers. To avoid the worst of niche products and small businesses being inadvertently cr ushed by GHG regulations, ex ceptions for trailers outfitted with work performing equipment in areas typical ly fitted with GHG devices need to be crafted in any proposed rule.

Cost-Benefit Calculations: We be lieve that requirements that each trailer design and its accompanying GHG devices be aerodynamically- or fu el-consumption tested will be co st prohibitive. Requiring this would cause major harm to small businesses building short runs of trailers, and will add so much cost that end users will divert freight to othe r types of trailers with worse perf ormance. Freight Diversion is a difficult problem to quantify, one which the DOT is currently grappling with as a part of their MAP-21 Size & Weight Study

.
We have heard reports that as a result of California’s ove rly broad and aggressive regulations, end users are shifting freight increasingly to intermodal containers on chassis. The fuel consumption/greenhouse gas properties of these chassis/container combinations hauled exclusively over the road are far worse than the unmodified van trailer they ar e displacing. We understand that th e scope of the regulations under consideration does not allow for requi ring changes to intermodal containe rs, so any regulation that lacks flexibility for the end user will likely see this sort of freight diversion problem.

Additionally, we hope to see that when the final se t of Phase 2 regulations are announced, there will be detailed cost-benefit analysis that factors in not only the full costs of the various GHG devices both to buy & install and to operate, but also considers various weight penalties to the maximum permissible loads which will result in increased trips. These regulation-induced trips will impose not only a cost in terms of increased costs to operate (e.g. buying /operating more equipment, hiring mo re drivers), and increased fuel consumption/greenhouse gas releases, but will also create societal costs from increased safety risks causedby putting more trucks on the nation’s roads. Every trip carries a statistical risk (that regulators, manufacturers and operators are all trying to keep to a minimum) of so me sort of accident.

We firmly believe that GHG devices must not increase risk to the motoring public.

Conclusion: We believe that marketforces are the best route to a ffect GHG reduction/fuel savings for heavy-duty truck trailers. The role of government in vetting various strategies through programs like the SmartWay program speeds the adoption of these devices by providing an i ndependent review of marketers’ claims. The best way to achieve the President’s directive is to expand the SmartWay program into other trailer designs/usage patterns and monitor adoption rates. By examining adoption rates of various strategies, you can guide the testing and data collection studies and re-evaluate the cost-benefits based on the various challenges facing real-world end users. As the program’s evaluation of prospective savings comes closer to real world conditions, with the appropriate primary variables such as design type and average fleet speed being addressed, end users will be able to accurately specify the best solutions for their particular case. Where there are discove red disconnects between a given technology and usage patterns, they can be subjected to follow up inve stigations and folded into follow-on rulemaking.

We hope you find this information useful and we appr eciate this chance to work with the EPA as you begin to consider regulations aimed at the tr ailer industry.

Sincerely,

John Freiler Engineering Manager
Truck Trailer Manufacturers Association