UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

NATIONAL VEHICLE AND FUEL EMISSIONS LABORATORY

2000 TRAVERWOOD DRIVE

ANN ARBOR, MI 48105-2498

OFFICE OF

AIR AND RADIATION

July 27, 2015

MEMORANDUM

SUBJECT: Supplemental Heavy-Duty Phase 2 Meeting with Members of the Truck Trailer 

Manufacturers Association Prior to their Joint Industry/Government Meeting

FROM: Jessica Brakora, Engineer, Assessment and Standards Division, Office of 

Transportation and Air Quality

TO: Greenhouse Gas Emissions Standards and Fuel Efficiency Standards for Medium- and 

Heavy-Duty Engines and Vehicles - Phase 2 - Docket EPA-HQ-OAR-2014-0827

This memo documents a meeting held on July 22, 2015 in Alexandria, Virginia between 

representatives of the Truck Trailer Manufacturers Association (TTMA) and EPA to discuss the 

recently-proposed Phase 2 greenhouse gas and fuel efficiency standards for heavy-duty vehicles. 

The meeting was scheduled the morning before TTMA’s annual Joint Industry/Government 

Meeting.

The following TTMA members attended the meeting:

– John Freiler, TTMA

– Jeff Sims, TTMA

– Glen Darbyshire, TTMA

– Andy Grow, East Mfg. Corp.

– Don Moore, CTEA

– John Denson, Fontaine Trailer

– Dan Giles, Fontaine Trailer

– Daniel Carter, Great Dane Trailers

– Charles Fetz, Great Dane Trailers

– Brian Polgrean, Heil Industries (phone)

– Les Jaworski, Hyundai Translead

– YJ Park, Hyundai Translead

– George Gauntt, Kentucky Trailer

– Chris Steinman, MGS Inc.

– Gary Fenton, Stoughton Trailers

– Justin Bell, Strick Trailers

– Jan Hoover, Strick Trailers

– Rupali Patel Shah, Strick Trailers

– Shari Solomon, Strick Trailers

– Sam Guron, Talbert Mfg.

– Jeff Thompson, Timpte

– John Rust, Trail King Industries

– Jeff Bennett, Utility Trailer Mfg. Co.

– Paul McNamara, Utility Trailer Mfg. Co.

– Andrew Cicmanec, VT Hackney

– Mark Ehrlich, Wabash National Corp.

– Kristen Glazner, Wabash National Corp.

– Robert Lane, Wabash National Corp.

– Erin Roth, Wabash National Corp.

– James Scacelli, Wabash National Corp.

– Tim Mahal, Wilson Trailer

– Shannon Richardson, XL Specialized 

Trailer
The following EPA representatives participated in the meeting:

– Jessica Brakora, Assessment and Standards Division

– Tad Wysor, Assessment and Standards Division

– Dennis Johnson, Transportation and Climate Division

– Sam Waltzer, Transportation and Climate Division

– Alan Stout, Assessment and Standards Division (via phone)

David Rostker attended the meeting on behalf of the Small Business Administration, and Coralie 

Cooper, of the Department of Transportation’s Volpe Center, participated via phone on behalf of 

NHTSA.

The meeting included an overview of the proposed HD Phase 2 program presented by EPA. The 

presentation and discussion focused on trailers, technologies, and the proposed standards, test 

procedures, and compliance process. The meeting concluded with EPA presenting a set of 

example CO2 calculations using an Excel worksheet that is available in the docket. 

The slides presented by EPA are attached below. The following materials, available in Docket

EPA-HQ-OAR-2014-0827, were also provided to TTMA for convenience.

– Small Business Advocacy Review Panel, Final Report

– Draft Regulatory Impact Analysis (RIA), Phase 2 Proposed Rule, EPA-420-D15-900

– Memo: Numerical Standards for Tractors, Trailers, and Vocational Vehicles Based on the 

GEM Executable Code; and Derivation of the Numerical Engine Standards

– Memo: Example Compliance Scenarios for Proposed HD Phase 2 Trailer Program

– Memo: Example CO2Emissions Calculations for Box Trailers

– ExampleTrailerCO2EmissionsCalcs.xlsx

– Information Collection Request (ICR), Supporting Statement

– Greenhouse gas Emissions Model (GEM) User Manual, EPA-420-B-15-076

Attachment: 

EPA presentation: “TTMA Industry/Government Meeting”
TTMA 

Industry / Government Meeting

July 22, 2015

Jessica Brakora

U.S. Environmental Protection Agency

brakora.jessica@epa.gov
Status of the Proposal

• NPRM signed June 19, 2015

– Available on EPA and NHTSA websites

• http://www.epa.gov/otaq/climate/regs-heavy-duty.htm

• http://www.nhtsa.gov/fuel-economy

• Published in Federal Register Monday, July 13

• Docket is available on www.regulations.gov

– EPA Docket: EPA–HQ–OAR–2014-0827 

– NHTSA Docket: NHTSA-2014-0132 

7/22/2015 TTMA Joint Industry/Government Meeting 2
Trailer-Specific Documents to Consider

• Small Business Advocacy Review Panel, Final Report

– Outlines recommendations from Panel members as part of EPA’s obligations under the Small 

Business Regulatory Enforcement Flexibility Act (SBREFA) 

– Also see Draft RIA Chapter 12, “Initial Regulatory Flexibility Analysis”

• Draft Regulatory Impact Analysis (RIA), Phase 2 Proposed Rule, EPA-420-D15-900

– Additional analysis behind the proposed HD Phase 2 proposed rule

– See Chapter 1 (Industry Characterization) and Chapter 2.10 (Technology Application and Estimated 

Costs – Trailers)

• Memo: Numerical Standards for Tractors, Trailers, and Vocational Vehicles Based on 

the GEM Executable Code...

– Numerical standards were updated to match results of proposed GEM executable code

• Memo: Example Compliance Scenarios for Proposed HD Phase 2 Trailer Program

– Step through of averaging and non-averaging compliance scenarios

• Memo: Example CO2 Emissions Calculations for Box Trailers

– Instructions for using spreadsheet for calculating estimated CO2 based on production volumes 

– Also see ExampleTrailerCO2EmissionsCalcs.xlsx

• Information Collection Request (ICR), Supporting Statement

– Our preliminary estimates of the reporting burden for the regulated entities

• Greenhouse gas Emissions Model (GEM) User Manual, EPA-420-B-15-076

– May be useful to understand assumptions in the proposed GEM compliance tool; the proposed 

equation for trailer compliance is based on the results of GEM

7/22/2015 TTMA Joint Industry/Government Meeting 3
Providing Feedback

• All meetings and material shared following the NPRM will be 

documented and made public with the FRM

• 60-day comment period from July 13 to September 11

– Written comments are accepted through our dockets, email, or mail 

– FRM will to respond to written comments made in this comment period

• Two public hearings will be scheduled

– Expected to be in Chicago, IL and Los Angeles, CA

– Individuals and organizations can provide comments at this time

– FRM will respond to oral comments made during these hearings 

• We will continue to have meetings and accept feedback as time 

allows until the FRM

– We are not required to consider or respond to comments made outside of 

the comment period

7/22/2015 TTMA Joint Industry/Government Meeting 4
Outline

• Technologies and Trailers in Proposal

• Overview of the Standards

• Test Procedures

• General Compliance

• Averaging, Banking, and Trading

• Example CO2 Calculations

• Summary of Comments Requested

• Areas we are specifically requesting comment

7/22/2015 TTMA Joint Industry/Government Meeting 5
TECHNOLOGIES & TRAILERS 

PROPOSED

7/22/2015 TTMA Joint Industry/Government Meeting 6
Trailers Considered for the Proposal

• We can only certify at the manufacturer-level

• We are proposing two length categories for box 

trailers

– “Short box” trailers are 50 feet or less in length

– “Long box” trailers are longer than 50 feet

• The proposed standards are based on short- and 

long-haul drive cycles

– Short box trailer standards are based on short-haul 

– Long box trailer standards are based on long-haul 

– The proposed regulations do not constrain actual 

trailer use 

7/22/2015 TTMA Joint Industry/Government Meeting 7
Technologies Considered for the Proposal

• Aerodynamics

– Single devices and aerodynamic systems

• Skirts, boat tails, rear fairings underbody, gap reducers

– May include changes to physical characteristics of the trailer

– Measured as reductions in drag, delta CDA (m2)

– Proposing zero-yaw results for certification (more discussion later)

• Lower rolling resistance tires

– Measured as tire rolling resistance level, TRRL (kg/ton)

– Any TRRL value below 6.0 kg/ton is considered LRR

• Same baseline proposed for all trailer subcategories

• Automatic tire inflation systems

– Automatic only; monitoring systems not considered

– Proposed a reduction of 1.5% applied for qualified systems

• Weight reduction

– Substitution of approved light-weight components

– A list of approved components available in the regulations

7/22/2015 TTMA Joint Industry/Government Meeting 8
Technologies Considered for Trailer Types

• Long box dry vans

• Long box refrigerated vans

• Short box dry vans

• Short box refrigerated vans

• Non-box trailers

• “Partial aero” box trailers 

– Work performing device(s) in 

one location on the trailer

• “Non-aero” box trailers

– Work-performing devices in 

multiple locations on the trailer

Aero and Tire Technologies

Tire Technologies Only

7/22/2015 TTMA Joint Industry/Government Meeting 9

Tire Tech and Limited Aero

Tire Technologies Only
What is included in “non-box”

• We are proposing design standards that would require 

LRR tires and ATI systems on all new non-box trailers

– Tank

– Platform

– Container chassis

– Dry bulk commodity

– Curtainside

– Chip/Biomass/Refuse/Dump

– Etc.

• While some of these trailers may spend time “off-road” 

we could not identify any design characteristics at the 

manufacturer level that could be used to distinguish 

them as exclusively “off-road” vs. those that travel onhighway

7/22/2015 TTMA Joint Industry/Government Meeting 10
• Trailers produced before January 1, 2018

• Trailers not designed to be pulled by a 

tractor

• Shipping containers

• Trailers designed for mining, logging, and 

livestock

• Heavy-haul trailers, defined as

– Long trailers (≥35’) with 4 or more axles

– Short trailers (<35’) with 3 axles

• Trailers designed to be stationary

– Expandable/display

– Office spaces

– Carnival trailers

– Mobile homes

– Crane trailers

Proposed Trailer Exclusions

7/22/2015 TTMA Joint Industry/Government Meeting 11
What criteria identify exclusions?

• Are they built in the timeframe of the proposed rulemaking?

• Are they pulled by a Class 7 or 8 tractor?

• Would the proposed technologies interfere with their work 

function?

– Used off-road where rocks, logs, etc may damage the devices

• Would their use patterns limit the benefits of the proposed 

technologies?

– Designed to haul very heavy loads

– Main function of the trailer is performed when stationary

– Exclusively used off-road in forests, work sites and fields *

– Limited time at high speeds *

– Limited distance of travel *

7/22/2015 TTMA Joint Industry/Government Meeting 12

* It is difficult to identify 

physical characteristics

linking to these use patterns
OVERVIEW OF STANDARDS

7/22/2015 TTMA Joint Industry/Government Meeting 13
Summary of the Proposed Trailer Standards

• Full implementation by MY 2027

– Equation-based performance standards

• Highest aero and tire stringencies for long-box dry and refrigerated vans

• Aero and tire stringencies for short-box dry and refrigerated vans

• Partial aero box trailers could have reduced standards starting in MY 

2027

– Design-based standards

• Non-aero box trailer standards based on tire technologies only 

• Non-box trailer standards based on tire technologies only 

• Proposing progressive performance standards in 3-year 

stages (full- and partial aero box trailers)

• Proposing two stages for the design-based standards (nonbox and non-aero box trailers)

• Over 10 years lead time to become familiar with technologies 

and compliance process

7/22/2015 TTMA Joint Industry/Government Meeting 14
Proposed Standards for Trailers

Subcategory 2018-2020 2021-2023 2024-2026 2027+

Long Dry Van

82 81 79

77

Partial-Aero Long Dry Van 79

Long Refrigerated Van

84 82 80

79

Partial-Aero Long Refrigerated Van 80

Short Dry Van

143 142 140

139

Partial-Aero Short Dry Van 140

Short Refrigerated Van

147 145 144

143

Partial-Aero Short Refrigerated Van 144

7/22/2015 TTMA Joint Industry/Government Meeting 15

From Table 3 of Memo to Docket “Numerical Standards for Tractors, Trailers...” *

* Update to values in Table 1 of § 1037.107— Phase 2 CO2 Standards for Trailers (g/ton-mile)

• § 1037.107(a)(3) Partial-aero trailers may continue to meet the 2024 

standards in 2027 and later model years

• § 1037.107(a)(4) Non-box trailers and non-aero trailers must meet standards 

as follows

– (i) Trailers must use qualified automatic tire inflation systems with wheels on all axles

– (ii) Trailers must use tires with a TRRL at or below 4.7 kg/ton. Through model year 

2023, trailers may instead use tires with a TRRL at or below 5.1 kg/ton
How do you qualify for reduced aero?

Rear features Side features

• Rear lift gate

• Rear hinged ramp

• Side lift gate

• Belly box

• Side-mounted pull-out 

platform

• Steps for side-door access

• Drop-deck design

• § 1037.107(a)(1)(i) Non-Aero Trailers

– All box vans 35’+: Have a rear feature and at least one side feature

– Refrigerated box vans <35’: at least one side feature

– Dry box vans <35’ would not qualify for non-aero status

• We do not know of any work-performing devices that restrict the front of the 

trailer

• § 1037.107(a)(1)(ii) Partial-aero trailers

– All box vans that have at least one of the side feature

– Long box vans that have a rear feature

7/22/2015 TTMA Joint Industry/Government Meeting 16
ADDITIONAL CONSIDERATIONS

7/22/2015 TTMA Joint Industry/Government Meeting 17
Time Periods to Note

7/22/2015 TTMA Joint Industry/Government Meeting 18

• Useful Life

– § 1037.801 Definitions: The period during which a vehicle is 

required to comply with all applicable emission standards

– § 1037.107(c): 10 years for trailers

– Manufacturer held responsible for design, not use

• Emissions-related warranty

– § 1037.120 Emission-related warranty requirements: Warrant 

that it meets the standards and is free of defects

• Trailer (including components): 5 years

• Trailer Tires: 1 year

– Not required to warrant against all damage

• Reporting and Recordkeeping

– § 1037.250(c) Retain records for 8 years after we issue your 

certificate
Modifying the Vehicle Post-Sale

• § 1037.120 (d) Limited applicability. 

– You may deny warranty claims under this section if the operator caused 

the problem through improper maintenance or use, as described in §

1068.115

• § 1037.120 (e) Owner’s Manual

– Include emission-related warranty provisions that apply to the trailer

– Include sufficient information for the owner to replace tires with those 

that meet or exceed the rolling resistance performance of the original 

equipment tires

• § 1037.655 Post-useful life vehicle modifications

– (b) Allowable modifications: You may modify to reduce emissions if you 

have a reasonable technical basis

– (c)(2) Example: Other fairings may be removed after the end of the 

vehicle’s useful life if the vehicle will no longer be used significantly on 

highways with vehicle speed of 55 miles per hour or higher.

7/22/2015 TTMA Joint Industry/Government Meeting 19
Labeling

• § 1037.135 Labeling

– (b) A permanent, legible label

• One piece, not removable, durable for life of 

vehicle

• Secured to a location not normally requiring 

replacement

– (c) Label requirements

• (6) Identify emission control system

• Appendix III to Part 1037

– Emission Control Identifiers for technologies 

installed on trailers

7/22/2015 TTMA Joint Industry/Government Meeting 20
TEST PROCEDURES

7/22/2015 TTMA Joint Industry/Government Meeting 21
How Do We Measure CO2 and Fuel 

Consumption of a Trailer?

• Trailers are integral part of a tractor-trailer vehicle

• We do not require full-vehicle compliance testing 

to measure CO2 and fuel consumption

• EPA created the Greenhouse gas Emissions 

Model (GEM) to simulate heavy-duty vehicles for 

compliance

• We are proposing an equation, based on GEM, 

for trailer manufacturers to use to determine 

compliance

7/22/2015 TTMA Joint Industry/Government Meeting 22
Four Trailer Inputs for Equation

• Drag Area, Delta CDA

– Result of aerodynamic testing compared to a conventional trailer (Phase 

1 standard trailer, § 1037.501(g)(1))

• Performed by the manufacturer or a contractor

• Performed by aero device manufacturer and results pre-approved by 

EPA/NHTSA

• Tire Rolling Resistance Level, TRRL

– Result of rolling resistance testing

– Generally obtained from tire manufacturer

• ATI

– If you have a qualified system, GEM provides a fixed reduction 

(proposed 1.5%)

• Weight Reduction

– List of components that have light-weight options

• Components must be applicable to all box trailers

• Components must not be commonly adopted already

– Open to other weight reduction options

7/22/2015 TTMA Joint Industry/Government Meeting 23
Aero Testing for Delta CDA

• Approved procedures 

– Wind tunnel

– Coastdown (also proposing constant speed)

– CFD

• We are proposing an A to B test strategy for trailers 

– Can measure delta CDA for components or whole 

trailer

• Expect most manufacturers will apply devices to their trailers 

• Baseline is always a conventional trailer without aerodynamic 

devices. See § 1037.501(g)(1)

– Provides a change in performance similar to 

SmartWay program

– Allows the option of pre-approving device performance

7/22/2015 TTMA Joint Industry/Government Meeting 24
Pre-Approved Test Data for Certification

• § 1037.211 Pre-approval for manufacturers of aero devices

– Aero device manufacturers can test their devices on a standard trailer

– Device manufacturers can submit their results to EPA for pre-approval

– Results can be pre-approved for single devices or systems of devices

– Must use Phase 2 test procedures that measure CDA

• § 1037.150(n) SmartWay 2014 Protocol procedures - OK before MY 2018

• § 1037.525 Phase 2 test procedures – OK throughout proposed program

– Trailer manufactures can adopt pre-approved devices on their trailers 

and use the device manufacturer’s results for certification under §

1037.515 

• If tested as a system, may use pre-approved DCDA for the same combination of 

devices installed on trailers

• If tested separately, may combine pre-approved delta CDA values for individual 

aero devices as follows:

– Composite DCDA = Largest DCDA + 0.9(second-largest DCDA) + 0.8(all other DCDAs) 

– Devices cannot significantly impair the effectiveness of another, consistent with good 

engineering judgment (no skirt + underbody device)

7/22/2015 TTMA Joint Industry/Government Meeting 25
SmartWay-Verified Aero Technologies

• SmartWay-verified devices are not automatically approved for 

use in the proposed regulations

• § 1037.150(n) Interim provisions.

– Prior to January 1, 2018

• Manufacturers of aero devices may ask for preliminary approval of test 

results for their devices previously verified under SmartWay

– Test results must be based on measured CDA values

– Verification test may differ from the Phase 2 test procedures

– From MY 2018 through MY 2020

• Trailer manufacturers may certify their trailers using pre-approved test 

data from SmartWay-verified devices

• Device manufacturers seeking pre-approval would use the Phase 2 test 

procedures

– For MY 2021 and beyond

• All aero devices must be tested using Phase 2 test procedures (§

1037.525) for pre-approval

• Devices previously approved using SmartWay-verified devices must 

resubmit test data for pre-approval

7/22/2015 TTMA Joint Industry/Government Meeting 26
Note on Wind-Averaged Drag Results

• Approved procedures 

– Wind tunnel

– Coastdown 

– Constant speed

– CFD

• Proposing only to accept zero-yaw test results

– Want to maintain consistency with test methods that have 

wind restrictions

– Want to continue to allow all test methods without requiring 

a “reference test” (additional testing) to establish a 

baseline

– Are requesting comment and data supporting the use of 

wind-averaged results and suggestions of ways to 

continue use of all test methods

7/22/2015 TTMA Joint Industry/Government Meeting 27

Can easily provide wind-averaged results
Bins for Aero Testing Results

• We want to maintain consistency in manufacturers’ test 

results

• We established bins, based on EPA’s aero testing, that 

account for variability due to 

– Test method

– Trailer manufacturer

– Tractor manufacturer

– Device type

– Device manufacturer

7/22/2015 TTMA Joint Industry/Government Meeting 28

If a trailer’s measured delta CDA is ... designated the trailer as ... and use the following values for delta CDA

< 0.09 Bin I 0.0

0.10 - 0.19 Bin II 0.1

0.20 - 0.39 Bin III 0.3

0.40 – 0.59 Bin IV 0.5

0.60 – 0.79 Bin V 0.7

0.80 – 1.19 Bin VI 1.0

1.20 – 1.59 Bin VII 1.4

>1.60 Bin VIII 1.8

Table 2 of § 1037.515—Bin determinations for Trailers Based on Aerodynamic Test Results (delta CDA in m2)
Performance Measures

7/22/2015 TTMA Joint Industry/Government Meeting 29

Aerodynamics (Delta CDA, m2)

Bin I 0.0

Manufacturers 

use bin values 

for compliance

Bin II 0.1

Bin III 0.3

Bin IV 0.5

Bin V 0.7

Bin VI 1.0

Bin VII 1.4

Bin VIII 1.8

Tire Rolling Resistance (CRR, kg/ton)

Tire Baseline 6.0 Manufacturers 

use any TRRL

value from tire 

manufacturer

Tire Level 1 5.1

Tire Level 2 4.7

Tire Inflation System (% reduction)

ATI System 1.5 Qualifying 

systems

Weight Reduction (lbs)

Weight1 Weight assigned to 

specific components

Manufacturers

use weight 

from table

Tire Type Material

Weight

Reduction

(lb) 

Wide-Based Single

Steel Wheel 84

Aluminum Wheel 139

Light-Weight Aluminum Alloy Wheel 147

Dual-Wide

High-Strength Steel Wheel 8

Aluminum Wheel 21

Light-Weight Aluminum Alloy Wheel 30

Component Material

Weight

Reduction

(lb)

Suspension Assembly1 Aluminum 280

Hub and Drum (per axle) Aluminum 80

Floor Aluminum 375

Floor Composite 245

Floor Crossmembers Aluminum 203

Landing Gear Aluminum 50

Rear Door Aluminum 187

Rear Door Surround Aluminum 150

Roof Bows Aluminum 100

Side Posts Aluminum 300

Slider Box Aluminum 150

Upper Coupler Assembly Aluminum 430

1 For tandem-axle suspension sub-frames made of aluminum, apply a weight 

reduction of 280 pounds. Use good engineering judgment to estimate a weight 

reduction for using aluminum sub-frames with other axle configurations.

1 1/3 added to payload, 2/3 reduces overall vehicle weight

Table 3 of § 1037.515—Weight Reductions for Trailers (pounds)

Table 7 of § 1037.520—Wheel-Related Weight Reductions
Proposed Equation for Trailer Compliance

7/22/2015 TTMA Joint Industry/Government Meeting 30

       CO2 C1 C2 TRRL C3 ΔCDA C4 WR C5        

Subcategory C1 C2 C3 C4

Long Dry Van 77.1 1.7 -6.1 -0.0011

Long Refrigerated Van 78.0 1.8 -6.0 -0.0011

Short Dry Van 133.4 2.2 -10.2 -0.0031

Short Refrigerated Van 136.0 2.4 -10.1 -0.0031

From Table 2 of Memo to Docket “Numerical Standards for Tractors, Trailers...” *

* Update to values in Table 1 of § 1037.515— Regression Coefficients for Calculating CO2 Emissions

From § 1037.515 Determining CO2 emissions to show compliance for trailers.

(a) * * *

Let C5 = 0.985 for trailers that have automatic tire inflation systems with all wheels; 

otherwise, let C5 = 1.

* * * 
Proposed Equation for Trailer Compliance

7/22/2015 TTMA Joint Industry/Government Meeting 31

       CO2 C1 C2 TRRL C3 ΔCDA C4 WR C5

CO

       

2

1. Calculate fuel consumption;

2. Submit results to Agencies for 

each trailer family 

3. Obtain certificate of conformity 

prior to production

From Tire 

Manufacturer’s

CRR Testing

From Aerodynamic Testing 

Manufacturer’s Testing or

Pre-Approved Test Data

Reduction 

Applied if 

ATI Installed

From List of 

Light-Weight 

Components
GENERAL COMPLIANCE

7/22/2015 TTMA Joint Industry/Government Meeting 32
Families

• Families are groups of similar vehicles 

with the same standards

• There are five general trailer 

subcategories > five families

1. Long box dry vans

2. Long box refrigerated vans

3. Short box dry vans

4. Short box refrigerated vans

5. Non-box trailers

7/22/2015 TTMA Joint Industry/Government Meeting 33
Families (cont.)

• We are proposing to allow manufacturers to combine 

families if they would like to reduce the number of 

families

• All trailers in that family are subject to the same 

standard

7/22/2015 TTMA Joint Industry/Government Meeting 34

1. Long box dry vans

Long box refrigerated vans

2. Short box dry vans

Short box refrigerated vans

3. Non-box trailers

1. Long box dry vans

Long box refrigerated vans

Short box dry vans

Short box refrigerated vans

2. Non-box trailers
Families (cont.)

Manufacturers who wish to take advantage of 

reduced standards in the later years may have more 

families

1. Long box dry vans

2. Long box refrigerated vans

3. Short box dry vans

4. Short box refrigerated vans

5. Non-box trailers

6. Partial-aero long box dry van

7. Partial-aero long box refrigerated van

8. Partial-aero short box dry van

9. Non-aero box van (all sizes)

7/22/2015 TTMA Joint Industry/Government Meeting 35
Compliance Steps

• Preliminary steps

– Identify families

– Determine technologies to offer customers

– Test for or obtain inputs for GEM-based equation

• Certification application (prior to production)

– Submit ONE application for each family

– Describe technologies used in family

– Include results for worst case and highest production 

trailers

• End-of-year reports

– Submit a production report for each family

– Submit an ABT report if you do averaging (described next)

7/22/2015 TTMA Joint Industry/Government Meeting 36
AVERAGING, BANKING, TRADING

7/22/2015 TTMA Joint Industry/Government Meeting 37
Averaging, Banking and Trading (ABT)

• Averaging

– Average within a family based on production

– Over-compliant trailers make up for under-compliant trailers

• Banking

– End-of-year credits (from over-compliance) or deficits (from undercompliance) can be carried over to the following year

• Trading

– End-of-year credits can be sold to other manufacturers who have deficits

• We are proposing that full-aero box trailers can average within a 

single model year 

– Credits cannot be banked or traded

– Deficits can be carried-over for up to 3 years

• We are not proposing averaging for non-box trailers, or partial- and 

non-aero box trailers

– A large fraction of non-box trailer manufacturers are small businesses, 

which we believe would be at a disproportionate disadvantage in an 

averaging program

– Partial-aero and non-aero options for box trailers are flexibilities that reduce 

the requirements

7/22/2015 TTMA Joint Industry/Government Meeting 38
Summary of Compliance Options

• Certification with averaging 

– All trailers within a family meet the standard on average

– Maximum flexibility for customers

– Maximum compliance requirements for manufacturer

• Certification without averaging

– All trailers produced to meet the standard

– Maintains some flexibility for customers

– Fewer compliance requirements for manufacturer

• Design-based certification

– All trailers adopt a minimum set of technologies

– Minimum flexibility for customers

– Minimum compliance requirements for manufacturer

7/22/2015 TTMA Joint Industry/Government Meeting 39
COMMENTS REQUESTED

7/22/2015 TTMA Joint Industry/Government Meeting 40
Seek Comment on...

• Regulations that may conflict

• Lead time proposed and lead time needed for proposed stringencies

• Current and projected market penetration of technologies

• Advantages and disadvantages of Averaging, Banking, and Trading

• Distinction between “long box” and “short box” trailers (currently 50’ cut-point)

• Trailers excluded

– Other physical characteristics that distinguish heavy-haul or off-road trailers

– Exempt or exclude for these trailers

• Data related to technology effectiveness

• Feasibility of proposed alternatives

• TRUs: capacity, leak rate, possible regs

• Reduced requirements for non-box, partial and non-aero box trailers

• Rolling resistance baseline of 6.0 kg/ton for all trailer types

• Data to supplement or suggest changes to aerodynamic bins

• Additional weight reduction component substitution options

• Specs of standard tractor for modeling and testing

• Zero-yaw option for compliance testing

• Flexibilities and compliance options

– Design-based certification

– Pre-approved devices

– Pre-approval of SmartWay devices

– Additional 1yr lead-time for small businesses

• Equation proposed to combine pre-approved devices

7/22/2015 TTMA Joint Industry/Government Meeting 41
EXAMPLE CO2 CALCULATIONS 

Spreadsheet will be available in the Docket

7/22/2015 TTMA Joint Industry/Government Meeting 42
See file: ExampleTrailerCO2EmissionsCalcs.xlsx

7/22/2015 TTMA Joint Industry/Government Meeting 43
QUESTIONS?

Jessica Brakora Tad Wysor Coralie Cooper

brakora.Jessica@epa.gov wysor.tad@epa.gov coralie.cooper@dot.gov 

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EXTRA SLIDES IF NEEDED

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Definition of model year

• 40 CFR 1037.801 

– “Model year means the manufacturer’s annual new model 

production period, except as restricted under this definition and 

40 CFR part 85, subpart X. It must include January 1 of the 

calendar year for which the model year is named, may not begin 

before January 2 of the previous calendar year, and it must end 

by December 31 of the named calendar year.”

• 40 CFR 85 subpart X: 

– Definition of model year. Model year means the 

manufacturer's annual production period (as determined under 

§85.2304) which includes January 1 of such calendar year, 

provided, that if the manufacturer has no annual production 

period, the term “model year” shall mean the calendar year.

– Duration of model year. A specific model year must always 

include January 1 of the calendar year for which it is designated 

and may not include a January 1 of any other calendar year. 

Thus, the maximum duration of a model year is one calendar 

year plus 364 days.

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EPA’s Handling of 

Confidential Business Information (CBI)

Any sensitive information sent to our office would be protected under the federal requirements of the confidential business 

information (CBI) provisions, if it is marked as such. We have controls in place to properly handle any CBI shared by 

companies. In some cases, release of some information may be justified or required, but only pursuant to the regulations at 

40 CFR part 2. The link below is for the electronic Code of Federal Regulations with all the details on how we handle CBI. 

http://www.ecfr.gov/cgi-bin/text-idx?SID=7199a8eb4e6113ccc8ffaf81560e66ca&tpl=/ecfrbrowse/Title40/40cfr2_main_02.tpl

When we publish proposed rules, we always include clear guidelines on how to submit CBI to EPA. Below is an excerpt of the 

guidelines that were included when we proposed the HD GHG Phase 1 rule in 2011: 

All comments received will be included in the public docket without change and may be made available online at 

www.regulations.gov, including any personal information provided, unless the comment includes information claimed to be 

Confidential Business Information (CBI) or other information whose disclosure is restricted by statute. Any CBI submitted to 

one of the agencies will also be available to the other agency. 

This statement constitutes notice to commenters pursuant to 40 CFR 2.209(c) that EPA will share confidential business 

information received with NHTSA unless commenters expressly specify that they wish to submit their CBI only to EPA and not 

to both agencies. However, as with all public comments, any CBI information only needs to be submitted to either one of the 

agencies’ dockets and it will be available to the other. Following are specific instructions for submitting CBI to either agency. 

Clearly mark the part or all of the information that you claim to be CBI. For CBI in a disk or CD-ROM that you mail to EPA, 

mark the outside of the disk or CD-ROM as CBI and then identify electronically within the disk or CD-ROM the specific 

information that is claimed as CBI. In addition to one complete version of the comment that includes information claimed as 

CBI, a copy of the comment that does not contain the information claimed as CBI must be submitted for inclusion in the public

docket. Information so marked will not be disclosed except in accordance with procedures set forth in 40 CFR part 2. 

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EPA’s Regulatory Definition of 

Good Engineering Judgment

§1068.30 What definitions apply to this part?

Good engineering judgment means judgments made consistent with generally accepted scientific and 

engineering principles and all available relevant information. 

§1068.5 How must manufacturers apply good engineering judgment?

(a) You must use good engineering judgment for decisions related to any requirements under this chapter. 

This includes your applications for certification, any testing you do to show that your certification, productionline, and in-use engines/equipment comply with requirements that apply to them, and how you select, 

categorize, determine, and apply these requirements.

(b) If we send you a written request, you must give us a written description of the engineering judgment in 

question. Respond within 15 working days of receiving our request unless we allow more time.

(c) We may reject your decision if it is not based on good engineering judgment or is otherwise inconsistent 

with the requirements that apply, based on the following provisions:

(1) We may suspend, revoke, or void a certificate of conformity if we determine you deliberately used 

incorrect information or overlooked important information, that you did not decide in good faith, or that your 

decision was not rational.

(2) If we believe a different decision would better reflect good engineering judgment, but none of the 

provisions of paragraph (c)(1) of this section apply, we will tell you of our concern (and its basis). You will have 

30 days to respond to our concerns, or more time if we agree that you need it to generate more information. 

After considering your information, we will give you a final ruling. If we conclude that you did not use good 

engineering judgment, we may reject your decision and apply the new ruling to similar situations as soon as 

possible.

(d) We will tell you in writing of the conclusions we reach under paragraph (c) of this section and explain our 

reasons for them.

(e) If you disagree with our conclusions, you may file a request for a hearing with the Designated Compliance 

Officer as described in subpart G of this part. In your request, specify your objections, include data or 

supporting analysis, and get your authorized representative's signature. If we agree that your request raises a 

substantial factual issue, we will hold the hearing according to subpart F of this part.

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GHG Regulation Writing

GHG Implementation

Voluntary GHG Program