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 Emis sions Standards and Fuel Efficiency Standards for Medium - and Heavy - Duty Engines and Vehicles - Phase 2 - Docket EPA - HQ - OAR - 2014 - 0827 This me mo documents a meeting held on July 22, 2015 in Alexandria, Virginia between representatives of the Truck Traile r Manufacturers Association (TTMA) an d 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 f ollowing 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, Grea t 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 Trai lers – 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 TrailerTh e following E PA representatives participated in the meeting:

– Jessica Brakora, A ssessment and Standards Division

– Tad Wysor, Assessment and Standards Division

– Dennis Johnson, T ransportation and C limate D ivision

– S am Waltzer, Transportation and Climate Divisio n

– 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 NHTS A. 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 E PA presenting a set of example CO 2 calculations using an Excel worksheet that is available in the docket. The slides presented by EPA are attached below. The followi ng materials, available in D ocket 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), Supp orting 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 CO 2 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 CO 2 

# 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 6 TTMA Joint Industry/Government Meeting

# 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 7 TTMA Joint Industry/Government Meeting

# 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 C D 

### A (m 2 

### )

– 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 8 TTMA Joint Industry/Government Meeting

# 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 9 TTMA Joint Industry/Government Meeting



## 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 on highway 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 13 TTMA Joint Industry/Government Meeting

# 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 (non box 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 CO 2 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 a ero?

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 21 TTMA Joint Industry/Government Meeting

# How Do We Measure CO 2 

# 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 CO 2 

# 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 22 TTMA Joint Industry/Government Meeting

# Four Trailer Inputs for Equation
• Drag Area, Delta C D 

## A

– 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 23 TTMA Joint Industry/Government Meeting

# Aero Testing for Delta C D 

# A • Approved procedures

– Wind tunnel

– Coastdown (also proposing constant speed)

– CFD 

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

– Can measure delta C D 

# A 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 C D 

### A • § 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 D C D A for the same combination of devices installed on trailers • If tested separately, may combine pre - approved delta C D A values for individual aero devices as follows:

– Composite D C D A = Largest D C D A + 0.9(second - largest D C D A) + 0.8(all other D C D As)

– 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 C D A 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 C D A is ... designated the trailer as ... and use the following values for delta C D A

< 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 C D A in m 2 )

# Performance Measures

7/22/2015 TTMA Joint Industry/Government Meeting 29 Aerodynamics (Delta C D A, m 2 ) 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 (C RR , 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) Weight 1 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 Assembly 1 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 

### Subcategory C 1 

### C 2 

### C 3 

### C 4 

### 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 CO 2 Emissions 

### From § 1037.515 Determining CO 2 

### emissions to show compliance for trailers. (a) * * * 

### Let C 5 

### = 0.985 for trailers that have automatic tire inflation systems with all wheels; otherwise, let C 5 

### = 1 . * * *

# Proposed Equation for Trailer Compliance

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

# 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 C RR 

### 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 32 TTMA Joint Industry/Government Meeting

# 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 33 TTMA Joint Industry/Government Meeting

# 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 37 TTMA Joint Industry/Government Meeting

# 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 under compliance) 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 38 TTMA Joint Industry/Government Meeting

# 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 39 TTMA Joint Industry/Government Meeting

# COMMENTS REQUESTED

7/22/2015 40 TTMA Joint Industry/Government Meeting

# 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 41 TTMA Joint Industry/Government Meeting

# EXAMPLE CO 2 

# 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
7/22/2015 TTMA Joint Industry/Government Meeting 44

# EXTRA SLIDES IF NEEDED

7/22/2015 TTMA Joint Industry/Government Meeting 45

# 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. 7/22/2015 46 TTMA Joint Industry/Government Meeting

# 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 agenc y. 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. 7/22/2015 TTMA Joint Industry/Government Meeting 47

# 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, production line, 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. 7/22/2015 TTMA Joint Industry/Government Meeting 487/22/2015 TTMA Joint Industry/Government Meeting 49 

### GHG Regulation Writing 

### GHG Implementation Voluntary GHG Program