Verbal Testimony 

Shannon Richardson 

XL Specialized Trailers 

August 9, 2015 

My name is Shannon Richardson, and I'm an engineer for XL Specialized Trailers located in 

Manchester, Iowa. I will start out by disclaiming that even though my comments will pertain to both 

exclusions and adaptions of specific areas of the proposed regulations, in no way should they be 

construed as support for the GHG-Phase II Standards as it applies to the truck trailer industry. Being 

good stewards of our surroundings and maintaining vigilance to our impact on our environment is a high 

priority for us, but we believe it should be through voluntary acceptance of proven technology and 

techniques working with well thought out regulations that will make a positive impact and not through 

generic applied rules that attempts to create a package of "one size fits all". 

XL Specialized Trailers is a small business entity that manufactures custom, built to order heavyhaul low bed, step deck, and flatbed trailers. As such, we do not have a large team of dedicated 

personnel to read, understand, and comment on all aspects of this proposed regulation much less just 

the basic information that only pertains to the truck trailer industry. Basically, I am that team. XL 

Specialized Trailers would like to thank the regulatory agencies for working with Truck Trailer 

Manufacturers Association (TTMA), which XL is a member of, over the past year and a half during the 

agencies initial consideration of this proposal. It is apparent that some of our fingerprints are found 

within the documents. However, this proposed rulemaking is exceptionally involved for our industry 

and to help ensure the best opportunity for comments and assist in the crafting of the proposed 

regulation, XL Specialized Trailers is officially requesting a 90 day minimum, ideally 6 month, extension 

to the now September 17, 2015 deadline for comments period. The TTMA has petitioned EPA to extend 

the comment period beyond the original date of September 11, 2015 and as a member, XL Specialized 

Trailers is in full support of this petition. 

This regulation, as it pertains to the truck trailer industry, proposes to separate trailers into 

ten subcategories. Of these subcategories, I would like to address the area of non-box trailers. More 

specifically, trailers that would "unofficially" be classified as specialized heavy haul trailers. As the 

current proposed regulations are presented, a very small list of exclusions and less-stringent standards 

are laid out. We appreciate the regulatory agencies proposed allowing of this list, but, we ask the 

agencies to also consider a much broader breakdown of specific characteristics of what defines a heavy 

haul trailer. Most of these trailers are not intended nor are they used for over-the-highway long haul 
operations or at highway speeds for extended periods of time. These trailers will operate both on and 

off road, at various speeds, and in various terrains. There are not specific design characteristics that 

indicate that this trailer should operate at low speeds or on a specific type of terrain, but, there are 

physical characteristics that can distinguish heavy haul style trailers from other trailer types. 

Heavy haul style trailers are designed to carry equipment used for construction, agricultural, 

mining, logging, power generation and other industries, specialized loads generally not transported on a 

regular base, high center of gravity loads, and over-sized (length, width, height, and/or weight) loads. 

Generally speaking, the trailer is a tool to move the primary piece of equipment which is then used as 

the primary revenue generator for the end user. Most of these trailers operate in either very small 

fleets of two to three trailers for a single tractor or are owner-operated where requirements for specific 

mandatory design standards for tires and specialty equipment types would cause a larger financial 

burden than the perceived benefit of reduced fuel use. This definition list will be submitted as a written 

comment, and we are asking the agencies to seriously consider this while developing the language for 

this regulation. 

As a small business entity, XL Specialized Trailers must consider the potential burden imposed 

on us by the proposed regulations. Additional pre-production reporting, new compliance and 

equipment labeling, government mandated warranty requirements not normally seen in this industry, 

user manual equipment list requirements, compliance submissions, and record keeping will create 

additional burdens to an already cost sensitive industry. As the proposed regulations are presented, this 

burden will exist whether a company produces a few regulated products or many. 

The truck trailer industry is a very innovative industry that embraces new technologies and 

standards that enhances the efficient operation of our equipment as well as leading to a safer product . • 

Mandating the implementation of this type of regulation across the board creates a counter-productive 

environment that leads to subpar products that end up costing consumers more and not achieving the 

goals set out by the regulator agencies. In closing I would ask the agencies to consider the items 1 have 

presented and will present as written comments during the rule writing phase of this process. 

Thank you for your time and the opportunity to speak during this public hearing. I am able to 

take any questions you may have now and will be available for any questions you should have in the 

future.