Verbal Testimony Shannon Richardson XL Speciali ze d Trailers August 9, 2015
My name is Shannon Richardson, and I' m an enginee r for XL Specialized Trailers located in Mancheste r, Iowa. I will s t art out by di sclaim in g that eve n though my co mments 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 steward s of o ur su rro und ings and maintaining vi g ilan ce to our i m pact on ou r 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 regula tions that will make a positive impact and not through gene ri c app li ed 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 heavyhau l low bed, step deck, and flatbed trailers

. As such, we do not have a large team of dedicated personne l to read, understa nd, and comment on all aspects of this proposed re g ulation much less just the basic information that only pertains to the truck trailer industry. Basically, I am that team

. XL Specialized Trailers would li ke to thank the regulatory agencies for working with Truck Trailer Manufacturers As soc iat ion (TTMA) , which XL is a member of , over the past year and a half during the agencies initial conside ration 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 t he best oppo rtunity for comments and ass ist in the crafti ng of the proposed regu lation, XL Specialized Trailers is officially request i ng a 90 day minimum , ideally 6 month, extens ion to the now September 17, 2015 deadline for commen ts period. The TTMA has petitioned EPA to extend the co mment period beyond the origina l date of Sept ember 11, 2015 and as a member, XL Specialized Trailers is in full support of thi s petition. This regulation, as it pertains to the truck trailer industry, proposes to separate trailers into ten subcategori es. Of th ese subcatego ri es, I wou ld like to add re ss th e area of non -box tra il ers. More specifica lly, trailers t hat would "u nofficially" 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 app rec iate the regulatory agencies proposed allowing of this list, bu t , we ask the agencies to also consider a much broader breakdown of specific characteristics of what defin es a heavy haul trailer. Most of these trailers are not intended nor are they used for over-the -highway long hauloperations 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 characterist ics 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, specia l ized loads generally not transported on a regular base, high center of gravity loads, and over-sized (length, width, height, and/or weight) loads. Generally speaki ng, 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 l ist wi ll 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 Trai l ers must consider the potential burden imposed on us by the proposed regulations. Additional pre -production reporting, new compliance and equipment labe l ing, government mandated warranty requirements not normally seen in this industry, user manua l equipment list requirements , compliance submissions, and record keeping will create additiona l burdens to an already cost sensitive industry. As the proposed regu lations 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 standa rds that enhances the efficien t operation of our eq u i pment as well as leading to a safer produ ct

. 

## • Mandating the implementation of this type of reg ulation across the board creates a counter-productive env ironment that l eads to subpar products that end up costing consumers more and not ac hi evi ng th e goa ls set out by the regulator agencies. In closing I would ask the agencies to cons id e r the items 1have presented and will prese nt as written comments during the ru l e writing phase of this process. Thank you for your tim e and the opportun ity 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.