By: David Bradley
Last year saw the coming into force of the first ever fuel economy/GHG reduction standards for heavy trucks in North America. The Canadian rules, introduced by Environment Canada, mirrored those developed and introduced in the United States by the Environmental Protection Agency. As indicated at the time, the EPA viewed these as only the first phase. It was not clear whether Canada would follow suit.
On October 4th, 2014, a Notice of Intent was published in the Canada Gazette, Part I indicating Canada’s intent to develop a second phase of GHG regulations for post-2018 model years that would be “consistent with the approach taken with current regulations for GHG emissions from heavy-duty vehicles and engines … and would be aligned with those that the United States Environmental Protection Agency are currently developing.”
While perhaps Canada could get away with simply mirroring the EPA rules in Phase 1, that won’t work in Phase 2. (A Notice of Proposed Rulemaking for Phase 2 of the EPA rules has been forwarded to the Office of Management and Budget for formal review and is slated to be published in the Federal Register in June).
It’s not that we oppose GHG standards for heavy trucks. We don’t. The Canadian trucking industry is known worldwide as a leader in fuel consumption/GHG reduction. We also support regulatory harmonization or alignment with the United States – where it makes sense to do so. Those are not at issue.
What is at issue is that the Phase 2 standards will look not just at the power unit, but at the entire tractor-trailer combination and the heavy vehicle fleet serving the US economy is very different from that which serves the Canadian economy.
When implemented, the new rule will set more requirements for suppliers of heavy trucks, engines, and trailer manufacturers to sell certain technologies to their customers. These technologies will produce annual credits for suppliers which will measure their level of compliance with the new GHG rule. This will have enormous implications for how fleets ‘spec their equipment.
The US fleet is basically standardized around one configuration – the 80,000 pound tandem-tandem tractor-semitrailer combination. On the other hand, in Canada a vast array of much more productive, efficient and innovative axle configurations, trailer body styles, and higher allowable weights are also allowed and in operation.
Vehicle weights and dimensions standards in Canada are governed by the provinces and territories. A national Memorandum of Understanding sets minimum standards for vehicle configurations that are able to operate coast-to-coast-to-coast and in doing so tries to maximize productivity within infrastructure and safety constraints. However, MOU configurations and weights are not recognized by US law and have not been considered by the EPA.
In addition, a host of configurations not included in the MOU exist that have been designed to support provincial/regional supply chains. These too will not be considered by EPA. Nor do we believe the EPA will give sufficient thought to winter conditions.
CTA recently hosted a symposium on these issues which for the first time brought together Canadian motor carriers, representatives of US carriers and truck, engine and trailer OEMs. One of the conclusions from that session was that CTA’s concerns are valid and legitimate. We are now building on this process working with the provincial associations to hold a series of workshops across the country with fleet personnel responsible for equipment ‘specing and suppliers to drill down further.
Failure to address this matter could limit the types of equipment that can be sold legally in Canada after 2018, reducing carriers’ ability to service the Canadian supply chain within existing business models. This could result in existing proven technologies being overlooked by technologies and others that are not real life tested to meet the needs of the Canadian trucking industry being pushed onto carriers.
As I was putting the finishing touches on this piece the media was reporting that the Prime Minister had indicated the “lock-step” approach to GHG emissions with the United States is about to end. Let’s hope that thinking applies in this case.