For the most part, truck and trailer manufacturers and stakeholders who submitted comments on the next round of fuel economy and emissions regulations generally support the overall goals of the proposal, but many clearly see major flaws in it. One manufacturer called the proposal “unworkable” as it’s currently written.”
The proposed standards would begin in model year 2018 for trailers and 2021 for tractors and culminate in vehicle-wide — engine, truck and trailer — standards for model year 2027 vehicles.
CCJ magazine summarized a collection of comments submitted to the EPA during the comment period by truck, trailer and engine manufacturers, trucking associations and carriers:
The American Trucking Associations said the market penetration rates estimated by EPA for the new technologies required under the proposed rule are “overly aggressive,” and that OEMs “will be facing an uphill battle from the start in meeting their targets.”
For their part, manufacturers appeared to concur. To expedite market penetration, Paccar said the EPA and NHTSA should provide credits for advanced/innovative technologies. The company said it believes the “concept of credits helps promote innovation by incentivizing manufacturers to go beyond traditional research, development and marketing programs.”
Some technologies Paccar suggests giving credits for include speed limiters, B-20 capability, tire pressure monitoring, hybrid technology multipliers, rear axle efficiency, transmission efficiency and more.
Navistar said it has “significant concerns” with the proposed Phase 2 rules. It said if changes aren’t made to the proposed rule, it “would not only cause disruption and heavy costs to the industry, but would also actually set back the goal of environmental improvements.”
The company there is a significant risk that the industry will be in nearly continuous development from 2019 through 2027, resulting in “complexity” and “added costs” and added equipment downtime.
For the rule to work, Daimler Trucks said the agencies have to resolve problems with aerodynamic test procedures. The “problems make the agencies’ proposed standards impossible.”
Volvo said it feels the rule as currently written, is “unworkable,” but supports the overall goal of it. The company said it believes there could be potential problems that won’t surface until the regulations are fully implemented, and that it’s important that the regulations “deliver the expected in-use performance.”
“Because of the strong financial impact of fuel efficiency on commercial fleet operations, the actual results of efficiency regulation will be closely measured and monitored by fleet owners. If the required technologies do not deliver expected fuel savings at an affordable cost, or result in excessive maintenance and down-time, fleets will not purchase vehicles. Instead, they will repair and rebuild their existing vehicles as they have increasingly done, due to costs and operational problems from recent emissions technologies.”
Several trailer manufacturers echoed many of the sentiments on their tractor counterparts, saying they support the use of these technologies to save fuel and reduce emissions. But they too warned that real world savings would not keep pace with the added costs of pushing the regulatory schedule too quickly without incentives.
Click here for the full summary of comments.
The agencies will consider the comments. EPA has already stated the proposal is a work in progress and it would have to alter its “roadmap” of the rules.
In Canada, meanwhile, CTA is working with regulators to try and ensure that equipment imported into Canada is ready and proven to operate in specific Canadian marketplaces, such as withstanding our extreme weather conditions and operating conditions.
CTA staff travelled across Canada this fall to gather carriers’ opinions and concerns regarding Phase 2 and how they think governments should treat the Canadian version of the regulations.
CTA will soon release a position paper that reflects the Canadian industry’s preferred technological approach to truck engines, tractors and trailers that will be impacted by the next round of GHG regulations.