Trucking Cautions NHTSA on GHG Rule

This story appears in the Sept. 1 print edition of Transport Topics.

Trucking companies and equipment manufacturers told the National Highway Traffic Safety Administration they are willing to cooperate on further regulation of greenhouse-gas emissions but also raised concerns that they hope will keep any proposal from unintentionally backfiring.

They made the comments as part of NHTSA’s impact study on Phase 2 of the greenhouse gas rule ordered by President Obama.

NHTSA will write the rule with the Environmental Protection Agency, with the spring of 2015 targeted for a proposal.

The companies warned that if a new GHG-carbon dioxide rule is poorly crafted, it could cause truck sales to tank, harm manufacturing employment and delay the adoption of more fuel-efficient technology.

Daimler Trucks North America and Volvo Group called for a complete-vehicle standard. But independent engine maker Cummins Inc. wants vehicles and engines considered separately.

“Our customers use these vehicles for commercial purposes and business tools to earn money, and therefore, many of them cannot afford more than two years’ depreciation time,” said Sean Waters, director of compliance and regulatory affairs, in comments from DTNA.

The Environmental Defense Fund agreed with Cummins on the separation issue.

Any proposal “should include separate performance-based standards for the engine, vehicle and trailer that would result in reducing new truck fuel consumption on average by at least 40% for the entire fleet by 2025, compared to 2010 trucks,” said EDF senior manager Jason Mathers.

The recommendation for separating engine and vehicle rules is similar to remarks by Cummins.

There is a “natural partitioning between power supply [the engine, which burns all the fuel and emits all the GHG] and power demand [the rest of the vehicle],” wrote Brian Mormino, a Cummins executive.

The Columbus, Indiana-based engine maker offered a menu of technologies it is investigating for Phase 2: advanced combustion strategies, turbocharger and exhaust gas recirculation air handling, friction and parasitic loss reductions, increased peak-cylinder pressure, high-efficiency aftertreatment, heat-transfer management, engine downspeeding and waste-heat recovery.

Mormino also said the engine could be considered with the truck’s transmission.

DTNA’s Waters and Anthony Greszler of Volvo disagreed strongly on the separate standards, preferring a single complete-vehicle rule. Among heavy-duty North American trucks, Daimler makes Freightliners and Western Stars, whereas Volvo makes Macks and Volvos.

In their sales campaigns, those companies have told customers they should specify in-house engines and transmissions to go with their Daimler or Volvo trucks. Managers from both companies have said they can do the most to maximize fuel economy when the total package is managed by one manufacturer.

Manufacturers called upon NHTSA to avoid creating a pre-buy sales cycle similar to one eight years ago, when sales boomed during the two years before a January 2007 regulatory change and then plummeted. Organized labor agreed.

“It is critical that standards be developed in a way that would not negatively impact the lives of thousands of hard-working UAW members and their families as well as other working Americans,” wrote Dennis Williams, president of the United Auto Workers.

“Among our most pressing concerns is the potential for a harmful ‘no-buy’ or ‘pre-buy’ caused by the new Phase 2 requirements,” Williams said.

Phase 1 of GHG regulation on heavy and medium-duty commercial trucks started Jan. 1. The 2014 standard was a 3% tightening over the EPA estimate for the average heavy-duty truck engine made in 2010. In 2017 there will be another 3% tightening on carbon dioxide and other GHGs.

Speculation has been that Phase 2 standards would start in January 2020.

Comment from American Trucking Associations focused on the cost of vehicles that would meet a new regulation. ATA said the new trucks should be able to demonstrate a return on investment of 18 months, meaning the extra cost of the tractor would generate fuel savings to cover the higher purchase price.

However, if costs soar far beyond that, trucking companies could avoid new models through a pre-buy, keep older tractors longer, buy used trucks instead of new or go out of business, according to the remarks filed by ATA energy and environmental counsel Glen Kedzie.

The Owner-Operator Independent Drivers Association had a similar view.

“The most crucial consideration is that a more affordable and reliable truck is more likely to be purchased at an earlier date by someone who is considering a new truck. Therefore, the more efficient new truck will be in service at an earlier date. That will lead to a desired environmental impact,” said OOIDA President Jim Johnston.

OEMs said regulators should maintain a 4/3 timing schedule that previously has been used. That means engineers would get four years of lead time to make trucks and engines that could hit the new standard, which would then remain in place for at least three years.

Great Dane Trailers was the only trailer maker to file a comment and said regulations should be limited to vans

53 feet long or longer, said company Vice President Charles Fetz.