Trailer Compliance With New EPA Regulations

7/16/2015
TCA 32nd Annual Refrigerated Division
Stowe Mountain Lodge
Stowe, Vermont
July 10, 2015
Eurell Eubanks
Director, National Accounts
Great Dane
Pending Rules:
• Foam Blowing Agents
• Green House Gas Phase II
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 Polyurethane foam is the primary insulator
 Blowing agent expands foam
 Blowing agent fills cells  Blowing agents first regulated under the Montreal Protocol (late 1980’s)
Early
1990’s
2000‐2008
2008‐2020
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 EPA just issued a fact sheet on the SNAP program change proposal
 Final rule expected soon
 Timing is the key, trailer foam systems will change in 2020
 GHG1 just taking effect
 Unofficial version of Phase 2 signed and released 6/19
 Will publish in Federal Register –
then 60 days to comment
 Final rule March of 2016 becoming effective in 2018 for trailers 3
7/16/2015
 Separate subcategories for:
 Long box (longer than 50 feet) dry vans and reefers
 Short box (50 feet and shorter) dry vans and reefers
 Non‐box trailers (flatbeds, tankers, etc.)
 Four‐step phase in of standards
 SmartWay Basic‐type standards in 2018
 Intermediate standards in 2021 and 2024
 Final standards in 2027
Long Dry Van Standards
2018
2021
2024
2027
Percent reduction from conventionala dry box van
6%
8%
10%
12%
a Conventional
trailer: dry van without
any aero, LRR tires, or ATIS
 Follows same basic structure as tractors
 Certification by trailer manufacturer
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Green House Gas Phase II
 Early stages
 LRR tires (mandatory on some trailers)
 Skirt or boat‐tail
 Credit for ATIS
 Late stage
 LRR tires
 Skirt and boat‐tail?
 Other technologies?
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 Rule is lengthy (1329 rule +971 pages RIA)
 EPA is requesting comments
 User comments are key
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Trailer Compliance With New EPA Regulations
David Wallace
Director of Sales
UTILITY TRAILER MANUFACTURING CO.
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TRAILER PROPOSED RULE
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Greenhouse Gas II
U. S. Environmental Protection Agency &
National Highway Traffic Safety Administration
06/19/2015
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Trends in Aerodynamic Devices
Trailer Tails
Advanced Side Skirts
Smart Truck
Smartlift
Automatic
Axle Lift
Lifts tires off the ground when they are not required to carry the load
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Industry Innovations
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TRAILER COMPLIANCE WITH NEW EPA REGULATIONS:
PHASE II GREENHOUSE GAS AND SNAP OUTLOOK
2015 TCA Refrigerated Conference
Brent Yeagy
Group President, Commercial Trailer Products (CTP)
PROPOSED PHASE II GREENHOUSE GAS OVERVIEW
What is it?
Proposed second phase of laws jointly sponsored by the EPA and NHTSA targeted to lower the carbon footprint of transportation resulting in lower pollution and fuel savings.
When is it?
Begins January 1, 2018 with increasing regulation in 2021, 2024, and 2027 all targeted around lowering carbon footprint
Who is impacted?
Ultimately, almost all trailers in varying degrees.
•
•
•
•
Long (≥50’) and Short (<50’) box dry and refrigerated vans
Partial‐aero long and short box dry and refrigerated vans Non‐aero box vans (all lengths of dry and refrigerated vans)
Non‐box trailers (tanker, platform, container chassis, and all other types of highway trailers that are not box trailers)
The only trailers exempted are logging, mining, livestock, heavy‐haul and those trailers who perform their primary function while stationary as well as:
•
•
Trailers ≤35 feet in length with three axles, and all trailers with four or more axles (including any lift axles)
Trailers designed to operate at low speeds such that they are unsuitable for normal highway operation
How is compliance achieved?
Compliance is achieved by adding aerodynamic devices, low rolling resistance tires, automatic tire inflation systems, and weight reduction all contributing in varying levels to meet a specified carbon threshold in g/ton‐mile units.
Where does compliance responsibility lie?
The proposal states that compliance lies with the OEM. Compliance may be achieved in a “primary” sense (all trailers produced meet requirements) or through weighted averaging (some over‐comply and others under‐comply)
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UNDERSTANDING COMPLIANCE OPTIONS AND ELEMENTS
Aerodynamic Devices:
• Placed into eight “bins” depending on change in drag area from the baseline.
• Highest leverage when calculating compliance
Low Rolling Resistance Tires:
• In feasibility study, two tiers utilized for calculation
• May require actual TRRL to be utilized on a per order basis
Automatic Tire Inflation (ATI):
• Presence of an ATI system yields a 1.5% improvement across all values as a multiplier
Example/used for feasibility
“For compliance, manufacturers would have the option
to use tires with any rolling resistance and would not be
limited to these TRRLs”
Reference: Greenhouse Gas Emissions and Fuel Efficiency Standards for
Medium- and Heavy-Duty Engines and Vehicles - Phase 2 (Page 279)
Reference: Docket EPA-HQ-OAR-2014-0827 (Page 2)
Weight Reduction:
• Incorporated weight reduction also considered – example next page
• Least amount of leverage for CO2 reduction overall
• Likely required in out years for compliance
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UNDERSTANDING COMPLIANCE CALCULATIONS AND LEVERAGE
Compliance goals by trailer type:
Note Baseline (“Zero-Technology”):
Dry Van – 88 CO2 Grams/Ton-Mile
Refrigerated Van – 89 CO2 Grams/Ton-Mile
Reference: Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles - Phase 2 (Page 263)
The compliance equation: Y = [C1 + C2 ∙ (TRRL) + C3 ∙ (∆CDA) + C4 ∙ (WR)] ∙ C5
Where:
•
•
Larger multiplier around C3 indicates stronger leverage on Aerodynamic improvements
Smaller multiplier on C4 indicates lower return on weight reduction
Reference: Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles - Phase 2 (Page 303)
The road to compliance:
Example Weight Reduction
CDA
No Aero
Gap Reducer
TRRL
Advanced Skirt/Tail
Optimized Skirts, Basic Combos
Skirt/Tail Combo
Optimized Advanced Combos
Future
0.3
0.5
0.7
1
1.4
1.8
DRY
REF
Basic Skirt
Dry Req
Ref. Req.
Dry Y
Ref Y
2018
83
84
83.0
83.2
2021
81
82
80.6
82.0
2024
79
81
78.8
80.3
DRY/REF
2027
77
80
76.8
79.5
DRY/REF
0.1
ATI
Smartway Tires
Top 25% Smartway Tires
No ATI
5.1
4.7
1
DRY/REF
DRY/REF
WR
ATI
Base
Pkg 1
Pkg 2
Pkg 3
Pkg 4
0.985
0
168
556
910
1315
DRY/REF
DRY/REF
DRY/REF
DRY/REF
DRY/REF
DRY/REF
DRY/REF
DRY/REF
DRY/REF
REF
DRY/REF
DRY
Reference: Docket EPA-HQ-OAR-2014-0827 and Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles - Phase 2 (Page 303)
Compliance may be achieved through multiple
combinations of elements resulting in target levels
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SIGNIFICANT NEW ALTERNATIVES POLICY (SNAP) OVERVIEW
What is it?
EPA modification to provide additional regulations around hydrofluorocarbons (HFC’s) specifically, “narrowed use limits for certain hydrofluorocarbons (HFCs) and HFC blends in various end‐uses in the aerosols, foam blowing, and refrigeration and air conditioning sectors where other alternatives are available or potentially available that pose lower overall risk to human health and the environment.”
Reference: Protection of Stratospheric Ozone: Change of Listing Status for Certain Substitutes under the
Significant New Alternatives Policy Program (Page 7)
Where is the impact?
•
Multiple aspects – Light duty vehicles, retail food refrigeration, vending machines, foam blowing agent usage, and aerosols.
•
Specifically, manufacturers of refrigerated trailers
What is changing?
•
The industry agents HFC‐134A and HFC‐245FA will no longer be allowed for use
When does this go into effect?
•
1/1/2020
How does this impact me?
This is not completely known at this time however it is likely that the alternative blowing agents will be:
• More costly
• Less efficient (thermally speaking)
Continued regulatory increases challenge efficiencies
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