Remember, visit http://www.regulations.gov/#!submitComment;D=EPA-HQ-OAR-2014-0827-0002 to submit comments.
Maintenance costs must be considered
In the current version of the proposal, the only additional maintenance cost considered by the agencies is a few hundred dollars a year tied to increased tire replacement frequency. Truckers know that anytime additional equipment is added to the truck, especially expensive equipment as is likely under this rule maintenance costs are likely to increase. While currently these issues are not part of the full cost-benefit analysis, the agencies have left the door open for these concerns to be highlighted in comments.
Commenters should consider discussing the impact of maintenance costs on their bottom line and the role reliablity plays in making a purchase. Also, commenters should highlight the fact that the agencies should be going out of their way to at least make realistic estimates regarding maintenance costs - they shouldn't be left blank in the cost-benefit calculation.
Post-purchase modifications to the vehicle's aerodymanic features
Input is requested regarding how a purchaser or user of a truck might modify aerodynamic or other features features on the truck post-purchase. One specific concern that OOIDA has raised with the agencies is a truck built for pulling a dry van trailer might be purchased used to pull a flatbed or the original purchaser of the truck might change from dry van to flatbed. According to the current proposal, removing the dry van-focused roof fairing for flatbed use could be a violation of the Clean Air Act, even though in this situation it would improve the vehicle's fuel efficiency.
Do you modify aerodynamic features based upon the trailers you are pulling or the loads you are hauling? Would losing this ability, especially when it improves fuel efficiency based upon the work you are doing, have a negative impact on your business?
The agencies suggest that a 400-pound weight reduction could achieve a 0.3 percent fuel savings. Much of this would be done though using more light-weight materials.
Do you have concerns with this area, whether regarding crashworthiness or the vehicle's ability to stand up to wear-and-tear?
Engine testing models must be realistic
There are concerns that the testing used by the agencies as part of their models for assessing engines and other technologies do not realistically reflect the use of heavy duty trucks, especially in long-haul operations over varied terrain and traffic.
What considerations should the agencies focus on in assessing technologies or building these test models?
Aerodynamics must be accurately assessed
While lots of trucks today use aerodynamic features to improve fuel economy, truckers know that they only work in certain situations. The testing of these devices must reflect this fact.
If you have fairings or other aerodynamics on your truck, under what conditions do you see a fuel economy benefit? When don't you?
Other tractor and engine-related topics
The agencies suggest that there’s no reason why Class 8 vehicles couldn’t be equipped with automatic engine shutoffs.
Can you share concerns about scenarios where a truck automatically shutting off could be dangerous/unsafe or otherwise problematic?
The performance standard would lead to automatic tire inflation (ATI) systems becoming standard. While they cost more than tire monitoring systems, the agencies point to ATI as an easy grab at a 1 percent savings due to the consistency of tires at a desired pressure.
If you have concerns about the increased cost or reliability of ATI systems please share them.
To reduce tire rolling resistance and improve fuel economy, EPA suggests choices for tire manufacturers concerning tread materials, architecture of the casing, tread design and ratings for speed, temperature and inflation.
EPA requests comments about rolling resistance and how it plays into different trucking applications. This is an opportunity to clarify how some tire technologies may be appropriate for your application while others may not.