Fuel economy not the only factor truckers focus on
As professional truckers, you know that there are many factors in a tractor, engine, or trailer that you look at when deciding to make a purchase. Fuel economy is certainly one of those factors, but other needs matter, from reliablity to being spec'd for the work you do.
Share your experience in buying a truck, new or used. What factors do you look for? What role does fuel economy play, especially if to gain fuel economy you lose in another area?
Lead time, stringency, and technology
A very crucial aspect of this rulemaking is the amount of time manufacturers will have to comply with the new standards. Without enough lead time to develop and test new ideas and new technologies this could easily result in trucks with reliability problems…again.
The agencies have proposed an overall level of stringency (the level of fuel economy gains under the rule) called Alternative 3. While agressive and not without costs, there is a good chance that the goals in Alternative 3 should be be achievable without forcing untested technologies. The agencies also have asked for input on what they are calling Alternative 4. Alternative 4 would push for even higher levels of fuel economy, on an even shorter time-frame. This would greatly increase the risk of forcing unproven technologies. Many groups outside trucking are pushing for the agencies to accept Alternative 4 in the final rule.
While the proposal doesn't mandate any specific technologies, the performance standards set and the way the agencies enforce them through testing could, especially if Alternative 4 is accepted, result in the forced adoption of a technology called "waste-heat-recovery" or WHR. WHR might have potential but it is an expensive and unproven technology - just the thing truckers want to avoid after the situation from the 2000s diesel engine emission rules.
Cost vs benefit in real life
The agencies estimate a $10,000 to $13,000 increase in the cost of a new truck and a $1,400 increase for a new trailer by 2027. These agencies have a poor track record in estimating costs and are assuming that a new Class 8 truck cost starts at $100,000.
Do you have experiences or figures you can share with the real increases in truck prices due to the Phase 1 emissions rulemaking? Past experiences with other EPA rulemakings? How much do you see new trucks costing today?
The agencies claim an owner of a new truck designed under the proposal will be able to recoup costs in “less than two years” due to fuel savings. The agencies have yet to show a direct connection between specific technologies and specific costs savings. The model they use to make these estimates does not reflect all types of operations or geography. Making a new truck more expensive is not a good incentive to encourage truck purchasers to buy new trucks.
Do you feel that this is a realistic estimate? If not, why?
Is it possible that the increased price of a truck will mean that you will not be able to afford to purchase a new truck (or even afford a new-to-you used truck with an increased price), and therefore never gain the benefit of the promised improved fuel economy? What about for your operation and the type of geography/roads you operate over (hills and mountains or flat plains? Interstates or rural roads with lots of curves?)
The agencies do not include estimates for increased maintenance costs, the impact of downtime due to breakdowns, etc. While these are all factors that truckers know are real, the agency hasn’t tried to estimate them, but has left the door open for these concerns to be highlighted in comments.
If you have a newer truck, do you have experiences with increased maintenance costs or breakdowns due to Phase I regulations? What about previous EPA regulations?
Impacts on niche segments of the industry
Niche segments such as oversized and heavy haul are recognized as being unique. This in an area where the agencies have partially listened to concerns. They acknowledge that trucking is not one-size-fits-all, and that technologies or add-ons that work in one setting, such as side skirts or boat tails, don’t work in other applications.
Are there other niche segments that should be considered (e.g. agriculture or oil field work)? What factors should be considered?