Lookin' at the [climate] plan through a windshield

One of the “new steps” called out in the Obama Administration’s recently announced climate action plan is the development of “post-2018 fuel economy standards for heavy-duty vehicles to further reduce fuel consumption through the application of advanced cost-effective technologies and continue efforts to improve the efficiency of moving goods across the United States.”

This is the first time that the White House has formally announced that the Environmental Protection Agency and the National Highway Traffic Safety Administration are working on so-called Phase 2 standards. Phase 1, for those just joining us, was completed in 2011, when the EPA and NHTSA finalized the first GHG and fuel efficiency standards for heavy-duty vehicles, affecting trucks and buses manufactured from 2014 to 2018—the first such standard passed in the U.S., and the first to go into effect anywhere in the world (Japan finalized HDV standards in 2006, but they do not take full effect until 2015).

So, this recent announcement signals that we can expect a Notice of Proposed Rulemaking (NPRM) for the Phase 2 regulation sometime in next year or so, and a final rule soon after. What should we expect it to contain, though?

One of the most important details in the Phase 2 rule will be whether trailers are included—“trailers” as in “semi-trailers,” the part of the ubiquitous tractor-trailer combination that contains the freight being hauled. The agencies left trailers completely out of the Phase 1 rule, citing lack of time to properly engage the trailer industry, which has never previously been regulated for environmental performance.

Why are trailers important? In a nutshell, a combination of off-the-shelf technologies for reducing aerodynamic drag, rolling resistance, and trailer empty weight can reduce overall tractor-trailer fuel consumption by 10% or more, which is significant because tractor-trailers account for roughly two-thirds of fuel use and GHG emissions from the entire heavy-duty vehicle sector. For reference, in the Phase 1 regulation, the regulatory class of vehicles with the most stringent standards is tractors, which must reduce their fuel use by up to 23% versus a 2010 baseline vehicle. So, the fuel consumption reduction potential of trailers can and should be an important element of the portfolio of technologies that the agencies include in the Phase 2 program. Bringing trailers into the regulatory fold will significantly improve the fuel savings and climate benefits of the Phase 2 regulation.

As we detailed in a recent paper, there are a number of cost-effective fuel-saving technologies for trailers being deployed in the market due to the EPA’s voluntary SmartWay Program, California’s mandatory tractor-trailer GHG regulation (which is based on the SmartWay Program), and general uptake in the market. However, to expedite the adoption of these technologies across the entire industry and to ensure additional fuel savings and GHG benefits, and the EPA and NHTSA should prioritize integrating trailers into the Phase 2 regulation.