The U.S. government’s commitment to reducing greenhouse gas (GHG) emissions and improving the fuel efficiency of medium and heavy duty commercial vehicles hasve led the Environmental Protection Agency (EPA) and U.S. Department of Transportation’s National Highway Traffic Safety Administration (NHTSA) to craft stringent regulations in recent years.
The second phase of regulations will take effect on Jan. 1, 2018, and they serve to promote the adoption of current technologies and spur the creation of new, advanced and cost-effective technologies through model year 2027. According to the EPA, the standards, which include regulations for trailers for the first time, will help lower carbon dioxide (CO2) emissions by 1.1 billion metric tons and save vehicle owners fuel costs of around $200 billion over the 10-year lifetime of the program.
However, according to Craig Bennett, senior vice president, sales and marketing, Utility Trailer Manufacturing Company, a manufacturer of dry vans, flatbeds, reefers and curtainside trailers (www.utilitytrailer.com), the expected benefits of the standards may not be able to be fully enjoyed by fleets due to certain assumptions included in the government’s complex GHG model tasked with measuring compliance with the regulations.
“(These factors) make us really question whether the regulations are a good idea or not,” says Bennett.
The factors, according to Bennett, include:
● Uncertainties about whether a fleet’s fuel consumption can be efficiently and effectively reported to the government.
● The model’s assumption that a certain tractor will always be paired with a certain trailer.
● The model’s assumption that a commercial vehicle averages a speed of 62 mph.
● The model’s assumption that there is a four-degree yaw angle wind at all times the vehicle is in motion.
Difficult Reports
Fleets will be tasked with attempting to provide accurate reports of their fuel consumption, and the government’s model will measure both compliance and benefits obtained. However, fleets will be required to report their entire backlogs for a year, which Bennett says, will be a difficult and laborious task, largely because they change so regularly.
“The quantities change, the specifications change, everything changes,” he adds. “(The backlogs) are always in flux, so that will have to be recalculated all of the time.”
Wrong Assumptions
Bennett also notes the model’s assumption that a certain tractor will always be paired with a certain trailer is quite problematic. “As we all know, tractors and trailers move around, so that’s a flawed assumption to begin with.”
The second flawed assumption, he says is the government’s assumption that a commercial vehicle averages 62 mph. “All the fleets we’ve talked to, when you pull the data off their tractors, the average miles per hour they are using is under 50. More often than not, it’s 45, 47 or 48 mph. So you aren’t going to get the results that the… formula says you are going to get.”
Bennett is also critical of the model’s assumption of a four-degree yaw angle wind at all times a vehicle is in motion.
“Winds change, as we all know,” he continues. “The stronger the wind blows, the more aerodynamic gains that you can have, and the better fuel economy improvement you’ll get with aerodynamic devices.”
No Idea
Above all else, though, Bennett is concerned about the stringency of the standards continuing to increase over the 10-year lifetime of the government’s phase two program. He notes the proposed fuel efficiency and C02 reduction goals proposed for 2024 and 2027 will be quite difficult to achieve.
“We don’t have any idea on how to achieve it, and there isn’t anybody in the industry at this time that knows how to achieve those improved fuel economy results,” he adds.
