

 From:
"Timothy A. Blubaugh" <tblubaugh@emamail.org>
 To:
Byron Bunker/AA/USEPA/US@EPA
 Date:
11/09/2010 09:59 PM
 Subject:
Vehicle Nomenclature



Hey Byron,
 
During your presentation on Friday you said there were debates about what to call the Class 7 & 8 tractors in the GHG program.  You settled on semi-trucks/combination tractors, which sounds like the perfect bureaucratic compromise: it makes no sense.  There is not such thing as a "semi-truck."  A semitrailer is a trailer constructed so that some part of its weight rests upon the towing vehicle.  It may be compared to a full trailer that is constructed so that no part of its weight, except the towing device, rests on the towing vehicle.  Further, there is no such thing as a "combination tractor."  A tractor is a truck designed primarily for drawing another vehicle, and not so constructed as to carry a load other than a part of the weight of the vehicle and the load so drawn (primarily, tractors tow semitrailers).  A combination vehicle is, descriptively, any combination of other vehicles (e.g., truck + full trailer, tractor + semitrailer, etc.).
 
You can read more about these exciting definitions at 49 C.F.R. § 390.5 and § 571.3.  
 
I think the category only includes "tractors."  As long as you are talking about on-highway tractors, and not agricultural nonroad tractors, I don't think there is much room for confusion.  (I might argue that the category actually should only include "long-haul tractors" or "over-the-road tractors," and not "vocational tractors," but that is another debate.)
 
Hoping this is helpful,
 
Tim
 
Timothy A. Blubaugh
Truck Manufacturers Association
333 West Wacker Drive ▪ Suite 810 
Chicago, IL ▪ 60606
312.929.1972 direct ▪ 312.208.0948 mobile 
312.929.1975 fax
tblubaugh@truckmfgs.org ▪ www.truckmfgs.org

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