

	UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF AIR AND RADIATION

NATIONAL VEHICLE AND FUEL EMISSIONS LABORATORY

2000 TRAVERWOOD DRIVE

ANN ARBOR, MI  48105-2498



April 12, 2016

MEMORANDUM

SUBJECT:	Follow-up Trailer Import Discussion with Wabash National
Corporation on April 8, 2016

FROM:	Jessica Brakora, Engineer, Assessment and Standards Division

Office of Transportation and Air Quality

TO:	Greenhouse Gas Emissions Standards and Fuel Efficiency Standards for
Medium- and Heavy-Duty Engines and Vehicles - Phase 2 - Dockets
NHTSA-2014-0132 and EPA-HQ-OAR-2014-0827



On April 8, 2016, EPA staff met with representatives from Wabash
National Corporation (Wabash) via phone.  The purpose of the phone call
was to include additional EPA staff and continue previous discussions
from December 1 and December 15, 2015 regarding Wabash’s concerns over
trailer importation.  The following participants attended the meeting:

Wabash representatives: 

Patrick Quinn, The Accord Group

Jamie Scarcelli, Wabash, Senior Vice President - General Counsel and
Secretary

Erin Roth, Wabash, Vice President - Corporate Strategy and Government
Affairs

EPA representatives:

Byron Bunker, EPA Compliance Division

Stephen Healy, EPA Compliance Division

Holly Pugliese, EPA Compliance Division

Jessica Brakora, EPA Assessment and Standards Division

Tad Wysor, EPA Assessment and Standards Division

Alan Stout, EPA Assessment and Standards Division

Chuck Moulis, EPA Assessment and Standards Division

Mario Jorquera, EPA Office of Enforcement and Compliance Assurance

The meeting began by highlighting that the largest concern was trailers
that are “imported” by being driven across the border as a standard
trailer that may be indistinguishable from other in-use trailers.  EPA
noted that if a new trailer is registered in the U.S., EPA has the
ability to track it.  Wabash acknowledged that it would be difficult for
large fleets to place large orders and accept delivery this way
undetected.  However, smaller fleets and owner-operators may be able to
register their trailers in Mexico and transport them into the U.S.  EPA
noted that fleets and operators that choose this route would be able to
do U.S.-Mexico and Mexico-U.S. deliveries, but would be restricted from
delivering exclusively inside the U.S.   

EPA inquired what location information was needed to register a trailer
and Wabash suggested that they may be able to use a PO Box.  EPA asked
if weigh stations are likely to check vehicle registration information
and Wabash believed the weigh station operators are mostly just focused
on safety and weight.   EPA suggested that it can work with state-based
departments of motor vehicles to ensure that they check manufacturer’s
statement of origin (MSO) paperwork as part of the registration process,
but that would not counter fraudulent activity.  EPA asked if duties or
tariffs may be an avenue to track imported trailers.  Wabash noted that
border traffic will be significantly impacted if border officials must
check every tractor-trailer that crosses into the U.S. 

EPA stated that it intends to reach out to appropriate agencies once the
rule is final to begin a dialogue related to future trailer importation
requirements.  The agency has a long-standing relationship with Customs
and Border Protection, but may have to recruit help from additional
agencies to ensure trailer registrations and emissions certifications
are aligned.

Follow-up Trailer Import Discussion with Wabash on April 8, 2016 - Page 
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