

U.S. DEPARTMENT OF TRANSPORTATION

NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

1200 NEW JERSEY AVENUE SE.

WASHINGTON DC, 20590	UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF AIR AND RADIATION

NATIONAL VEHICLE AND FUEL EMISSIONS LABORATORY

2000 TRAVERWOOD DRIVE

ANN ARBOR, MI  48105-2498



August 2, 2016

MEMORANDUM

SUBJECT:	Example Compliance Scenarios for the Final HD GHG Phase 2
Trailer Program

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



Introduction

As described in the Phase 2 HD GHG and Fuel Consumption Final
Rulemaking, EPA and NHTSA are adopting the first CO2 emissions and fuel
consumption regulations for trailer manufacturers.  The trailer industry
has no experience with the process for complying with EPA emissions or
NHTSA fuel consumption regulations.  The industry is used to safety
standards that require specific technologies be installed on their
trailers.  In contrast, the box van performance standards of the Phase 2
program offer trailer manufacturers several technology options to
comply.  Additionally, the concept of averaging, which is an optional
compliance flexibility for trailer manufacturers in MY 2027 and later,
may add complexity to a process that is already unfamiliar to vehicle
manufacturers that are not currently regulated.  The purpose of this
memo is to provide a set of hypothetical examples of how a trailer
manufacturer might comply with the Phase 2 standards while meeting the
needs of a variety of customers.

In this memo, we provide example scenarios to illustrate some of the
different compliance options that would be available to trailer
manufacturers in the program.  The first set of scenarios presented is
for model year (MY) 2018, representing the first stage of the phase-in. 
A second set of scenarios is presented for MY 2027, when we the program
is fully phased-in.  We performed this analysis in terms of grams of CO2
per ton-mile; use a conversion of 10,180 grams of CO2 per gallon of
diesel to calculate the fuel consumption values.  All calculations were
performed using the attached Excel file.  This Excel file is updated
from the Example Trailer Emissions Calculations template that was
included in the docket at the time of the NPRM.   This updated file can
be used to estimate compliance for trailer manufacturers, but cannot be
used for official compliance.  

Compliance Options Available in the Final Trailer Program

In MY 2018 through MY 2026, trailer manufacturers comply with the
trailer program by producing all of their regulated trailers to meet the
standards.  The agencies expect a variety of technology combinations
from several device manufacturers would satisfactorily meet the
standards, and a manufacturer would be able to offer its customers some
flexibility in the choice of technology packages they purchase.  
Trailer manufacturers would take on basic recordkeeping and reporting
responsibilities during these years.

Historically, EPA has created provisions that allow vehicle
manufacturers the option of averaging, banking, and trading within their
sales mix, which provides an additional flexibility for manufacturers to
achieve compliance.  Averaging provisions allow a vehicle manufacturer
to produce and sell trailers that under-comply with the standards as
long as they make up for those sales with sufficient over-compliant
trailers.  Banking and trading provisions allow vehicle manufacturers to
carry-over, sell or purchase end-of-year credits generated from
over-compliance.  This final trailer program does not include banking or
trading provisions, since the agencies believe these provisions would
disproportionately impact the large number of small businesses in the
trailer industry.  See the preamble to this rulemaking for a more
detailed discussion of these impacts.  

The agencies are adopting averaging provisions as a compliance
flexibility for trailer manufacturers in MYs 2027 and later.  As will be
shown in the examples to follow, an averaging compliance approach would
allow a trailer manufacturer to offer its customers a greater number of
technology options, since not all trailers sold are required to meet the
standards.  Customers would have the option of purchasing technology
packages that meet or exceed the standards, or they could choose to
avoid purchasing some technologies.  Trailer manufacturers that opt for
an averaging compliance approach would have additional recordkeeping
responsibilities in that they must ensure that their sales of adequately
over-compliant trailers exceed their under-compliant sales.  These
manufacturers would also have to submit an additional end-of-year report
describing their averaging strategy.  

Summary of Performance Levels for Trailer Technologies

As discussed in the preamble to this rulemaking and its accompanying
RIA, the agencies evaluated several existing technologies and created
metrics to evaluate their performance.    REF _Ref412048314 \h  Table 1 
presents performance parameters for aerodynamic technologies, lower
rolling resistance tires, and tire pressure systems (i.e., TPMS or
ATIS), and provides example technologies for reference.  Delta CdA is
the change in drag area, which is a measure of aerodynamic performance. 
The tire rolling resistance level (TRRL) is the regulatory term for the
coefficient of rolling resistance (CRR) that a trailer manufacturer uses
in compliance.   

Table   SEQ Table \* ARABIC  1 :  Summary of Performance Parameters and
Example Technologies 

Aerodynamics	CdA (m2)	Example Technologies



Long Van	Short Van

Bin I 	0.0	No Aero 	No Aero

Bin II 	0.1	Gap Reducer 	Skirts or Tail

Bin III 	0.4	Skirts or Tail 	Skirts + Gap

Bin IV	0.7	Skirts + Gap	Optimized Combinations

Bin V	1.0	Skirts + Tail

	Bin VI	1.4	Optimized Combinations

	Bin VII	1.8	Future Devices/Redesign

	Tire Rolling Resistance	TRRL (kg/ton)	Example Technologies

Level 1 	6.5	Non-Box Trailer Baseline

Level 2	6.0	Box Van Baseline Tires

Level 3	5.1	SmartWay Tires

Level 4	4.7	Top 25% 2014 SmartWay Tires

Tire Pressure System	Effectiveness	Description

No System	0.0%	None

TPMS	1.0%	Tire Pressure Monitoring System

ATIS	1.2%	Automatic Tire Inflation System



The regulations include a list of 12 light-weight components and four
tire/wheel options that a manufacturer could install on its trailers for
weight reduction.  For simplification in this set of examples, we are
limiting the weight reduction options to six packages.  Package 1
substitutes eight dual-wide steel wheels with eight aluminum wheels, and
Package 2 substitutes eight steel wheels with four aluminum wide-based
single wheels and tires.  Package 3 is a combination of weight savings
by installing aluminum trailer chassis (i.e., bogie) components: 
suspension assembly (280 lb), and hubs and drums (2 x 80 lb).  Package 4
includes aluminum versions of three components found on the underside of
box trailers:  landing gear (50 lb), a slider box (150 lb), and upper
coupler assembly (430 lb).  Package 5 is a combination of six aluminum
trailer body components:  roof bows (100 lb), rear door surround (150
lb), rear door  (187 lb), floor crossmembers (203 lb), side posts (300),
and the complete floor (375).  Package 6 includes all of the components
in Packages 2-5.    REF _Ref416257947 \h  Table 2  summarizes the weight
savings for each package.

Table   SEQ Table \* ARABIC  2 :  Summary of Weight Reduction Packages
Used in Compliance Examples

Weight Reduction	Description	Weight Reduced (lbs)

Base	Standard Components	0

Package 1	8 Aluminum Dual Wheels	200

Package 2	4 Aluminum Wide-Based Single Wheels	524

Package 3	Trailer Bogie Components	440

Package 4	Trailer Underside Components	630

Package 5	Trailer Body Components	1362

Package 6	WBS Wheels, Bogie, Underside, Body	2956



The performance parameters for aerodynamics and tires are combined with
the cumulative weight savings from any light-weight component
substitutions and the improvement for use of a tire pressure system to
determine CO2 emissions and fuel consumption from a tractor-trailer
vehicle.  The agencies developed an equation for trailer manufacturers
to combine the effects of these technologies and calculate CO2 emissions
for compliance.  The equation is based on the EPA’s heavy-duty vehicle
simulation tool, the Greenhouse gas Emissions Model (GEM), that is used
for compliance by other heavy-duty vehicle sectors.  See RIA Chapter
2.10.5.  Equation 1 is the generic GEM-based compliance equation for box
vans.

∙TRRL + C3∙CdA + C4∙WR)∙C5	(1)



Coefficients C1 to C4 are identified for each trailer type in Table 1 of
40 CFR 1037.515 and copied in the “ForReference” tab of the attached
emissions calculations Excel file.  The performance parameters for tire
rolling resistance and aerodynamic improvements (i.e., TRRL
andCdA) would be obtained from testing performed by the trailer
manufacturer or aerodynamic device or tire manufacturers.  The weight
reduction (WR) value could be a sum of the approved light-weight
components that are installed on the trailer or obtained from off-cycle
testing (see 40 CFR 1037.515(e)).  The constant, C5, is equal to 0.990
(to account for a 1.0 percent improvement) if a trailer has TPMS
installed, or 0.988 (to account for a 1.2 percent improvement) if a
trailer has ATIS installed, otherwise it is 1.0.  Throughout this memo,
Equation 1 is used to calculate the CO2 emissions.  As mentioned
previously, we performed this analysis in terms of grams of CO2 per
ton-mile; use a conversion of 10,180 grams of CO2 per gallon of diesel
to calculate the corresponding fuel consumption values for compliance
with NHTSA’s regulations.

Description of Example Customers

In the examples that follow, we consider a box van manufacturer that
sells a total of 200 long dry vans to four customers with different
needs and preferences for their orders.      REF _Ref416327515 \h  Table
3  introduces the four customers, their preferences, and their order
sizes.  Each customer purchases an equal number of trailers that qualify
as “full-aero” and “partial-aero”.  For simplicity, the
customers and the number of trailers in their orders remain the same in
each scenario presented.  We recognize that manufacturers may produce
more than a single type of trailer, sell more than 200 trailers, and
have more than four customers.  The concepts presented here can be
easily translated to larger production volumes and the other box van
subcategories.  A short description of some of the subcategory
differences is provided at the end of these examples.  Note that
non-aero box vans and non-box trailers are not presented here.  These
trailers have design standards that require manufactures to install a
tire pressure system (TPMS or ATIS) and LRR tires at specific
performance levels.  They do not have numerical standards to calculate.

Table   SEQ Table \* ARABIC  3 :  Description of Customers for Example
Compliance Scenarios

Customer	Acceptance of Technologies	Units in Order

1	Reluctant to adopt aero	60

2	Reluctant to adopt LRR tires	20

3	Willing to adopt all tech	80

4	Reluctant to adopt ATI	40

Example Compliance Scenarios 

In MYs 2018 through 2026, long and short box van manufacturers produce
all of their regulated trailers to meet the standards.  In MY 2027 and
later, these manufacturers would be allowed to use averaging within a
model year, in which case some of their trailer production could
under-comply if enough of their other trailers over-complied.  The first
set of scenarios presents two approaches to meeting the MY 2018
standards for long dry vans for both the full- and partial-aero vans. 
The first example allows each customer to choose specific technologies
to avoid.  In the second example, the manufacturer specifies a base
level of technologies such that all trailers will meet the standard and
customers have the option to order additional technologies if desired.
The second set of scenarios describes two approaches to meeting the MY
2027 standards.  One MY 2027 example shows how each customer’s
trailers might comply with the standards and the other uses averaging
such that the long dry van family complies while allowing customers to
avoid adopting some technologies.

MY 2018 Compliance Scenarios 

In MY 2018, each of a manufacturer’s regulated trailers must perform
at or better than the applicable standard for the model year.  Below are
descriptions of two example scenarios that adopt this compliance
approach.  The first scenario offers more flexibility for customers to
choose technology packages based on their preferences.  A trailer
manufacturer adopting this approach would likely evaluate several
technology combinations to ensure each of the trailers sold meet the
standards, which may require some additional recordkeeping.  The second
scenario describes a simplistic strategy for achieving the standards for
the given model year.  The trailer manufacturer’s customers in this
second example would still maintain some choice in technology options,
but a minimum set of combinations would be required.  This scenario
would involve the least amount of recordkeeping for the trailer
manufacturer.

Example 1:  MY 2018 Standard Long Dry Van Compliance Scenario

In MY 2018, full- and partial-aero standards are the same (81.3 g
CO2/ton-mi) and the standards can be met with the same technologies.  In
this example, Customer 1 does not like aerodynamic technologies and is
ok with adopting TPMS (for a 1% reduction) and LRR tires at the SmartWay
verification level (5.1 kg/ton).  This customer made up for no
aerodynamic improvements by adopting Package 6 weight reduction (2956
lb).  Customer 2 does not like LRR tires.  Instead, this customer
purchases ATIS (1.2% reduction), skirts at a Bin III level of
performance (0.4 m2 improvement) and Package 1 and Package 5 weight
reduction (200 lb + 1362 lb).  Customer 3 is open to all technologies,
and chooses ATIS, SmartWay tires, and Bin III skirts, but no weight
reduction.  Customer 4 does not like ATIS and chooses SmartWay tires,
Bin III skirts, Package 5 weight reduction, and no tire pressure system.
  REF _Ref458460213 \h  Table 4  shows the performance parameters
applied for each trailer configuration. It’s seen that all trailer
orders meet the standards.

Table   SEQ Table \* ARABIC  4 :  Example Performance Parameters for
Four Customers in a MY 2018 Standard Compliance Scenario; MY 2018
standard is 81.3 g CO2/ton-mile

Trailer	Preference	C5	TRRL

(kg/ton)	DCdA

(m2)	Weight Reduction

(lb)	CO2

(g/ton-mi)

Config_Full_1	No Aero	0.990	5.1	0.0	2956	80.8

Config_Full_2	No LRR Tires	0.988	6.0	0.4	1562	81.2

Config_Full_3	All Tech OK	0.988	5.1	0.4	0	81.3

Config_Full_4	No ATIS	1.000	5.1	0.4	1362	80.9

Config_Partial_1	No Aero	0.990	5.1	0.0	2956	80.8

Config_Partial_2	No LRR Tires	0.988	6.0	0.4	1562	81.2

Config_Partial_3	All Tech OK	0.988	5.1	0.4	0	81.3

Config_Partial_4	No ATIS	1.000	5.1	0.4	1362	80.9



Prior to the model year, a manufacturer adopting a similar compliance
strategy as shown in   REF _Ref416334075 \h  \* MERGEFORMAT  Table 4 
may wish to consider and keep track of which combination of technologies
would result in compliant trailers when deciding the technology packages
to offer to its customers.  The trailer manufacturer would not need to
analyze its sales throughout the year as long as each of the trailers
sold continued to meet the standards.  At the end of the year, this
trailer manufacturer would submit a production report to the agencies
that includes the production volumes and performance of the trailers
sold.  A detailed description of the reporting and recordkeeping
requirements is available in 40 CFR 1037.250.  

Example 2:  MY 2018 Simplified Long Dry Van Compliance Scenario

A simplified compliance example is shown in   REF _Ref416348328 \h 
Table 5 .  In this example, the trailer manufacturer establishes a base
set of technologies for all of its trailers to ensure that every trailer
was compliant.  Every trailer sold includes at least Bin III aerodynamic
technologies, SmartWay level rolling resistance tires, TPMS, and
aluminum dual wheels which exactly meets the standard at 81.3 g
CO2/ton-mile.  The trailer manufacturer in this scenario would not
restrict the purchase of additional technologies, as demonstrated by
Customers 3 and 4 choosing to purchase trailers with ATIS and additional
light-weight components, respectively.  

Table   SEQ Table \* ARABIC  5 :  Example Performance Parameters for
Four Customers in a MY 2018 Simplified Compliance Scenario; MY 2018
standard is 81.3 g CO2/ton-mile

Trailer	Preference	C5	TRRL

(kg/ton)	DCdA

(m2)	Weight Reduction

(lb)	CO2 

(g/ton-mi)

Config_Full_1	No Aero	0.99	5.1	0.4	200	81.3

Config_Full_2	No LRR Tires	0.99	5.1	0.4	200	81.3

Config_Full_3	All Tech OK	0.988	5.1	0.4	200	81.1

Config_Full_4	No ATIS	0.99	5.1	0.4	1362	80.1

Config_Partial_1	No Aero	0.99	5.1	0.4	200	81.3

Config_Partial_2	No LRR Tires	0.99	5.1	0.4	200	81.3

Config_Partial_3	All Tech OK	0.988	5.1	0.4	200	81.1

Config_Partial_4	No ATIS	0.99	5.1	0.4	1362	80.1



While this simplified compliance scenario reduces the number of options
the manufacturer offers its customers, it maintains a degree of
flexibility by not requiring the use of a single make or model of any
technology.  Several vendors and technology models are available today
that meet these qualifications, and the trailer manufacturer would be
able to allow its customers some choice of specific technologies to
apply.   For example, many of the aerodynamic technologies currently
verified by SmartWay are expected to perform at Bin III levels, so
manufacturers would have many options in terms of device design and
manufacturer.  Similarly, there are many LRR tire options, and several
makes and models of tire pressure systems (i.e., ATIS or TPMS).    

The reduced flexibility of this simplified compliance scenario provides
the trailer manufacturer with the lowest compliance burden of the
options evaluated in this memo.  The manufacturer would only need to
evaluate the base technology package that meet the performance criteria
and ensure every trailer sold included, at minimum, that base technology
package.  Any additional technologies added to a trailer would result in
over-compliance and would not benefit the manufacturer in this scenario.
 The manufacturers would still need to submit an end-of-year production
report to summarize the year’s sales and confirm that a baseline
performance package was installed on each trailer sold.  

MY 2027 Compliance Scenarios 

Beginning in MY 2021, the full- and partial-aero standards no longer
match.  The full-aero standards progressively increase in stringency
until they are fully phased-in by MY 2027.  The standard for full-aero
long box dry vans is 75.7 g CO2/ton-mile in MY 2027, and the trailers
sold by the trailer manufacturer would have to include higher performing
technologies to comply.  The partial-aero stringency increases in MY
2021 to reflect the use of higher-performing LRR tires and the long box
dry van standard remains constant at 80.6 g CO2/ton-mile in the years
that follow.  Example 3 demonstrates on set of options for all trailer
configurations to meet the standards.  In Example 4, the trailer
manufacturer opts to use the averaging provisions to meet the standards.

Example 3:  MY 2027 Standard Long Dry Van Compliance Scenario 

In this example, the trailer manufacturer avoids averaging by ensuring
each trailer is sold in a compliant configuration.  Similar to Example
1, the manufacturer allows each customer to choose the technology
combinations.  However, due to the increased stringency, some
technologies cannot be fully avoided as was possible in MY 2018.    REF
_Ref416779299 \h  Table 6  shows the performance parameters applied for
each trailer configuration.

Customer 1 was initially reluctant to include aero on its box vans, but
was given a great deal on a Bin IV aerodynamic package (0.7 m2
improvement) for its full-aero box van order.  It completed its
compliant full-aero van order with advanced tires beyond TRRL 4
performance (4.5 kg/ton), ATIS (1.2% reduction) and Package 6 weight
reduction.  Customer 2 was reluctant to order LRR for its trailers, but
settled on SmartWay-level tires with Bin V aerodynamics, ATIS, and
Package 6 weight reduction for its full-aero trailers.  Customers 3 was
open to most technologies and opted to order trailers with very advanced
aerodynamic improvements (Bin VI), ATIS, TRRL 4 tires and aluminum
wheels on its full-aero order.  To continue to avoid purchasing a tire
pressure system, Customer 4 chose TRRL 4 tires, Bin V aerodynamics, and
Package 6 weight reduction in its full-aero order. The partial-aero box
van orders from each customer were the same as   REF _Ref458460213 \h 
Table 4  in Example 1, except that the tire performances increased by
one TRRL; Customer 2 ordered SmartWay-level tires and the others ordered
TRRL 4 tires.  

Table   SEQ Table \* ARABIC  6 :  Example Performance Parameters for
Four Customers in a MY 2027 Standard Compliance Scenario; MY 2027
standard is 75.7 g/ton-mi for full-aero and 80.6 for partial-aero 

Trailer	Preference	C5	TRRL

(kg/ton)	DCdA

(m2)	Weight Reduction

(lb)	CO2 

(g/ton-mi)

Config_Full_1	No Aero	0.988	4.5	0.7	2956	75.6

Config_Full_2	No LRR Tires	0.988	5.1	1.0	2956	74.8

Config_Full_3	All Tech OK	0.988	4.7	1.4	200	74.7

Config_Full_4	No ATIS	1.000	4.7	1.0	2956	75.1

Config_Partial_1	No Aero	0.990	4.7	0.0	2956	80.1

Config_Partial_2	No LRR Tires	0.988	5.1	0.4	1562	79.7

Config_Partial_3	All Tech OK	0.988	4.7	0.4	0	80.6

Config_Partial_4	No ATIS	1.000	4.7	0.4	1362	80.2



As noted previously, trailer manufacturers that produce over-compliant
trailers do not receive any benefit from them in a non-averaging
compliance strategy.  However, some trailer manufacturers may consider
the relatively few recordkeeping and reporting requirements to be an
acceptable compromise.  Similar to Example 2, a manufacturer may choose
a minimum set of technologies to its customers to ensure compliance in
MY 2027.  The process is similar to the previous example and an
additional example is not shown for this standard.

Example 4:  MY 2027 Averaging Long Dry Van Compliance Scenario 

In this scenario, the trailer manufacturer chose to use the averaging
provisions for its full-aero box vans.  This compliance approach allows
the manufacturer to offer its customers the largest range of technology
options for their trailers.  This example shows that the four
customers’ technology preferences that were outlined previously in  
REF _Ref416327515 \h  Table 3  could be better reflected in an averaging
scenario; the customers that wanted fewer (or no) technologies could be
accommodated.  However, it is noted that trailer manufacturer adopting
an averaging scenario would have additional reporting and recordkeeping
requirements, and would likely need to monitor both the performance
level and production volume of their trailers sold throughout the model
year to ensure end-of-year compliance.  

During the certification application process, a manufacturer that wishes
to use the averaging provisions would identify trailer “subfamilies”
that have similar performance.  The technology packages used in each
subfamily would have unique target performance values, or Family
Emission Limits (FELs).  When averaging is not applied, subfamilies are
not necessary, since every trailer produced would meet the standards. 
In an averaging compliance strategy, as described next, a
production-weighted average of the FELs is used to determine compliance.


  REF _Ref416352346 \h  Table 7  illustrates the technology choices of
the four customers for the full-aero box vans in this averaging
scenario, highlighting the values assigned to the technologies they
wished to avoid.  The partial-aero box vans are not eligible for
averaging and are unchanged from Example 3.  The order from Customer 3
in Example 3 included advanced Bin VI aerodynamics, tires with the
lowest rolling resistance, ATIS, and aluminum wheels for a small weight
reduction.  Since Customer 3 has a relatively large order, the trailer
manufacturer was able to promote additional weight-reducing component
substitutions (Packages 3 and 5), which resulted in larger CO2
reductions for the trailer manufacturer.  Customer 3’s order resulted
in CO2 reductions well below what was needed for the manufacturer to
comply with the standard with a value of 72.9 g CO2/ton-mi.  Because of
this over-compliance for part if its production, the manufacturer could
offer trailers with fewer technologies to its other customers.  

In Example 3, Customer 1 was willing to order trailers with advanced LRR
tires, ATI systems, and the largest weight reduction option (Package 6)
and reluctantly adopted Bin III aerodynamics.  However, with averaging,
the manufacturer could allow this customer to purchase trailers without
any aerodynamic technologies.  The absence of aerodynamics on these
trailers resulted in under-compliant trailers with an FEL at 79.6
g/ton-mi.  Customer 2 preferred not to adopt LRR tires, but maintained
the ATIS, Bin V aerodynamics and Package 6 weight reduction from Example
3 and the FEL for this order was 76.3 g/ton-mi.  Since Customer 4 was
still willing to order its trailers with Bin V aerodynamics, the TRRL 4
tires, and Package 6 weight reduction, it was able to continue to avoid
a tire pressure system and achieve an over-compliant FEL of 75.1
g/ton-mi.      

Table   SEQ Table \* ARABIC  7 :  Example Technology Adoption Rates for
Four Customers in a MY 2021 Averaging Scenario with Four Subfamilies; MY
2027 standard for full-aero is 75.7 g/ton-mile

Trailer	Preference	C5	TRRL

(kg/ton)	DCdA

(m2)	Weight Reduction

(lb)	CO2

(g/ton-mi)	Trailer

Order

Config_Full_1	No Aero	0.988	4.5	0.0	2956	79.6	30

Config_Full_2	No LRR Tires	0.988	6.0	1.0	2956	76.3	10

Config_Full_3	All Tech OK	0.988	4.7	1.4	2002	72.9	40

Config_Full_4	No ATIS	1.000	4.7	1.0	2956	75.1	20



In this scenario, each order results in a unique CO2 value.  Therefore,
each trailer order becomes a subfamily within the long dry van family,
and the CO2 results become the FELs for the subfamilies.  The
manufacturer calculated a production-weighted average of all its FELs as
follows: 30% x 79.6 g/ton-mi + 10% x 76.3 g/ton-mi + 40% x 72.9 g/ton-mi
+ 20% x 75.1 g/ton-mi to arrive at the overall compliance level of 75.7
g/ton-mi.  Since this level exactly matches the standard in MY 2027, the
manufacturer would be in compliance with the standard for this model
year.  

In summary, Example 4 shows how averaging can give a manufacturer more
flexibility to meet its customers’ individual preferences. 
Specifically, 40 percent of the sales in this averaging example did not
meet the overall standard for this model year and 60 percent of the
orders were able to completely avoid a technology.  This strategy could
be valuable for trailer manufacturers that have customers willing to
purchase sufficient numbers of trailers with higher-performing
technologies to offset orders from customers that prefer fewer or
lower-performing technologies.  However, this approach can be
challenging if all of a manufacturer’s customers demand
lower-performing trailers.  

The flexibility of averaging comes with an increased compliance burden
in terms of number of subfamilies and CO2 calculations, increased
tracking of sales, and increased end-of-year reporting to the agencies,
as well as the potential for more complex interactions with customers in
sales negotiations.  All trailer manufacturers submit an end-of-year
production report to EPA that summarizes their annual sales.  Trailer
manufacturers that adopt an averaging compliance approach would include
a description of the subfamilies in their application for certification,
and would submit a second end-of-year report that describes their
averaging strategy and the results for each of their subfamilies.  These
manufacturers would not need to ensure that every trailer produced
throughout the year met the standard.  However, they would benefit from
keeping record throughout the year of the volume of sales and an
estimate of the CO2 (and fuel consumption) level for each sale to ensure
that under-complying trailer sales do not account for a majority of the
overall sales for the year.  Otherwise, a manufacturer could be in a
situation where they create a large deficit that will require
significant over-compliance in the following years.

Final Notes

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more effective to substitute light-weight components in lieu of adopting
other technology options.  The attached Excel template can be used to
repeat the examples presented here and to evaluate other compliance
strategies.  

Attachment:  MemoAttachment_ExampleTrailerCO2EmissionsCalcs_FRM.xlsx

 Manufacturers that opt into an averaging program in MY 2027 and later
cannot sell trailers with zero CO2 or fuel consumption improvements
(i.e., “no control” trailers).  The agencies are adopting a maximum
FEL that requires manufacturers to at least meet MY 2018 standards or
better on all trailers.  See 40 CFR 1037.10(a)(5).  

Example Compliance Scenarios for the Final HD GHG Phase 2 Trailer
Program, Page   PAGE  8  of   NUMPAGES   10 

