United States
  Environmental Protection
Air and Radiation                    EPA420-R-05-002
                         January 2005
          Truck Stop Electrification
          Codes and Electrical
          Standards; Notice of Data
          Availability [FRL-7783-3]:
          Summary of Comments

                                                              January 2005
                        of Data
              Transportation and Regional Programs Division
                 Office of Transportation and Air Quality
                 U.S. Environmental Protection Agency

                      U.S. Environmental Protection Agency
            Truck Stop Electrification Codes and Electrical Standards;
                     Notice of Data Availability [FRL-7783-3]
                             Summary of Comments


    1)  Caterpillar, Inc.
    2)  ConocoPhillips Alaska, Inc.
    3)  IdleAire Technologies Corporation
    4)  National Electric Transportation Infrastructure (IWC)
    5)  Phillips and Temro Industries
    6)  Shurepower
    7)  State of Missouri Department of Natural Resources
    8)  Truck Manufacturers Association (TMA)
    9)  Washington State Department of Transportation

Potential TSE Code and Electrical Standards

Note: One commentor submitted a draft standard for TSE as part of their comments. (4)

General Comments:
          Mexican standards for connections may be an additional area of interest given
          the large number of trucks that may pass through our southern borders. (9)
       -  The location of oilfields in the remote arctic requires operation of diesel trucks
          on a 24-hour basis during cold ambient conditions, which is a large part of the
          year.  In addition, the North Slope oilfields do not have enough power
          generation capacity to support the TSE initiative envisioned by EPA and the
          U.S. Department of Transportation. We request that EPA clarify in future
          rulemaking that the TSE initiative is not meant to apply to industrial
          applications such as ours, particularly in arctic conditions on the North Slope
          of Alaska. (2)
       -  We would like to express our support for the effort to develop uniform
          national standards for truck stop electrification (TSE) infrastructure.  As the
          number of manufacturers and users of TSE technology grows, the lack of
          uniform standards could lead to stranded investments, damage to TSE
          equipment and, worst of all, safety hazards. (7)

On-Board System Power Needs

       What is the kW  power needs? Is it <3 kW, 3-6 kW, or >6 kW?
          Power availability ranging from 3-6 kW is needed (6), (5)
          Based on analysis and study of class 8 trucks equipped with sleeper cabs, and
          considering future trends, we recommend 5kW (with some allowance for
          power factor due to lagging loads, to arrive at 7.2 kVA). (1)
          It depends primarily whether the truck is used extensively in cold weather
          environments, in which case,  it is likely to be equipped with a block  heater, as

      well possibly, with an oil sump and fuel heater. Peak loads without this
      equipment can range to over 7kW; with this equipment, the figure can
      increase to over lOkW. (8)
   -  Over 3 million hours of service data has been compiled into a forecasting
      model to project TSE power demands under varying weather conditions. This
      empirical evidence shows that TSE, taken in  terms of a national average,
      requires an annual power demand of 1.25 kW per space to maintain comfort
      and provide needed power to accessories. Peak power draw by definition is
      greater than this nationwide average. Under conditions of extreme cold, the
      maximum power draw/peak load could reach or exceed 6kW per space. (3)

  Describe the types of devices and their kW needs when operated?

   -  HVAC - heater (2.5/5kW), AC compressor (1.5 kW), fans (.2 kW)
      Interior Electronics - .2 kW
      Block Heaters - 1.5 kW (@120Vac) (3)
      A/C compressor - up to 4 kW, electric heat up to 3kW, battery charging 0 -
      3kW, blowers & lights 0 - 1 kW. Appliances up to 2 kW. (1)
   -  HVAC 1.2 - 2.5 kW; Block Heater 1 .OkW -1.5kW; Lights .200kW; Oil Pan
      Heater .150kW-.300kW; Microwave 1.0 kW ; Refrigerator .140kW; Fuel
      Heater 1.0 kW; Television .150kW ; Fuel/Water Sep 0.06 kW (5), (6)
   -  Television 0.75 kW; VCR or DVD 0.75 kW; Refrigerator 0.180 kW;
      Microwave 1.4 kW; HVAC 4.4 kW; Blockheater 2.5 kW;  Fuel heater 0.350
      kW; Battery charger 0.60 kW (8)

  Should we use peak power needs?

   -  No. (1)
   -  Yes. (6), (8)
   -  Duty cycle graphs of equipment demand versus most probable maximum
      occupancy and/or weather should be incorporated into the power needs to
      provide a reasonable value for expected power demand. An example of this
      can be seen in Article 220 of the NEC where demand factors are applied to
      design loads. Demand factors for TSE should be developed that take
      advantage of empirical data and allow for reasonable design constraints.  (3)

  Should we follow existing codes for feeder and demand calculations or does
   this technology warrant specific codes to follow?

      Since current NEC guidelines do not take into consideration the unique
      characteristics of TSE,  it should be considered part of the TSE implementation
      to also develop specific codes within the NEC. (3)
   -  Yes. (1)
      Standard land-side wiring standards and practices are likely to be sufficient.

   Precautions need to be taken, however, to design wiring, receptacles, and
   plugs to quickly disconnect and be electrically protected if a driver
   inadvertently pulls away without disconnecting the plug. (8)

What are the future trends?

-  Future trends should be those that allow for truck accessories (including
   HVAC) to be connected to AC shore power. (3)
   As land-based connections become more prevalent, the number of
   components and power requirements may increase. Drivers will acquire
   additional components to match the comfort and convenience of their homes.
   There is a trend to accumulate and use more electrical devices, which is partly
   offset by many appliances being designed with higher energy efficiencies. The
   new hours of service are expected to have an impact on the trucking industry
   and TSE.  Trucks will need electrical power for cab temperature control
   (heating or air-conditioning), PLUS, electrical power for entertainment. (1)
   Future trends are as follows: Dedicated truck stop parking spots will be
   increasingly hard to find at locations where drivers want to stop, thus, stand-
   alone solutions will be increasingly important; Public displeasure with idling
   trucks will increase; Fuel and engine maintenance costs will continue to
   increase; therefore truck operator demand for these technologies will increase;
   Just-in-time delivery operational demands and hours-of-service rule changes
   will make stopping at  remote truck stops less appealing. Drivers will want to
   stage their stops very close to origin and destination points; Demand for
   internet and entertainment connections is increasing, as is demand for full
   household capabilities (water & sewer). (8)
   Future trends will most likely see hotel and vehicle power loads combined
   under a single load. (5)

Will power needs increase or decrease?

   It appears that peak power needs will decrease as more efficient methods for
   placing equipment on-board are developed. An example of this would be the
   decreased thermal loss when delivering HVAC directly from inside the truck.
   However, the overall average power needs inside the truck could increase
   (from the current 1.25 kW/space) as drivers become aware of more uses for
   AC power in the truck cab. (3)
   Power demands will likely increase. (5), (8)
   Demand will likely increase, but be partially offset by using increased
   capabilities in power management systems and by leveraging and using on-
   board battery systems during transient peak electrical power demands. (1)
-  Even if the components increase in the cab, measures can be taken to decrease
   power demand.  Although the total and average demands may increase,
   existing technologies can drastically reduce the peak loads (6)

ii. Off-board Power Needs

   General Comment: We suggest that the evaluation also account for power constraints
   that may be present at public rest area facilities (perhaps standardized 120V or 240V).

      What voltage and amperage configuration will supply the off-board needs?
       Should it be 120V, 240V single phase, 280V single phase or some other

          Recommendation for use of 120-volt and 208-volt AC power. (3), (4)
       -   We recommend that initially two 120VAC - 20amp and one 120/208VAC -
          30amp outlets be available to drivers. If future trends dictate that all OEM
          manufacturers are supplying the 120/208 VAC connection, a shift to
          exclusively providing the higher power outlet will  be considered. If a 120/208
          VAC - 30amp connection is provided, the block heater wiring can be
          integrated into a single plug. (6)
          Single phase 240-Volt AC at 30 amps, and use of a 4 wire configuration is
          recommended. (1), (5)
       -   It is clear that we need to design our products to enable our customers to
          simultaneously use as many 120V AC "household" items as possible. A
          significant hurdle, however, is the need, in many cases, to be able to also
          power engine block, oil sump, and fuel heaters (in  winter) and HVAC (in
          summer), all which  run on 120V AC. A better solution would be to leave the
          engine block, oil pan,  and fuel filter heaters on a separate 120VAC
          connection. (8)

      What amperage configuration will best provide the power
       requirement? Is it 20,  30, 50, or some other amperage?

          30 amp service. (3), (8), (5)

       -   Recommend that initially two 120 V-20 amp and one  12/208 V-30
          amp outlets be available to drivers. (6)

      What are the power needs for the transportation refrigerator units?

       -   "Interior-hauling" vehicles (those that transport goods to the Interior US) that
          have the capability to connect to shore power, use  208/3/30 for the required
          shore  power connection. (3)
       -   Inquiries to the major TRU manufacturers indicate that most TRUs can be
          configured to accept 208VAC 3-phase power.(6)
          We defer to our colleagues at the Truck Trailer Manufacturers Association for
          the answer to this question. (8)
       -   Large trailer reefers require a much higher power level than needed for truck
          cabs for hotel loads. A 30 kW reefer unit parked in the sun needs 30 kW.(l)

      Will a voltage above 120V present problems for existing heaters on the
       market? Or does this emphasize the need for truck OEM's to install
       integrated block heaters into the TSE design?

          Any change in the current power requirement of an automotive component
          will cause "problems" in the market. The need to move away from 120Vac for
          block heaters seems insignificant due to 120Vac always being necessary
          inside the truck (for accessories) and for the minimal improvement in
          efficiency by moving to higher voltages on block heaters. In either case, the
          TSE shore power distribution would be designed to offer either 120Vac or
          208Vac. (3)
          Voltage above 120 V will present problems for existing heaters on the
          market. (8)
          We recommend that trucks continue the long-standing practice of plugging in
          a separate 120 V cable for the engine block heater to handle extreme cold
          conditions. (1)

HI. Connection Compatibility and Safety

   General Comment: If RVs and trucks are meant to have compatible
   connections, then competition between vehicle types for space may be an
   issue. Also, if public rest areas are used for electrification, foolproof systems
   of connections (or connection indicators) are needed so that pulling away
   without disconnecting would not harm persons or equipment (9)

      What plug configuration should be used?

       -   There are two pedestal outlet configurations that will meet most truck needs
          and will use readily available  and proven plug configurations.
             o   The first configuration is all 120VAC and has two 20 amp GFCI
                 outlets and one 30 amp ground outlet. The 30 amp outlet is NEMA
                 TT-30R, which is used by a majority  of RVs. One of the two 20
                 GFCI outlets is used for vehicle (block heater) loads while the other is
                 used for small HVAC.
             o   The second configuration will see the inclusion of a NEMA 14-3OR
                 outlet. The outlet has 4 wires with 2 hot 120VAC connections, a
                 ground and neutral. (1), (5)

          It will be necessary  and appropriate to consider using a twist/lock style plug
          that will only energize if/when properly installed.  Something capable of
          delivering 208Vac and up to 30 amps will be needed to support TSE. We
          suggest exploring a TSE-specific configuration, with breakaway capabilities.

       -   We recommend two outlets with the dual (or "T") configuration that can
          accept either 15 or 20 amp 120VAC plugs (NEMA 5-15P or 5-20P). This
          outlet should accommodate either plug and be rated at 20 amps.  We

          recommend either a 120/240 VAC or 120/20 8 VAC NEMA approved
          receptacle rated for SOamps (over 6kW total power). (6)
          Currently, a standard 3-prong plug is most widely used.  If in the future, a 240
          VAC line at 30 amps is provided, a standardized plug should be used. (8)

   Should the block heater connection be considered as part of the truck-mounted
   TSE system?
  Should power management be required, and if so where should it be installed, on
   the truck or within the connection facility?

       -   Although power management should be a design requirement for the truck
          and the facility, it will be imperative that the facility is designed to handle
          power distribution to all variations of truck designs in a safe manner. (3)
          Power management should be installed within the TSE facility. (8)
       -   If power management or "load management" is to be recommended or
          required, it should be located on the vehicle (6)
          A power manager controller will be required to handle(manage) the electrical
          power needs. Its location needs to be on-board the truck so that power
          management schemes can be tailored to best address the needs, or the devices,
          that the customer has installed and is using.  (1)

  Should multiple configurations be available on a percentage of use basis, as is
   done at RV campsites?
      It is reasonable to expect that users would be charged on the basis of how many
      lines/circuits they used and only be charged for the power they consume (8)

  How should the user be required to interface with the TSE system for questions
   and  payment?

      The user interface should take place inside the truck. However, it could be said
      that this aspect of TSE is not one that should be within the codes and standards
      but instead up  to the facility. (3)
   -  NY's TSE sites are demonstrating a payment system that addresses customer
      needs. A kiosk or ATM station should be utilized that accepts credit/debit/or fuel
      card payment,  which activates the pedestal for the select number of hours (1)

  What type of safety considerations should be included in developing the TSE

   -  Grounding standards, in addition to normal safety considerations, must limit
      interference with onboard electrical and electronic systems.(S)

   -   Ground fault protection, over-current protection, weather-proof plugs and
       receptacles. (1)

  Which grounding standard should be adopted for truck on-board and facility

   -   UL/CSA  (6), (8)
   -   The truck frame should be grounded and GFI circuitry implemented (1)

  Should power be distributed in any certain manner?

       It should only be required that all codes and safeguards are followed recognizing
       the design setting.. .the truck stop environment. (3)
   -   We believe this is best left to the truck OEMs and suppliers of idle reduction
       systems (1)
       GFCI and circuit protection should exist at the power source and/or on the
       vehicle.  General safety standards as recommended by NEC and local codes
       should also be followed. (6)

  Should power be available at any distance away from the vehicle?

   -   There may be an occasional need/desire to operate some 120VAC electrical
       devise outside a parked vehicle (8)
       Any TSE design should allow for safe user interface via delivery module or cord
       so long as the distance from the truck to the TSE interface is within an allowable
       distance for proper power distribution. (3)
   -   Distribution should be limited to avoid excessive voltage drop and cable size. The
       national TSE code/standard needs to address pedestal designs (1)

  Should electrical safety measures (GFCI, fuses, breakers, etc.) be present on the
   truck, at the connection facility, in the connection wiring, or a combination of

   -   Combination as  needed for safety (8)
       Electrical safety must be addressed on all locations of the truck and facility. (3)
       The safety measures should be installed at the connection facility (1)

  What sort of safeguards should be in place to verify that the driver only
   energizes his/her parking space?

   -   "No Pay/No Power" requires that the driver not only attempt to pay for service
       but is also approved first before power is supplies to any connection to the truck.
       This also would require that the system be designed such that
       payment/transactions cannot begin unless the user has plugged in properly. (3)
   -   TSE systems should be "safe" regardless of whether power is energized or not (1)

  What safety measures (like auto-eject connectors or break-away connections,
   engine/transmission/emergency brake system interlocks, visual indicators, or
   other equipment) should be integrated into the TSE system to prevent structural
   damage, should users pull away while still connected?

       All aspects of the design that interface with the driver should incorporate
       breakaway features (3)
   -   Break away cord or plug (5), (6), (8)
       Safety measures should be added into the pre-trip installation (8)
       Perhaps a lock box or lock-out device (5), (9)
   -   One of the following safety measures should be required: 120VAC -15&20amp
       cords; Auto-eject connectors; Transmission or brake interlock; or Visual (dash
       indicator) and audible (buzzer/chime). An auto-switching device (between
       onboard and off-board power sources) is recommended when the vehicle is
       capable of generating its own power. (6)
   -   It should be left to the truck OEM, provider of idle-reduction solution system, and
       the customer. A number of measures could be used, such as eliminating engine
       starting and/or parking break release, to activating warning lights and horns, if the
       vehicle engine is started with TSE connected. We also recommend a cable in-line
       breakaway connector be used to minimize damage to both the pedestal and the
       truck mounted outlet. This in-line cable breakaway connector should be
       approximately 2 feet from the truck mounted connector or at a length so as not to
       drag on the ground by a moving truck. (1)

  Should tamper-loop monitoring be required?

   -   Yes. This aspect of the design is far too "easy" and sensible to not be considered a
       requirement. The "Monitoring" of this system is paramount and forces TSE
       implementers to ensure that they have systems in place to watch and manage the
       power distribution safely. (3)
   -   No. (1)

  Are standards  required to ensure safe power supply switching between on-board
   and off-board power sources?

       It should only be required that services are not offered until proper connection is
       established and payment of service is verified (3)
   -   Yes, there is a potential for 3 separate AC power sources: 1. TSE 2. APU 3. AC
       Inverter (1)
       Generally accepted design practice dictates that if a method of powering the 120
       VAC system is on board the truck, the system will automatically detect power at
       the land connection and disconnect the onboard 120 VAC power source (8)

  Should open service neutral protection be standardized on truck mounted

   -   Yes. (1), (3), (8)

iv. System Design

General Comment: The electrical grid standards for truckstops should be shown in the
NEC article 551 much in the same manner as those for RV parks and marine boatyards.
The electrical standards for trucks themselves should be written as a SAE Recommended
Practice. (5)

  What steps should be taken to ensure that modularity of both the truck-mounted
   and facility-based TSE is ensured?

       Implementation of national  codes/standards will help promote and ensure this. (1)

  How should wiring systems of the truck-mounted systems delineate AC and DC
   wiring or high and low voltage wiring (color-coding)?

   -   We are not aware that any standard color coding exists for this purpose.(S)
   -   Recommend use of bright orange coloring for the high voltage DC wiring, such as
       the SAE hybrid vehicle standard. (1), (6)

  What location on the truck (incorporating safety, visibility, and user
   preferences) should be designated as the standard location for the installation of
   the truck-mounted TSE  connection (e.g., driver side, passenger side or front of
   vehicle, fender or cab area)?

   -   Because of the high traffic on  the driver-side of the truck (trucker coming and
       going) it seems most appropriate to keep any and all connections on the passenger
       side. (3)
   -   TSE connection  should be on the driver's side (1), (8), (6)

  How should cab design issues  be approached when determining the impact on
   cab power requirements?

       If cab power requirements can be lowered  by making reasonable standards for
       truck OEM's, it should be considered most beneficial for both truck and facility to
       address those areas inside the cab. One simple example of this would be a
       requirement to reduce truck window glass  emissivity in the interest of lowering
       HVAC loads inside the truck due to radiation. (3)
       OEM's should be encouraged to better insulate cabs. This would help with both
       sound and thermal efficiency.  (1)
   -   The availability of information about the thermal insulation properties of various
       manufacturer's' sleeper berth designs can help drivers/truck buyers decide how
       much power they will need  to  heat/cool these units. (8)

   Should a standardized cab living space be identified to determine the vehicle
   electrical load requirements (heating, ventilation, and air conditioning [HVAC]
   system capability and cab insulation levels)?

       Only for the upfront TSE design parameters should a "standardized cab living
       space" be identified. These minimum standards should be set in place to ensure
       efficient use of TSE, but the OEM's should enjoy the ability to design trucks to
       meet market demand. It is reasonable to assume that over time, as TSE gets
       deployed, market forces would drive the adoption of cabs designed to take
       maximum advantage of TSE, and would drive OEM's to improve such features
       as cab insulation. Here again, for design and recommended practice purposes, it
       seems reasonable to average the  OEM cab living spaces for items such as
       "average volume," "average window area," "average overall insulating
       coefficient," "average infiltration rate," etc. to allow for design load requirements
       to be estimated. (3)
      No, however it may be beneficial to recommend a certain maximum heat
      loss/gain rate through the cab envelope to reduce the average HVAC loads. (6)

  What weight allowances should be permitted for truck-mounted TSE

      Implementing  a weight allowance for TSE and idle reducing systems would
      provide an incentive to truck owners to add the idling reduction systems with the
      knowledge they would not lose truck payload capacity. This would mean that the
      current truck class weight limits  would need to be raised for trucks with truck
      mounted TSE  or idle reduction equipment. (1)
   -  The added weight of this equipment could approach 100 Ibs. (8)
      Idle reduction  technologies in general often increase the weight of the vehicle.
      The 250 pound weight exemption request for idle reduction technologies in the
      Energy Policy Act of 2004 should be sufficient for on-board related TSE
      hardware (6)