Proposed EPA and NHTSA Regulation
of Commercial Trailers Used with
Combination Tractors
Brief answers to common questions about EPA's and
NHTSA's proposed regulation of trailers.
Why Are EPA and NHTSA Proposing To Regulate Trailers?
EPA and DOT each have statutory responsibilities to control heavy-duty vehicle
pollutant emissions and fuel consumption. Trailers pulled by combination tractors
are part of that vehicle. Trailers contribute significantly to carbon pollution emis-
sions, and to the vehicle's fuel consumption. Cost-effective technologies, including
aerodynamic devices, low rolling resistance tires, and automatic tire inflation systems
can offer significant CO2 emissions and fuel use reductions for the vehicle, provid-
ing a benefit to the environment and the nation's energy security, and reducing fuel
costs.
When Would The Proposed Reg u I at ions Take Effect?
Initial proposed standards for trailers would apply beginning January 1, 2018 in the
EPA program. NHTSA's trailer standards would be voluntary from 2018 to 2020,
becoming mandatory in 2021. The standards would gradually increase in stringency
in model years 2021 and 2024, and the most stringent requirements would not apply
until model year 2027. During these years manufacturers would make incrementally
greater improvements to their new trailers to increase fuel efficiency and reduce CO2
emissions.
How Do EPA's Regulations Relate To NHTSA's Regulations?
NHTSA's proposed fuel consumption standards are authorized under the Energy In-
dependence and Security Act of 2007, and EPA's proposed GHG emission standards
are authorized under the Clean Air Act,
EPA-420-F-15-902
June 2015
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EPA and NHTSA worked very closely to ensure that EPA's CO2 proposed regulations and
NHTSA's proposed fuel efficiency regulations are fully harmonized. The agencies also propose
that manufacturers would submit a single report to show compliance with both programs.
What AreThe New Regulations Being Proposed forTrailers?
The proposed program is designed with separate performance-based standards for four box
trailer subcategories:
• Long'box dry vans
• Long'box refrigerated vans
• Short-box dry vans
• Short-box refrigerated vans
Box trailer manufacturers can choose the combination of technologies they believe are right for
the market, which include:
• Aerodynamic devices
• Lower rolling resistance tires
• Automatic tire inflation systems
• Light'weight components
Box trailers with work-performing devices that inhibit the use or effectiveness of aerodynamic
technologies may be eligible to meet reduced standards,
Non-box trailers (including platform/flatbed, tank, container chassis and other specialty trail-
ers) would be required to use lower rolling resistance tires and automatic tire inflation systems,
What is NOT Covered?
The agencies are only regulating heavy-duty trailers pulled by tractors. Certain specialized
trailers such as logging, mining, and livestock trailers, and trailers intended for temporary or
permanent residence or office space (mobile homes and campers) would not be subject to new
regulatory requirements,
What Are the Benefits of the Trailer Standard?
The CO2 and fuel consumption reductions vary based on trailer type, technologies already in-
corporated, typical operation, and miles traveled. Compared to conventional trailers, the fully
phased-in program would result in CO2 and fuel consumption reductions up to 8 percent for
2027 model year trailers, depending on the type of trailer.
The agencies projected fuel savings for new trailers of all types by model year in combination
with the tractors. We project that all model year 2027 combination tractor-trailer vehicles will
save up to $20 billion over their lifetimes as a result of the new standards. We also estimate
that as much as one-quarter of those savings would result from the trailer standards. This could
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translate to $20,000 fuel savings over the life of the average model year 2027 trailer. Such sav-
ings would fully offset the additional costs associated with these more fuel efficient trailers in less
than two years.
Are New or Untested Technologies Required to Meet the Standard?
Most of the technologies that would enable trailers to meet the standard are already on the road,
and are used by many leading fleets to reduce fuel costs. EPA's voluntary SmartWay program
helps freight companies identify operational strategies, equipment and technologies that save
fuel and lower emissions, and many of the SmartWay-verified trailer technologies could be used
to meet the proposed standards. SmartWay has verified trailer technologies that reduce fuel use
and GHG emission since 2005, and designated SmartWay tractors and trailers since 2007.
Would The Proposed Standards Limit The Type Of Features Available
On Trailers In The Marketplace?
No. EPA and NHTSA consulted extensively with trailer manufacturers and fleet owners to
design proposed standards that would not limit trailer features or compromise trailer capabilities.
The technologies that could be used to meet the standards would offer fuel savings that would
offset any additional up-front cost increase within a reasonable timeframe.
Can I Still Use My Old Trailer?
Yes. These proposed standards only apply for new trailers. There is no requirement for owners
or operators to retire or retrofit trailers.
AreThere Any Compliance Flexibilities Available?
Yes. Trailer manufacturers have emphasized to us the importance of simplicity. The agencies
are proposing a simplified compliance program with options to demonstrate trailer performance
without requiring the trailer manufacturers to perform device testing or vehicle modeling.
In addition, trailer manufacturers have indicated that unique manufacturer-customer relation-
ships make it challenging for them to benefit from multi-year flexibilities such as traditional
averaging, banking and trading programs. Instead, we are proposing a more limited approach in
which manufacturers could comply by ensuring that the average performance of all the trailers
they sell for a single model year meet the standard for that same year. Comments on the proposal
will help the agencies to further simplify the compliance program,
Did The Agencies Seek Input From Small Manufacturers?
Yes. Both agencies consider small business impacts under the Regulatory Flexibilities Act. Ad-
ditionally, in accordance with the Small Business Regulatory Enforcement Fairness Act, EPA
conducted a formal process to solicit input from representative small businesses. The conclu-
sions of that process are reported in detail in the proposed rule.
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What Regulatory Relief Or Flexibilities Are Proposed For Small
Businesses?
Because so many trailer manufacturers are small businesses, the agencies designed the entire
trailer program to work for small businesses. In addition, the agencies are proposing that those
trailer manufacturers that have less than 500 employees and qualify as small businesses may
begin compliance in MY 2019, one year after the rest of the industry. This would provide small
businesses with additional lead time to make any staffing, process, or production adjustments
that may be necessary to meet the proposed requirements.
How Do I Provide Input On The Proposed Regulations?
The agencies welcome your input on this proposed rule. Further information on opportuni-
ties for public participation may be found on EPA's and NHTSA's websites (see below for more
information). You should consult the Federal Register notice for this proposal for more informa'
tion about how to submit comments, when the comment period will close, and about where and
when public hearings will be held. You can access the proposed joint rules and related docu-
ments on EPA's Office of Transportation and Air Quality (OTAQ) Web site at:
www.epa.gov/otaq/climate/regulations.htm ,
You can access the proposed joint rules and related documents, including the Draft Environmen-
tal Impact Statement, on NHTSA's Fuel Economy Web site at:
www.nhtsa.gov/fuel-economy
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