The Truck Renting and Leasing Association recently submitted comments on proposed GHG rule changes to the Environmental Protection Agency and the National Highway Transportation Safety administration. The new rules cover increasingly strict reductions in greenhouse gas emissions from commercial vehicles.
TRALA’s comments focused in large part on the cost to comply with the new rules. According to discussions with both trucking members as well as engineering experts at OEM member companies, compliance costs will most likely be much higher than the agencies have proposed. In its comments, TRALA detailed how the truck renting and leasing industry is disproportionately impacted by higher upfront costs and often is unable to recoup fuel savings due to the fact that they do not operate their vehicles. TRALA's comments also illustrated the concern that the agencies' technology assumptions are overly optimistic.
TRALA also pushed back on the EPA and NHTSA over concerns with future rule changes to air quality or safety requirements which could further complicate an OEM's ability to meet the greenhouse gas reductions standards. Specifically, TRALA has concerns that a future reduction in the NOx standard by the California Air Resources Board (CARB) could significantly hinder an OEM's ability to meet emissions requirements in Phase II. TRALA urged the agencies to continue its dialogue with CARB to ensure that it adheres to one national standard.
Additionally, TRALA strongly opposed Alternative 4, which would expedite the implementation process from 2027 to 2024. This timeline would lead to an unworkable standard requiring several extensions, higher research and development costs for OEMs, and higher purchasing costs.
As background, on July 13, the EPA and NHTSA released Phase II of their push to reduce greenhouse gases from trucks. This proposal expands on the first greenhouse gas regulations by further reducing the amount of carbon emitted from new model tractors, engines, and trailers between 2017 and 2027. For tractors, and trailers these changes will be implemented in phases with the first benchmark in 2021, the second benchmark in 2024 and then the final goal in 2027.