FREQUENTLY ASKED QUESTIONS ABOUT GHG2
Answers to GHG2
Questions
In response to a great number of recent
questions regarding GHG2 for trailers we have compiled a list of the most
popular, along with the answers. The
situation is still somewhat confusing, but we are always available to help with
any questions that you might have.
FREQUENTLY ASKED QUESTIONS ABOUT GHG2
In response to a great number of recent
questions regarding GHG2 for trailers we have compiled a list of the most
popular, along with the answers. The
situation is still somewhat confusing, but we are always available to help with
any questions that you might have.
1. Is
the regulation even final? I’ve heard
that it might be thrown out completely.
a.
The short answer is yes, the regulation is final
and is set to implement on January 1st. The long answer is, in August, EPA announced
that they were putting the trailer portion of GHG2 through their review
process. This process can take several
months or longer. Currently there is
litigation between TTMA and EPA. TTMA
has asked a federal court to either throw out the trailer portion of the
regulation completely or, at least postpone the regulation until the EPA
completes its review process. There is
no timetable on when to expect a decision from the court. It could be a few days or months.
2. If the regulation is postponed or thrown
out, does this also apply to California?
a.
No. The
California rules still apply. The CARB
regulations were expected to “sunset” after GHG2 was implemented, but
California has indicated that they will keep the regulations if GHG2 for
trailers is delayed or cancelled. CARB has joined in the litigation between
TTMA and EPA as a State Intervenor, along with the states of Vermont, Massachusetts,
Connecticut, Washington, Oregon, Rhode Island and Iowa.
3. Will all trailers be regulated? I understand that this only applies to 53’
trailers.
a.
All trailers will be subject to the regulation. Compliance requirements will vary, depending
on the trailer type and length.
4. What will be required on a typical trailer to
be compliant with GHG2?
a.
There are various options available, but the
most typical combination for a 53’ trailer will be a Bin 3 side skirt,
low-rolling resistance tires, and a tire inflation system.
5. What is Bin 3? What does that mean?
a.
In the GHG2 regulation, EPA uses a drag
reduction standard instead of a fuel reduction standard. Every device will be assigned a drag
reduction number. In order to meet Bin 3
requirements, the device’s drag reduction number must exceed .40.
6. Does TrailerBlade make a Bin 3 device?
a.
Yes. Our
standard product well exceeds the Bin 3 requirement. We also have developed 9 different additional
configurations that exceed the Bin 3 minimum requirement.
7.
Has
TrailerBlade been officially certified under the new standard?
a.
Yes. We
received our certification letter from EPA in September.
8. If I order a trailer today for delivery
after January 1, 2018, will it need to be equipped with a side skirt?
a.
As of today, yes. If the ruling is postponed or eliminated
before your production date, you might presumably be able to cancel the aerodynamic
device, but that will depend on your trailer manufacturer.
9. Currently my dealer installs my aerodynamic
devices. I have heard that this will no
longer be allowed. Is this really true?
a.
No, this is not true. The regulations allow for trailer
manufacturers to designate installers, typically their dealers or the aero
device manufacturers, to install the product after the trailer has left the
plant but before the trailer is delivered to the customer. A manufacturer may have come up with a
different policy on their own, but the regulation allows dealers to continue
installing aero devices.
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