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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