TRALA Submits Comments on Greenhouse Gas Rule

Today TRALA submitted its comments to the EPA and NHTSA regarding the impact their new round of greenhouse gas rules will have on the truck renting and leasing industry.  In its comments, TRALA focused on several core areas where it felt that the EPA and NHTSA could make improvements to the final rule.

As background, on July 13, 2015, the Environmental Protection Agency (EPA) and the National Highway Transportation Safety Administration (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. 
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.
To see the full comments submitted by TRALA please click here
If you have any questions regarding TRALA's comments to EPA and NHTSA or the Phase II regulations, please contact Andrew Stasiowski at or at 703-299-9120.