The Minnesota Trucking Association recently submitted the following to the EPA:
Filed via Federal eRulemaking Portal: https://www.regulations.gov
EPA Docket Center
WJC West Building, Room 3334
1301 Constitution Avenue NW
Washington, DC 20004
RE: Comments on EPA “Control of Air Pollution From New Motor Vehicles: Heavy-Duty Engine and Vehicle Standards, Proposed Rule” Inducement Provisions, Docket EPA-HQ-OAR-2019-0055
To Whom It May Concern:
We file these comments in support of the revised inducement provisions under EPA’s proposed low-NOx rule. The trucking industry understands EPA’s rationale behind low-speed de-rates after: (1) there are three hours of Diesel Emission Fluid (DEF) remaining in the tank; (2) DEF quality fails to meet manufacturers’ concentration specifications; or (3) when certain SCR system tampering events have occurred. Current speed derating to five miles per hour within four hours of detecting certain NOx fault conditions pose on-going concerns over driver safety and presents potential hazards for all vehicles operating on roadways due to the stark speed differentials being created.
Fleets nor drivers wish to experience derate episodes which have the potential to create both safety and delivery concerns. Yet, following more than a decade of experience, derates are still occurring at unexpected rates and do not involve inadequate DEF levels or quality, but rather a variety of other reasons particularly faulty sensors. Trucking companies that cannot deliver goods in a timely manner lose hauling contracts and suffer financially – the last thing a fleet manager wants. This is why fleets routinely check DEF fluid levels and purchase DEF from reputable sources.
The proposed changes for the freight sector reduce truck speeds in 5 mph increments beginning at 65 mph and ending at 50 mph at 60 hours of engine operation. Our member fleets have indicated this modification should ensure adequate time for drivers to reach repair facilities while avoiding operating at unsafe speeds or the need to have their vehicles towed which can cost thousands of dollars. Other considerations include providing adequate time for vehicles operating in remote areas to reach repair facilities as well as allowing drivers to finish their deliveries should the in-cab display appear during a shift. EPA’s proposed modification will also allow fleets added time to access preferred repair facilities as opposed to the limited choices they may have under the existing derate schedules.
The overriding assumption should be that fleets routinely check all fluid levels and avoid derates at all costs. To do otherwise makes no business sense. Thank you for considering our comments. Together we can work to improve the environment and keep the nation’s goods and economy moving forward.
Sincerely,
John Hausladen
President
Minnesota Trucking Association
