September 27, 2017…

September 27, 2017
Katerina Minaeva
Senior Policy Analyst
Ministry of Transportation
Policy and Planning Division
Transportation Planning Branch
Environmental Policy Office (Toronto)
777 Bay Street
Suite 700
Toronto Ontario
M7A 2J8
Phone: (416) 585-6310

Dear Madam:

Pursuant to the subject request for comments, STEMCO is pleased to provide the following:

About STEMCO

STEMCO is a leader in the technology and manufacture of commercial vehicle wheel end, braking and suspension components, trailer aerodynamic devices (including the TrailerTail® product line), automatic tire inflation systems (ATIS, including the Aeris® product line), and other innovative tire and mileage solutions. STEMCO is an EnPro Industries, Inc. (NYSE: NPO) company with offices and manufacturing facilities in Texas, Georgia, Michigan, Kentucky, Tennessee, Ohio, California, Mexico, Canada and China. EnPro is a leader in the manufacture of sealing technologies and engineered products for use in critical applications by industries worldwide. For more information, please consult the STEMCO website at www.stemco.com.

Executive Summary

•  STEMCO welcomes Ontario Policy and Planning Division partnership with the trucking industry for the common goal of conserving limited resources and promoting a sustainable environment.
•  STEMCO recommends that the most recent commercial vehicle standards, Phase 2 of the Canadian Heavy-duty Vehicle and Engine Greenhouse Gas Emission Regulations, be referenced as the certification verification method in the GCVP. In this standard devices are measure by ΔCdA and not percent fuel savings. Qualifying devices should achieve at minimum a Bin III result.
•  Alternatively, STEMCO recommends that the minimum performance for a qualifying fuel saving aerodynamic device be 5% under the SmartWay program
•  STEMCO recommends that all eligible devices provide a minimum 3 year warranty

Detailed Comments

We support Ontario Policy and Planning Division’s effort to reduce greenhouse gas emissions in the transportation industry while at the same time recognizing the complexity of implementing this province-wide program. Because our products related to this regulation are primarily installed on trailers, our comments will apply only to the Trailer related portions of the proposal. In general, we believe that this proposal outlines appropriate standard for achieving the goal of significant environmental improvements.

Stemco recommends that the Ontario Green Commercial Vehicle Program uses the most up to date regulations for verifying trailer aerodynamic performance. The industry in general does not have much trust in certified performance values. Part of this mistrust comes from past certification regulations not being strict enough in testing protocol and allowing too many test parameter variations that device manufacturers can take advantage of to make a product look better than it is. A study by NRC published in Transport Canada hinted towards the fact that some currently certified devices did not provide a measurable benefit (https://www.tc.gc.ca/eng/programs/environment-etv-menu-eng-2980.html). Newer regulations attempt to close these loopholes by restricting to specific testing types and providing more detailed definition of test methods and conditions. The newest certification requirements in use in the US and Canada are described in Title 40, Chapter I, Subchapter U, Part 1037.211 . A multitude of manufacturers are prepared for the implementation of the new program and have completed certification using the new testing requirements. By restricting approved devices to those that have received a preliminary approval letter from the EPA, the Green Commercial Vehicle Program will ensure that only validated high performing aerodynamic devices are eligible for government funding. We recommend that the GCVP uses the new program and restrict rebates to trailer skirts and other trailer aerodynamic devices that, at minimum, fall in the Bin III device level (0.4 to 0.7 ΔCdA). The other benefit of using the EPA certification program is that it reduces the burden on manufacturers to maintain certifications in the SmartWay program. The SmartWay program is being phased out in favor of the new EPA program. Canada, US and CARB are all transferring to performance requirements to be based around the new certification program highlighting drag coefficient improvements.

Alternatively, if the EPA certification system cannot be used for the GCVP, Stemco recommends that the program increase the minimum percent fuel savings SmartWay certification from 4% to 5%. If a newer testing standard cannot be used, requiring a higher level of performance will provide a greater level of insurance against the wide range of testing variations. Devices that save 5% fuel and greater have been available for many years and often for the same cost as a 4% device. Half of the devices listed on the SmartWay website achieve 5% or greater fuel savings. By requiring a 5% device, more fuel savings is achieved per taxpayer dollar.

Stemco also recommends that eligible fuel saving devices be required to provide a minimum 3 year warranty that the product is free from defects in material and workmanship. A warranty will help insure that the money spent on fuel saving devices is recuperated, as the typical payback period is 1-2 years on most devices. This requirement is similar to requirements in place with the Phase 2 of the Canadian Heavy-duty Vehicle and Engine Greenhouse Gas Emission Regulations and therefore should not put additional strain on manufacturers.

STEMCO is grateful to the Ontario Policy and Planning Division for this opportunity to comment on the Green Commercial Vehicle Program. We look forward to answering any follow-up questions or requests for additional data.

Sincerely,

Drake Piper
VP Innovative Tire and Mileage Solutions STEMCO

[Original Comment ID: 211122]