CHAPTER VII. ENVIRONMENTAL SUSTAINABILITY
• Comment regarding the statement on Page 72 regarding ethanol and biodiesel use … ”With the exception of 10 percent ethanol and five percent biodiesel, the requisite codes and standards are not in place that would allow the traveling public or commercial carriers to use alternative fuel.” -- This is a partially correct statement. The EPA has granted waivers for fuel containing up to 15% ethanol (E15) gasoline for model year 2001 and newer cars and light truck. However, according to DOE, there are more than 90 state laws and regulations currently limiting sales of E15 in more than 30 states. Some state restrictions in conflict include a 10% ethanol blend cap, state biofuels mandates, technical fuel specification standards, and waivers. EPA has, however, approved the sale of E-15 gasoline blends at limited locations in six states to date. As for 85% ethanol (E85) gasoline, there are already more than 2,400 U.S. fueling stations that offer E85 to the over 8 million flex-fuel vehicles on U.S. roadways. E85 is available in more than 40 states with a concentration in the Corn Belt states. Regarding biodiesel use, blends of up to 19% biodiesel (B-19), are currently sold in the U.S. and biodiesel retail sales above 5% blends across the country are not uncommon. Specific to trucking, almost all truck warranties allow the use of up to B20 biodiesel blends. Biodiesel is also required to meet ASTM 975 quality standards as well.
• Comment regarding truck speed governors as an additional sustainability strategy -- DOT should add the concept of reducing speed as a strategy to reduce foreign oil dependence and carbon emissions. Current ATA policy calls for all new Class 7 and 8 trucks to have their top speed electronically limited to no more than 65 mph at the time of manufacture. The goal of this initiative is to assure that both environmental and safety benefits of setting a maximum governed truck speed are realized across the trucking industry and by the motoring public. ATA petitioned the U.S. Department of Transportation (DOT) to initiate a rulemaking to implement the adopted policy. In 2011, NHTSA granted petitions of ATA and the Road Safe America (RSA) Coalition to establish a safety standard to require devices that would limit the speed of certain heavy trucks. The industry now awaits an NPRM from NHTSA to mandate speed governors in Class 7 & 8 trucks.
• Comment regarding DOT and EPA joint greenhouse gas/fuel consumption regulations for trucks on Page 65 -- While DOT references the aforementioned rule for model year 2014-2018 trucks (given the 5-year strategy planning objective), there is no reference to the second round of regulations currently under development by EPA and NHTSA which will take effect post 2018. NHTSA, under the authority of the Energy Independence and Security Act of 2007, is currently working with the National Academies in assessing truck fuel consumption strategies to be considered in the second phase of the rule. A final report is likely due in 2015. ATA recommends that these current efforts should be referenced in the report given the significant impact this work will have on the industry’s fuel consumption levels and its carbon footprint beyond 2018.
• Comment regarding natural gas use in the industry on Page 72 – Natural gas use in transportation is listed under the “External Risk Factor” category and is not even referenced in the first paragraph as a transitional fuel. While not expected to supplant diesel fuel in the short-term planning timeframe, the potential for trucks transitioning to this cheaper and lower greenhouse gas/particulate matter/nitrogen oxide emitting fuel should be given more deference in the plan. While the refuse and bus industry has widely embraced the use of natural gas for quite some time, an orderly transition to natural gas as an alternative transportation fuel for trucking continues to gain momentum.