Assessment of Fuel Economy Technologies for Medium and Heavy ...

e defined as something similar to ‗percent of miles of travel on roads within Census Urban
Area boundaries,‘ trucks that travel half in the city and half outside of the city represent a
likely marginal case. Trucks meeting the marginal description are likely to be trucks that, for
example, carry goods between warehouses on the urban fringe and urban retailers. These
carriers would likely make the argument that their travel was most often inside of the urbanarea
boundary and, therefore, they should not be required to install fairings. They are not
likely to shift classes to avoid regulation, as their shipments are not likely to change.
Monitoring and enforcement of such a regulation would likely be a challenge, especially
without the deployment of technologies such as global positioning systems (GPS) monitors as
a basis for charging VMT fees. Additionally, urban area boundaries change after each
decennial census, further reducing the practicality of this type of regulation.
Regulations that impact a certain engine size:
Regulations that would impact only a certain engine size would implicitly impact a certain
class truck more than another. For example, if engine regulations were implemented on any
engine with peak horsepower greater than 400, this would select for Class 8 trucks—either
line-haul or other vocational loads. However, any regulations that would increase the
operating cost for an engine sized for Class 8 use would be doing so for the class of trucks
that are least likely to switch. Vocational trucks would still be used for job-specific purposes
and other users of Class 8 trucks are extremely unlikely to shift to smaller trucks because
labor costs would still far outweigh the increased operating cost that would accompany the
required increase in shipments.
For example, a steering column manufacturer in Vermont fills four 53-foot trailer-loads of
steering columns bound for an automobile manufacturing plant in Mississippi. If he were to
shift this into a smaller Class 7 carrying a 28-foot pup trailer, it would take nearly twice as
many truckloads, doubling the total number of shipments. The impact of switching to Class 7
trucks will significantly increase total cost because fuel costs of Class 7 trucks are roughly 75
percent of Class 8 fuel costs ($0.48 compared to $0.634 per mile) and labor is likely to remain
similar since the shipment requirements are comparable. 19 Total labor costs will double (eight
trucks compared to four) and fuel expense will increase by about 50 percent (eight trucks *
$0.48 - four trucks * $0.634), resulting in a much more expensive shipment.
(v) Transportation Service and Performance Effects
Key Question: Are regulations likely to reduce the quality of the services provided by vehicles,
for example by affecting speed, reliability, or cargo capacity If so, what are the implications for
costs and benefits
Discussion: Initial research conducted by ERG for the concurrent white paper suggests that the
impacts of fuel economy regulations on truck engine power output will be minimal, if any.
Therefore, the impacts of fuel economy regulations on quality of service are likely to be minimal
19
Antich, ―Medium-Duty Operating Costs Increase in 2008-CY,‖ reprinted from Work Truck Magazine,
May/June 2009 and American Transportation Research Institute, An Analysis of the Operational Costs of
Trucking, December 2008.
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