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Impact of Regulatory Issues on Medium-Duty Truck Fleets

January 2016, Work Truck - Feature

by Chris Wolski & Kat Sandoval

For truck fleets — whether it is a Class 3-7 vehicle or not — regulations are often part and parcel of day-to-day operations. Not surprising, fleet managers responsible for medium-duty trucks can look forward to one certainty in 2016; there will be new regulations.

The following are highlights of some of the new rules and regulations that fleet managers may have to take into account in the very near future.

Logging Electronically

One of the biggest changes for truck fleets will be the requirement for electronic logging for drivers operating trucks that are 10,001 pounds gross vehicle weight (GVW) or more and that operate interstate.
While this is a change in the way drivers have to keep logs, it doesn’t change the requirement of who has to keep a log.

“What’s going to happen is the driver who keeps a paper log would now have to switch over to an electronic log under that rule,” explained Tom Bray, lead editor, Transportation Management for J.J. Keller. “That’s going to make a difference to the medium-duty truck fleet managers because they have a lot of drivers who need to keep a log, so they have to switch over to an electronic version.”

Bray noted this means cost, management, and operational issues will have to be taken into account.
Today’s electronic logs are less expensive than they were when first introduced, costing only a few hundred dollars and having relatively inexpensive data costs. The real costs for electronic logs come from what Bray calls the “administrative back office.”

“Where companies have trouble with electronic logs isn’t so much the cost of the system as operating it,” he said. “It’s not just the cost, but the time and the effort that’s a little overbearing on the fleets.”

Overbearing or not, fleets will not have the option to forego the implementation of electronic logs.

“If fleets don’t implement electronic logs, it’ll be a violation of the safety regulations. There will be a fine issued, which will be attached to the carrier’s CSA score just like any other hours of service (HOS) violation is currently. If a fleet gets enough of them, it will get the agency’s attention and they’ll come out and do an investigation. If the fleet is not doing anything to comply, they will order it out of service,” Bray said. “One way or another, fleets have to make the change or pay a lot of fines and put up with a lot of visits.”

Making Fleets Safer

If there’s one issue that is top of mind for every fleet manager today, it’s probably safety. There are several regulations winding their way through the regulatory maze that could change safety requirements for truck fleets and their drivers.

Among the ones that may have the most impact on medium-duty truck fleets is one that’s called “Prohibition of Coercion.”

“What that says is that nobody can force a driver regardless of the size of the vehicle to violate any of the safety regulations,” Bray said.

For instance, if a light is out on the vehicle and the driver points this out and says he or she won’t drive until it’s fixed, and the company forces him or her to drive, then the company is in violation of the rule.

“Technically now there’s a thing in the rule called aiding and abetting and the carriers are responsible for the actions of the drivers, so it’s kind of a fuzzy thing that’s in the rules,” Bray said. “What is changing is that this is will be addressed more directly in the rules. And, nobody involved in the supply chain — the company, shipper, or the receiver — can force the driver to violate the regulations. The biggest thing that’s going to change for the medium-duty carrier is how they deal with driver issues. This is one of those things that a good company already does, but the companies that are just running day-to-day may not have given a lot of thought to that. That dynamic is going to be there.”

While new rules can be viewed as a headache, Bray pointed to one that could actually be of benefit to both drivers and the fleets they drive for. This rule will simplify the process drivers have to go through in order to be cleared to drive if he or she has type 2 diabetes and requires insulin. The previous system was relatively extensive, requiring multiple doctors’ visits to both government and primary physicians. The new rule would potentially simplify and expedite the process.

“What the FMCSA wants to do is change it so that the Department of Transportation (DOT)’s examining doctor, provided that the driver brings in the material from his treating doctor and can show it to the examining doctor, can certify him right then and there. That would make things a lot easier for the drivers or any drivers in the future who make the transition from diet-controlled diabetes to having to inject themselves with insulin. As long as the driver brings in materials from his treating doctor to the examining doctor, the examiner would be able to sign off and say they’re qualified,” Bray said.

Another new rule being worked on is the establishment of a drug and alcohol clearinghouse, a database that includes the name of any driver who refuses or fails a drug test. The database could be accessed by employers to clear or flag a potential new hire’s issues with drugs or alcohol.

“Carriers would have to query that before they could hire a driver to verify if he hasn’t failed or refused a drug test, and if he did where he is at in his return-to-duty process. That’s going to streamline a lot of things for carriers on the front end. It’ll alleviate a lot of worries,” said Bray.

Looking Back: Greenhouse Gas Emissions Standards Phase 1

The Environmental Protection Agency (EPA) and the DOT’s National Highway Traffic Safety Administration (NHTSA) are currently updating their fuel efficiency and greenhouse gas (GHG) emissions standards.
Phase 1 set the standards for vocational vehicles, heavy-duty pickup trucks and vans, and combination tractors.

The next step, Phase 2, which is expected to be finalized in the spring of 2016, refines the heavy-duty truck and vocational vehicle categories, builds on the preset GHG emissions standards, and increases the fuel-efficiency standards previously set.

Under Phase 1, vocational vehicles were required to reduce GHG emissions and fuel consumption by approximately 10 percent. This goal has to be met by Model-Year (MY)-2018.

And, fuel savings for vocational vehicles were to amount to approximately one gallon of fuel for every 100 miles fleet drivers traveled, according to the EPA.

Phase 2 regulations will impact MY-2021 through MY-2027 trucks, respectively.

“Under the proposed Phase 2 standards, vocational vehicles would require an additional 10-13 percent improvement from a 2017 baseline in gasoline vehicles,” said Ben Sharpe, senior researcher with the International Council on Clean Transportation (ICCT). “And, there would be a 14-15 percent reduction for diesel vocational vehicles.”

According to the EPA and NHTSA, the proposed Phase 2 standards are expected to lower CO2 emissions by approximately 1 billion metric tons, cut fuel costs by about $170 billion, and reduce oil consumption by up to 1.8 billion barrels over the lifetime of the vehicles sold under the program. And, the EPA estimates the new standards for model years 2021-2027 will reduce GHG emissions by more than 33 million metric tons annually by 2025.

“The Phase 2 proposal would apply standards to cut carbon emissions and reduce fuel use from combination tractors, commercial trailers, heavy-duty pickup trucks and vans, vocational vehicles, and separately, the engines that power combination tractors and vocational vehicles,” said Christopher Grundler, director of the EPA’s Office of Transportation and Air Quality.

The subcategories NHTSA and the EPA created for the vocational vehicle segment facilitate the breakdown of proposed fuel consumption standards beginning in model-year 2021. (SOURCE: CENTER FOR CLIMATE AND ENERGY SOLUTIONS)
The subcategories NHTSA and the EPA created for the vocational vehicle segment facilitate the breakdown of proposed fuel consumption standards beginning in model-year 2021. (SOURCE: CENTER FOR CLIMATE AND ENERGY SOLUTIONS)

Reclassifying the Category

While the Phase 1 rules focused on emissions, Phase 2 rules are targeting mileage.

“The Phase 2 rules, they’re combined NHTSA and EPA rules. The EPA side is greenhouse gas emissions, and the NHTSA side is the fuel efficiency, effectively CAFE. They’re written to go hand-in-hand — if you meet one you meet the other — so the more you increase fuel efficiency, the more you decrease greenhouse gas emissions,” said Mike Kastner, managing director of the NTEA. “Phase 1 broke the vehicle categories down to one category of pickup trucks and vans, and a second category of tractors, and a third category of vocational trucks. For Phase 2, they kept that and added trailers for tractor trailers, then they took the vocational category and subdivided the three categories three more times by drive cycles.”

These drive cycles are urban, regional, and mixed. The urban category is stop and start driving, representing package and delivery vehicles. In broader terms, it would be trucks driving within cities.

Regional is long-distance, high-speed driving.

Mixed or multi-purpose trucks are a mixture of urban and regional driving vehicles. Multi-purpose trucks would be those that provide support at work sites. And, these trucks would typically be upfitted to meet the needs of the job site or company.

“With Phase 2, there are specific regulatory targets for each of the vocational vehicle categories. Within those groupings, there’s another level of categorization. There are also distinctions between being urban, multi-purpose, and/or regional vocational vehicles,” said Sharpe.

According to Grundler with the EPA, it was NHTSA and the agency’s aim to recognize the variability of the medium- and heavy-duty vehicles.

These standards would achieve fuel efficiency based on metrics tailored to each subcategory and not by miles per gallon (mpg).

Adding Technology

Under Phase 1, vocational vehicles needed to make engine and tire improvements.

Phase 2 allows fleets and medium-duty truck operators to equip their vehicles with a mix of different technologies that would still meet the standards for fuel efficiency and GHG emissions.

“The proposed standards are performance-based, meaning that manufacturers would be able to choose the technologies, or combinations of technologies, that are best for them in achieving the standards,” Grundler said. “Technologies applied to vocational vehicles, for example, could include lower rolling resistance tires, improved engines and transmissions, and workday idle reduction technologies.”

The hybridization of medium-duty trucks would also boost fuel economy and reduce emissions significantly.
Sharpe at ICCT said that there will also be new testing procedures to address vehicle compliance in meeting the program’s standards. These new testing procedures would give credit for transmission improvements.

The integration of these technologies would benefit fleets long-term.

“These better-equipped vehicles will payback in a reasonable amount of time. The expected payback time for Phase 2 technologies is about five years, on average, for the vocational vehicle category,” said Sharpe.
Typical first owners keep trucks for 8-10 years, so fleets should see a return on investment during the last half of vehicle ownership.

“The overall approach to Phase 2 is to have granular categories so that the standards better reflect how the vehicles are operated and, therefore, are better able to promote technologies that make sense for those different types of vocations,” said Sharpe of ICCT.

Kastner foresees that one of the possible changes for fleets in light of the new Phase 2 standards would be the way that they order vehicles based on driving use.

“Ideally, if you, as a fleet, knew the duty cycle for a given truck, you could, look at that regional, mixed, urban choice and better match it to your uses. This would presumably give you a better mpg profile,” he said. “I don’t know how significant that difference would be. But, theoretically, the more closely you could match your truck’s specs to its actual duty cycle the greater the benefit.” 

Comments

  1. 1. Miles Sticka [ January 20, 2016 @ 10:32AM ]

    Yeah...typical first ownership is 8-10 years and fleets SHOULD start seeing investment returns on the last half of vehicle ownership?! One word: Pipedream!! What planet is the EPA and NHTSA really living on? So far, with all this overpriced and underperforming emission and aftertreatment systems on these newer trucks, it is costing the trucking companies billions every year just to keep their truck moving. I remember before the aftertreatment systems were mandated on our trucks, you could get into a repair shop on the road within a day. Now, with all the trucks breaking down due to junk aftertreatment system, you are lucky if you can get anyone to start working on your rig within 2-3 days. The backlog on these repair shop is very high. If your truck breaks down on Monday, you are not getting in until Wednesday-Thursday. God forbid you break down on a Thursday-Friday. There are a lot of shops that only have service for a half day on Saturday or are closed for the entire weekend. Just to have someone plug into the ECM or CECU is gonna run you $200-300. Most repairs will average $1000 by the time the repair(s) are made. At one time or another, every truck with an aftertreatment system will be in the shop with a breakdown due to the aftertreatment system failure. Programming glitches, junk parts, bad engineering, you name it. They will all breakdown at one time or another. For example, one of our trucks in the course of nine months accumulated $12,000 of repair work all of which where aftertreatment related. Wiring, progranning, bad DEF pums, bum sensors, troubleshooting that leasds to nowhere. That truck is a 2011 with 560K miles on it. There is no return as of right now on our "investments" for the sake of regulations. How is that going to change with more technology when they haven't even perfect the previous technology yet? I think is a bunch of malarkey. And you can take THAT to the bank.

 

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