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26 Sales & Marketing 70 aerodynamic technologies verifi ed by the SmartWay program are eligible for use — only that one product for each category must be used, and that the combination of the three systems net a 3 to 8 percent reduction in fuel consump- tion and CO2 emissions, depending on the type of trailer. Before October's stay was announced, box trailer manufacturers were working diligently to acquire the necessary prod- ucts to fulfi ll the regulations. "We're going to have a long list of spec'ing options," Stoughton Vice Presi- dent of Sales Dave Giesen said before the regulations were paused. "As long as what the customer wants has been EPA autho- rized and is on that [approved technolo- gies] list, it will generally be OK." For other trailer types, the scheduled regulations were less restrictive — some lower-volume types were exempt from the proposed rules — but were harder to achieve. "The fi nal program excludes all non- box trailer types except for three specifi c types that we believe are designed for and mostly used in on-road applica- tions. These types are tanks, fl atbeds, and container chassis," the EPA wrote in its 2016 Final Rule. With these trail- ers, the EPA said Phase 2 would require only low-rolling resistance tires and tire pressure monitoring or automatic tire infl ation systems. It was that tire obligation that was proving most diffi cult for trailer OEMs in preparing for Phase 2, East President and COO Dave dePoincy said before October's pause. "Tires are often very specifi c for certain types of equipment and many of the low-rolling resistance tires out there today aren't designed for these types of trailers," he said. "They work for those other segments [dry van and reefer] that are meeting those long-haul requirements." As a small manufacturer with less than 1,000 employees under Phase 2's guidelines, dePoincy said East had an additional year to work with its tire sup- pliers to develop tires that would allow the company to meet Phase 2's bench- marks. But for larger manufacturers, Phase 2's upcoming implementation date was looming as potentially impossible target to hit. That preparation struggle, and further questions regarding the usefulness of Phase 2's regulations, were also targets for TTMA in fi ghting the proposed regulations. The organization has long supported EPA's SmartWay program, and said its members offer a wide selection of SmartWay-approved systems to their customers. But in making such technol- ogy required, the EPA was forcing equip- ment onto trailers that not only would not see the air quality and benefi ts, but also could result in raising emissions, TTMA said. "There is already a compelling incen- tive for the owners and operators of heavy trailers to add this equipment where these benefi ts can be achieved," TTMA said. "But most trailers are oper- ated in such a way as to get little or no benefi t from these design changes, and T R U C K P A R T S & S E R V I C E | N o v e m b e r 2 0 1 7 Low-rolling resistance tires and tire monitoring or infl ation systems were going to be required on fl atbed, container and tanker trailers, under the Phase 2 rule. We intend to initiate a rulemaking process that incorporates the latest technical data and is wholly consistent with our authority under the Clean Air Act. – Scott Pruitt, EPA Administrator