OK, so we’ve seen Phase 2 of the fuel efficiency and greenhouse gas emission regulations for medium- and heavy-duty trucks. The Notice of Proposed Rulemaking was finally published in June by the Environmental Protection Agency and the Department of Transportation’s National Highway Traffic Safety Administration.

It’s a whopping 1,349 pages long, so I’ve barely scratched its surface. But some numbers in there make me uncomfortable, even though I believe that the ultimate result will be good for trucking (see Locking It In, March 2015, for my original take on all this).

As with every other EPA mandate, estimates are flying. A Class 8 tractor will cost 10-12% more under the Phase 2 rules, officials say. But they insist that by 2027, that cost increase — they say $12,000, which I don’t trust — will be recovered within two years of operation, thanks to reduced fuel consumption.

To be honest, I’m left rolling my eyes, even though I believe that the fuel-economy gains we’re talking about here are reachable. It’s just that Washington’s guesses have never been accurate. And the political suits just love to throw wild macro numbers around in what amounts to a marketing campaign.

They estimate the proposed standards will create $230 billion in net benefits over the lifetime of the vehicles sold in the regulatory timeframe, while costing the industry about one-tenth that amount, or $25 billion.

I guess they have to play at this macro level, but I fear it blinds them to what goes on in the trenches. Where you work.

The proposed Phase 2 regime calls for truck fuel economy to be improved by as much as 24% over 2014-18 levels by 2027, starting in model-year 2021.

Yet I hear all the time of trucks already doing 9, 10, even 11 mpg in 2015 form. Not Montana cattle haulers, mind you, but a whole bunch of plain-vanilla five-axle rigs are on Interstate highways as we speak doing an easy 7 mpg without really trying. They’ll be pushing at least 9 mpg in 2018 simply by virtue of the factory spec. Which means something like 12-13 mpg or more in 2027.

Is it just me, or does something seem out of whack here? Really, it would take relatively little to get awfully close to that level of efficiency more or less right now. Well, soon, at least for basic van operations, and long before we need to talk about semi-exotic technology like waste-heat recovery. Flatdecks and vocational rigs of all sorts represent bigger and different challenges, I’ll admit.

To be honest, I’m left rolling my eyes, even though I believe that the fuel-economy gains we’re talking about here are reachable.

So what could we do right now? Among other possibilities, taking trailer aerodynamics to the max equals an easy 5% fuel saving at least, likely more, for not much money. Costing even less, let’s take driver training seriously, because there’s anything from 10 to 30% in there. 

And in my mind, the best and biggest ton/mile efficiency option we have is to increase truck size and/or weight, though the DOT has effectively nixed the idea of six-axle rigs weighing up to 97,000 pounds – while admitting it would save 2 billion gallons of fuel every year and cut emissions by 19% per ton/mile.

The problem here is that Washington never sees the whole picture, never sees how the various elements that make up the trucking industry fit together and offer opportunities to save.

It’s not just about the machinery we use.