Should the trucking industry be concerned about underride legislation?

After a phone call with a congressman’s office the other day, I thought that it would be a good idea to put the question out on the table for some honest conversation: What is it going to cost the trucking industry to install effective comprehensive underride protection?

Without going into the exact cost/truck, here are some of my observations about the impact of a comprehensive underride protection mandate:

Fuel savings from combining side skirt and side guard can be significant. The AngelWing side guard has already had SmartWay testing.
Current weight of AngelWing is 800 lbs. and a very small percentage of 80,000 lb. limit–1%. They plan on working to decrease that weight. http://airflowdeflector.com/home/airflow-2/
Aaron Kiefer’s TrailerGuard system weighs closer to 300 lbs (.375% of 80,000 lbs.).: https://www.collisionsafetyconsulting.com/
In an off the record phone conversation with a trailer manufacturer CEO a month or so ago, he told me that he (as a trailer manufacturer) will welcome a mandate because it will take the burden off of the manufacturer to have to persuade their customers to put on underride safety equipment.
When we met with a congressman a few weeks ago (who also holds a CDL), he suggested a possible credit at weigh stations for extra weight of side guards.
In the Truck Trailer Manufacturers Association TTMA letter to NHTSA on May 13, 2016
I was encouraged by the closing paragraph of the TTMA letter to NHTSA:

TTMA would support the implementation of side guards if they ever become justified and technologically feasible. We continue to support the NHTSA review of Petitioners’ requests and stand ready to partner in the development of justified and feasible designs if they possibly emerge. Jeff Simms, President

https://annaleahmary.com/2016/05/truck-trailer-manufacturers-assn-reminds-nhtsa-side-guards-are-not-cost-effective-says-who/: TTMA_Side_Impact_Main_Comment_2016-05-13 TTMA_Side_impact_Exhibits_A-D_2016-05-13
IIHS just tested the 6th major manufacturer’s improved rear guard. They have offered to test manufacturer’s side guards. Two have said they are working on a design.
The industry is responding, but pressure is still needed to address the problem decisively, comprehensively, and quickly. Time is of the essence to save lives. And that includes retrofitting of existing trucks.
Fuel savings from trucks with side skirts/guards. Could be $20,000/yr. https://annaleahmary.com/2017/02/perfect-opportunity-to-transform-supertruck-into-an-esv-to-advance-underride-protection-dot-doe/ and https://annaleahmary.com/2017/02/doe-pours-millions-into-supertruck-fuel-savings-research-projects-0-devoted-to-side-underride-protection/
Some have estimated a 2 yr. ROI for side guards.
Congressman LaMalfa proposed a tax repeal for purchase of new trucks. This could help offset the costs: the 12-percent Federal retail excise tax routinely adds between $12,000 and $22,000 to the cost of a heavy truck, tractor, or trailer. Read about it here: http://www.truckinginfo.com/channel/fleet-management/news/story/2017/06/house-bill-would-repeal-heavy-truck-federal-excise-tax.aspx and https://annaleahmary.com/2017/06/would-this-truck-tax-savings-cover-cost-of-comprehensive-underride-protection-for-a-winwin-solution/
With proven effective side guards, there will be a new de facto standard. If trucking companies experience a collision with an underride death, the liability could put smaller companies out of business. Effective comprehensive underride protection can prevent these catastrophic outcomes to many truck crashes which end in life-changing tragedies for more than just the victim.
Effective underride protection is more likely to result in a truck which can be used more quickly after a collision.
Stoughton Trailers was able to produce a more effective rear guard on new trucks with no added cost or weight penalty to their customers.
What about a tax credit for early adopters of underride technology before the compliance date?
Truck Underride 101: Part IV Win/Win