


 From:
david.kayes@daimler.com
 To:
Byron Bunker/AA/USEPA/US@EPA
 Cc:
brian.burton@daimler.com, donald.keski-hynnila@daimler.com, francis.seymour_jr@daimler.com
 Date:
07/12/2011 01:25 PM
 Subject:
Model year 2013




Byron,

There is one addition to the GHG regs that the agency proposed making that is really a wise change.  I am not sure that, during our meeting a few weeks ago, I stressed adequately how important this change is.  (I should have sent you this email right after our meeting, but I immediately went on vacation and just returned.  Hopefully, this email is not too late to lock in place this change.)  

The proposed change was to allow a manufacturer to certify some but not all MY 2013 vehicles.  If I remember correctly, a manufacturer could earn early credits after certifying the manufacturer's last vehicle family in MY 2013 (either in an averaging category or in all categories, I do not remember).  This provision, or some other allowance for some early MY 2013 builds, is important to us because we are beginning to build MY 2013 vehicles very soon.  For example, some of our vehicles take a long time to build from start to finish; in order that we have the appropriate MY at the time of sale to a customer, we start to build very early (and as you know the build begins by stamping rails with a vehicle's MY).  Build up of some MY 2013 vehicles will begin in September of this year, before I expect that we will have our certificates from the EPA.  In other words, we will very soon start building MY 2013 vehicles but will likely not have certificates for those vehicles under the GHG regs.  Because we still want to take advantage of the early MY 2013 certification, we need a provision that allows manufacturers out of the earlier-proposed requirement that a manufacturer must certify all MY 2013 products in order to certify any.  In turn, it is important for us to have this newly proposed addition or some other one that allows some uncertified MY 2013 vehicles without jeopardizing a manufacturer's entire MY 2013 fleet certification.

Thanks,
Dave
-------------------------
David Kayes
Compliance and Regulatory Affairs --- Environmental Compliance
Daimler Trucks
(503) 745-9162 Office
(503) 265-9838 Mobile
David.Kayes@Daimler.com

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