

 From:
david.kayes@daimler.com
 To:
Byron Bunker/AA/USEPA/US@EPA
 Cc:
brian.burton@daimler.com, donald.keski-hynnila@daimler.com
 Date:
06/12/2011 12:58 PM
 Subject:
HDV GHG rule:  weight reduction credit issues




Byron:

We understand that Navistar has requested that the EPA (and possibly NHTSA) add 13L engines to the list of items eligible for weight reduction credits in the GHG rule.  (By "credit" I mean being able to run GEM with a higher weight reduction input.)  While we do not object to Navistar's making such a request, we want the agencies to know that Navistar has not gotten industrywide agreement for this credit.  Daimler does not support the credit.  In particular, we see the idea as (1) lacking in scientific rigor and (2) possibly self-serving.  

Specifically, regarding the first point, we believe that a lot more contributes to total vehicle mass than just the bare engine weight.  The full engine system weight would capture cooling system weight, aftertreatment and associated hardware, mounting provisions, accessories, etc.  In particular, a lightweight 13L engine, operated frequently at high torque, may require a relatively heavy cooling system, the weight of which is not appropriately captured by Navistar's proposal.  Yes a 13L engine and its cooling system will likely be lighter than a 15L, but not by the amount that Navistar proposes.  We would be happy to work with the agency and our industry colleagues to develop a more scientifically robust procedure for credits based on full system weight.  While we are at it, we should also consider other equally valid weight savings, such as that for a reduced weight cab and cab-mount assembly, a reduced weight drive train, etc.

Regarding the second point, we think that a manufacturer who has primarily 13L engines to offer (besides two low rated 15L offerings) is trying to get a competitive advantage from the agency seal of approval that would come with this credit.  For example, where a manufacturer offers no equivalent 15L engine rating, why should the manufacturer get credit for putting a 13L engine into the vehicle?  In short, because we believe the agencies should not give competitive advantages to one manufacturer or another, we do not support the credit.

One final point, in case we have not yet made this clear to the agencies:  we think the weight reduction table, with credits for aluminum parts, needs much work before it is ready for the regulation.  Many of the parts on the list (e.g., the hood, fairings, fan shroud) are made of plastic or fiberglass, such that going to aluminum would increase the weight.  Again, we would be happy to work with the EPA and NHTSA in developing a more robust list or, alternatively, a procedure for taking weight into account.

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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