MEMORANDUM
SUBJECT: Summary of Communications with External Parties Regarding the Final Rule for Medium and Heavy  Duty Vehicle Fuel Efficiency and GHG Standards.
FROM:  Byron Bunker  - Assessment and Standards Division US EPA
TO: Docket EPA-HQ-0AR-2010-0162
DATE:   August 3, 2011
The table below describes various phone calls and meetings with interested parties related to the proposed rule to set GHG emission standards for medium and heavy duty vehicles.
                                     Date
                                 Participants
                                    Summary
                                  10/28/2010
     Mike Joyce  -  Owner Operator Independent Driver Association (OOIDA)
Discussed concern that vehicle speed governors weren't a good solution for all drivers especially for individual owner operators.
                                  10/28/2010
                        Pat Quinn  -  the Accord Group
Discussed challenges for heavy-duty hybrid vehicles to comply with EPA's OBD requirements.
                                   11/1/2010
                           Call w/ NHTSA & OOIDA
Separate docket memo by Angela Cullen
                                   11/4/2010
       Jed Mandel and Tim Blubaugh Engine Manufacturers Assocation (EMA)
Discussed opportunity for harmonization of GHG standards long-term with Europe and the ultimate desirability of that outcome for EMA members.  EMA emphasized this was a priority for their organization.
                                   11/5/2010
                      Steve McCauly and Stephane Couroux
Discussed potential value of harmonized standards and new work being done on Low Rolling Resistance tires in Canada.  Discussed importance of common test procedures even if differences in fleet mix mean that different standard levels might be more appropriate.
                                  11/29/2010
               Don Anair  -  Union of Concerned Scientists (UCS)
Questions about our cost and technology analysis in the rule.
                                   12/1/2010
                             Mike Joyce  -  OOIDA
How does the rule handle size and weight?  Will it discourage heavier trucks?  Discussed that GEM approach does not limit truck capability regarding weight only incentivizes weight reduction.
                                  12/16/2010
                       Jed Mandel and Tim Blubaugh (EMA)
EMA raised concerns that 2% measurement allowance for in-use testing does not adequately account for measurement variability.  EMA raised concerns that DFs for CO2, N2O and CH4 could be difficult to develop and impacted by potential for measurement variation to impact estimate accuracy.
                                   1/4/2011
                         Brad Hicks  -  Arvin Merritor
Agency should consider expanding weight reduction list to additional components like brake drums and wheel hubs.
                                   1/5/2011
                               David Bookbinder 
Discussed virtues and challenges of accurately accounting for upstream emissions for Natural Gas versus electricity.  Discussed that natural gas has better CO2 performance when compared to a gasoline or diesel baseline.
                                   1/5/2011
Patrick Charbonneau and Tony Cook - Navistar
Discussed technical challenges of reducing CO2 emissions from legacy products that will be retired and replaced.  Discussed potential for hybrid vehicles to grow in the market and cost challenges facing wider use of heavy-duty hybrids.  Discussed how to most accurately estimate 2011 baseline performance for comparison in 2014.  Discussed value of innovative credits and potential for new technologies like active fifth wheel systems that adjust trailer gap at highway speeds.  
                                   1/6/2011
ACEE  -  Therese Langer, 	EDF  -  Hilary Sinamon, NRDC  -  Luke Tonachel, 	NESCAUM  -  Coralie Cooper,	UCS  -  Don Anair, Brendan Bell, ICCT  -  Ben Sharp, CATF  -  David Marshall
Margo Oge's Office and by phone.  Discussed need for data that VIUS survey used to provide.  Need for additional data to do the rule better and especially future rules.  Group discussed the potential for more stringent standards for heavy-duty pickups and vans by 2018 especially for gasoline engines.  Discussed potential for more stringent vocational truck standards based on additional technologies including transmissions and hybrids.  Discussed merits of laying out a 2020 path based on full suite of NAS identified technologies as a goal for the next rule but expressed in this rule.  
                                   1/12/2011
Heavy Duty Fuel Efficiency Leadership Group  -  Pat Quinn, Waste Management, Randy Mullet- ConWay Trucking, Bill Bennet  -  Eaton, Brian Mormino  -  Cummins 
Discussed implications of general vehicle description in GEM model when vocational vehicles specifically refuse vehicles are so varied.  Discussed unique tire needs for vocational vehicles specifically high scrub resistance and high load ratings.  Discussed value of multipliers and other aspects of credit generation to encourage market introduction of HEV and PHEV medium duty trucks.   Discussed process for PHEV certification.
                                   1/14/2011
                   Patrick Charbonneau, Tony Cook - Navistar
Discussed alternative engine standard and intent behind requirement to use all banked credits prior to utilizing the flexibility.  Discussed inherent tension in using up banked credits when at the same time agencies presumably want to encourage introduction of advanced technologies.  Discussed value of innovative credits to bring new technologies to market and relative merits of unrestricted credit trading versus more typical trading within standard categories.
                                   1/20/2011
                           David Piech  -  Navistar
Discussed best method to accurately reflect CO2 performance for engines at different levels of NOx performance.
                                   1/25/2011
                                Don Nage  -  GM
Discussed inherent difficulty in meeting requirement to report individual 13mode data and RMC data from existing test cells.  Discussed potential to substitute engineering test data for 13 mode results as one possible solution.
                                   1/28/2011
             Susan Alt, Jonathon Miller and Tony Greszler - Volvo
Margo Oge's Office and by video.  Volvo raised five priority issues in the rule.  Their number one issue was maintaining existing EPA approach to restrict credit averaging across vehicle class sizes.  Volvo does not make LHD and MHD products.  Volvo also raised concerns about the process for certifying to the alternative engine standard, the alignment of model year definitions, and potential competitive issues if in markets were small businesses produce a significant fraction of the vehicles (specifically refuse trucks).
                                   2/9/2011
                           Brian Burton  -  Daimler
Discussed Daimler trucks interest in future alignment of US and European GHG and FE programs. 
                                   2/10/2011
                                Don Nage  -  GM
Discussed relative merits of using engineering data rather than 1065 compliant date for reporting engine maps used for modeling and not certification.  Don emphasized that it would require extensive test cell upgrades to make all development cells 1065 compliant.
                                   2/14/2011
     Drew Kodjak  -  International Council on Clean Transportation (ICCT)
Discussed ICCT's interest in helping other regions move forward on GHG and FE programs for HD trucks.
                                   2/15/2011
                             Tim Blubaugh  -  EMA
Discussed top issues of concern for EMA and its members including broader use of ABT credits, treatment of innovative credits, DF determination, OBD for GHG controls, consistency of definitions between EPA and NTHSA regulations, emissions warranties for tires, handling of small business exemptions where small businesses compete with large companies, and impediments to bringing hybrid vehicles to the market.  Discussed need for additional work on aerodynamic test procedures.
                                   2/25/2011
                             Tim Blubaugh  -  EMA
Discussed issues of concern to EMA and its members including concern that N2O standard didn't reflect full range of current product performance, CO2 compliance margin didn't reflect facility to facility variation, need for additional methods to certify hybrid drivetrains similar to innovative technologies, means to account for wind average yaw, and potential to use CdA vs Cd for GEM model.
                                   3/2/2011
                             Tim Blubaugh  -  EMA
Discussed issues of concern to EMA and its members including need for enhanced coastdown test procedure, need to account for aerodynamic performance differences between sleeper cab and day cab tractors, potential to correlate OEM's own aerodynamic procedures to a common reference test procedure, need for means to account for wind average yaw, need to define a trailer as a test article for coast down procedure.
                                   3/2/2011
          Patrick Charbonneau, Tony Cook and David Piech  -  Navistar
Discussed various aspects of alternative CO2 standard in the proposal.  Discussed issue of legacy engines and need for a compliance path that would work for engines that could not be readily updated in the near term but that would see a significant update in the coming years.  Discussed technologies that would be available to legacy engines including turbocharging improvements, fuel system, reduction in friction, and improved combustion optimization.  In total these available technologies were believed to allow improvements on the order of 2 percent.  Discussed need to address differing NOx baselines for engine out technologies and the potential to use a correction factor based on 2009-2011 certification data.  Discussed potential for innovative technologies and the merits of early introduction of Advanced Smartway designs to be treated as an advanced technology like hybrids.
                                   3/3/2011
     John Wall, Brian Mormino, Jackie Yeager and Bob Jorgensen  -  Cummins
Discussed issues of concern to Cummins including their feeling that advanced technology credits should not have special standing, a concept for addressing the denominator effect in child ratings, additional means for hybrid certification, and Cummins opinion that gasoline engines should have to meet the same stringent standards as diesel engines.
                                   3/8/2011
                             Tim Blubaugh  -  EMA
Discussed issues of concern to EMA and its members including standard trailer testing conditions, how to handle anemometer location for coastdown testing, need to tighten wind speed allowance for coastdown, and other aspects of improving the defined aerodynamic coastdown procedure.
                                   3/17/2011
                    Stephane Couroux  -  Environment Canada
Discussed how certification processes in the US and Canada might be better aligned or harmonized.
                                   3/17/2011
                             Tim Blubaugh  -  EMA
Discussed issues of concern to EMA and its members including hybrid test procedures, potential to certify hybrid vehicles using innovative procedures, concerns that proposed drive cycle not representative of most hybrid applications, and means to improve aerodynamic test procedures including similar methods as discussed on 3/8.
                                   3/25/2011
                           Brian Mormino  -  Cummins
Discussed issues of concern to Cummins including treatment of vocational vehicles especially emergency vehicles and interest in seeking harmonized standards in China.
                                   4/1/2011
                            Tim Blubaugh - Cummins
Discussed issues of concern to EMA and its members including concern that technical need to potentially create separate GHG engine families for FTP and SET certified engines would inadvertently double the testing burden of the existing HD in-use and OBD programs.  Also discussed EMA's interest in more definition regarding innovative technology test procedures including the possibility of using an SAE type II or III fuel economy procedure.
                                   4/1/2011
                              Barbara Kiss  -  GM
Discussed issues of concern to GM including concern that gasoline loose engines would not have access to other potential sources of GHG credits and hence could not be sold if technical difficulties made certification below the standards not possible.  Also discussed the relatively large testing burden given the small volume of loose gasoline engine sales.
                                   4/1/2011
                           David Piech  -  Navistar
Discussed issues of concern to Navistar including limitations of legacy engines to improve performance beyond improvements in combustion, parasitics and turbomachinery.  Also discussed challenges of appropriately addressing differences in NOx baseline performance with many 2011 engines certified to 0.5 g NOx and likely to be certified to 0.2 g NOx in 2014.
                                   4/12/2011
                             Tony Greszler - Volvo
Discussed issues of concern to Volvo including use of MHD advanced technology credits to comply with HHD vehicle standards, alternative engine standards, and concerns regarding "double jeopardy" under a joint EPA/NHTSA program.
                                   4/12/2011
                             Tim Blubaugh  -  EMA
Discussed EMA's concerns regarding development of DFs for CO2.
                                   4/15/2011
           Jackie Yeager, Brian Mormino, and Bob Jorgensen - Cummins
Discussed Cummins' interest to develop some means to adjust CO2 standard for child ratings.  
                                   4/18/2011
Brian Mormino  -  Cummins, Tony Greszler  -  Volvo, and Brian Burton - Daimler
Discussed Cummins, Volvo and Daimlers common concerns that alternative engine standards could be "gamed" without appropriate accounting of the 2011 baseline and concerns that advanced technology credits from MHD trucks could undermine HHD tractor reductions leading to a competitive concerns for these OEMs.
                                   4/19/2011
                             Tim Blubaugh  -  EMA
Discussed issues of concerns to EMA and its members including their interest in harmonized standards for the US, Canada, and Mexico, their concerns about the 2% in-use compliance margin, the N2O standard,  and handling of early emissions credits by calendar year or model year.
                                   4/20/2011
                    Tony Greszler and Marc Miller  -  Volvo
Discussed Volvo's concerns with the advanced technology credits and the potential for significant credit flows from MHD trucks negatively impacting Volvo in the HHD tractor market.
                                   4/25/2011
                             Tim Blubaugh  -  EMA
Discussed issues of concern to EMA and its members specifically EMA's recommendation to use CdA rather than Cd in the GEM model and the specific recommendation that the reference trailer used for coast down testing be set at 13 foot 6 inches measured from the ground.
                                   4/27/2011
                              Jed Mandel  -  EMA
Discussed issues of concern to EMA and its members including EMA's strong desire that the program works as a single national program with a single certification template, single certification determination and coordinated single action to address any violations of the CAA or EISA.
                                   4/28/2011
                             Tim Blubaugh  -  EMA
Discussed EMA's concern regarding dual certification of engines to both the FTP and SET standards for CO2.
                                   4/29/2011
                    Tony Cook and David Piech  -  Navistar
Discussed issues of concern to Navistar including how to most appropriately account for difference in NOx baseline emissions for the proposed alternative engine standard.  Also discussed need to group LHD and MHD baseline data together given small number of LHD engines and common standards for LHD and MHD engines.
                                   4/30/2011
                             Tim Blubaugh  -  EMA
Discussed issues of concern to EMA and its members including the method for determining the overall height for a box trailer used in aerodynamic testing.
                                   5/2/2011
                            Tony Greszler  -  Volvo
Discussed issues of concern to Volvo including competition concerns for LOCE Class 8 trucks with exempted small businesses and credit trading between MHD and HHD vehicle.
                                   5/4/2011
                           Debbie Gordon  -  Allison
Discussed issues of concern to Allison Transmission including how A to B testing for hybrids and powerpack testing should be done, how NOx criteria certification would be handled, how transmission shift schedules could be assured to give a fair A to B comparison.
                                   5/4/2011
                            Tony Greszler  -  Volvo
Discussed issues of concern to Volvo including treatment of MHD credits, the alternative engine standards, potential for double jeopardy, potential for loopholes in baseline and child engine ratings, desire for US to work with Europe towards a common standard.
                                   5/4/2011
                    Barbara Kiss & Steve Freneti  -  GM
Discussed issues of concern to GM including the gasoline engine standard, and N2O measurement techniques.
                                   5/5/2011
Meeting Dennis Slagle, Tony Greszler, and Jonathon Miller from Volvo with Gina McCarthy, Margo Oge, Lori Stewart, Steven Silverman and Byron Bunker of EPA
Discussed issues of concern to Volvo including potential for "double jeopardy" with dual EPA and NHTSA programs, Volvo's competitive concerns with credit trading of advanced technology credits from MHD to HHD trucks including Volvo's recommendation that the agencies consider capping those credit transfers, and Volvo's strong interest to ensure the program is robust and enforceable in order to maintain a level playing field in the market.
                                   5/6/2011
Brian Mormino  -  Cummins, Tony Greszler  -  Volvo, and Brian Burton - Daimler
Discussed issues of concern to all three companies including means to ensure alternative engine baseline level is real perhaps by using sales weighting and pooling all engines together.  Also discussed potential to constrain advanced technology credit trading to address concerns raised by companies on level playing field.
                                   5/9/2011
                              Jed Mandel  -  EMA
Discussed EMA and its members concerns regarding the potential for dual EPA and NHTSA programs rather than a joint national program.  In particular, EMA continued to express concerns regarding handling of enforcement actions with potential for in EMA's words "double jeopardy"
                                   5/10/2011
Don Anair  -  UCS, Luke Tonachel  -  NRDC, Therese Langer  -  ACEEE, Mark McCloud  -  EDF, David Marshall  -  CATF, Fanta Kamatake  -  ICCT, and Matt Solomon  -  NESCAUM
Discussed issues of concern to the groups on the call including what actions the agencies would take to ensure data was available to develop the phase 2 program,  what the agencies could do to ensure innovative credits were real and appropriately accounted for, process for certification and interest in finding a more elegant solution to child ratings.
                                   5/11/2011
                             Tim Blubaugh  -  EMA
Discussed issues of concern to EMA and its members including data gathering for phase 2, handling of alternative engine baseline, ability to certify FTP and SET GHG standards separately, and appropriate hybrid vehicle drive cycles.
                                   5/11/2011
                           Brian Mormino  -  Cummins
Discussed issues of concern to Cummins including their recommendation that gasoline engines meet the same CO2 standard as diesel, that advanced technology credits would not be fungible across regulatory classes, that the agencies consider other ways to handle child engine ratings.
                                   5/11/2011
    Meeting Jed Mandel  -  EMA, Margo Oge  -  EPA, and Ron Medford - NHTSA
Participants discussed EMA's strong interest in a harmonized national program with EPA and NHTSA acting effectively as a single agency and not a dual program with duplicate certification applications, duplicate approval and duplicate enforcement.
                                   5/13/2011
     Pat Quinn  -  Accord Group, Chris Hess and Mihia Dorobantu  -  Eaton
Discussed issues of concern to Eaton specifically related to determination of A to B test procedures and selection of a fair comparison transmission.  Eaton believed power and vehicle weight would be most important aspects to match.
                                   5/17/2011
                       Patrick Charbonneau  -  Navistar
Discussed issues of concern to Navistar including the alternative engine standards and the best performance possible for certain legacy engines.  Discussed appropriateness of accounting for tradeoffs between N2O emissions and CO2 in seeking to achieve the lowest total GHG emissions.
                                   5/19/2011
                    Debbie Gordon  -  Allison Transmission
Discussed issues of concern to Allison including ways to ensure that A to B testing was done using an appropriate reference vehicle for comparison.  Discussed need to look at equal performance for acceleration, startability, and gradeability.  Also discussed need to clarify what is meant by worst case and how do our current procedures ensure best effort when a vehicle cannot follow the driving trace.
                                   5/19/2011
                             Tim Blubaugh  -  EMA
Discussed issues of concern to EMA and its members including how to handle aerodynamic testing for low and midroof tractors where trailer characteristics are quite variable (EMA recommendation  -  test bobtail) and function of a vehicle emissions label.
                                   5/20/2011
                             Tim Blubaugh  -  EMA
Discussed issues of concern to EMA including DF determination, concept of a minimum improvement for innovative credits, handling of vocational tractors, definition of a Rankine cycle engine, warranty and emissions label concerns.
                                   5/23/2011
                             Steve Frenetti  -  GM
Discussed issues of concern to GM including how vehicles with similar configuration would be tested and accounted for in the pickup truck standards.
                                   5/24/2011
                        Patrick Charbonneau - Navistar
Discussed issues of concern to Navistar including handling of advanced technology credits, interest in accounting for N2O / CO2 tradeoff, interest in accounting for mass reductions due to smaller engines and concerns about the alternative engine standards.
                                   5/24/2011
                           Cynthia Williams  -  Ford
Discussed issues of concern to Ford including handling of emissions warranties for tires and other components.
                                   5/25/2011
                       Patrick Charbonneau  -  Navistar
Discussed issues of concern to Navistar including alternative engine standard and treatment of N2O emissions.
                                   5/25/2011
                             Tim Blubaugh  -  EMA
Discussed issues of concern to EMA and its members including determining what products could reasonably qualify for early compliance credits without creating a windfall.
                                   5/31/2011
                             Tim Blubaugh  -  EMA
Discussed issues of concern to EMA and its members including how many vehicle tests must be completed prior to certification at the start of a model year, handling of all components on an emissions label, and treatment of emissions warranties for trucks vs engines.
                                   6/2/2011
Brian Mormino, Mike Ruth, Bob Jorgensen, Jackie Yeager, and John Dixon - Cummins
Discussed issues of concern to Cummins including treatment of advanced technology credits, certification process for hybrids, means to measure 13 point steady state results over a Ramp Modal Cycle, how to demonstrate that early compliance credits do not represent a windfall, how to address phantom rating concern, and means to certify complete vehicles in Class 4 and 5.
                                   6/3/1022
                             Tim Blubaugh  -  EMA
Discussed issues of concern to EMA and its members including treatment of N2O emissions, issues raised on OBD standards for hybrids, emission warranties for hybrids,  and handling of advanced technology credits.
                                   6/6/2011
                         Fuel Economy Leadership Group
Discussed HD proposal in general and few issues of concern including vocational tires and ability of fleets to specify the right truck for their businesses.
                                   6/6/2011
Don Anair, Michelle Robinson (UCS), Vickie Patton (EDF), Luke Tonachel (NRDC), Drew Kodjak (ICCT)
Discussed common issues of concern for the groups including need to move forward soon on phase 2, timeline for EPA and NHTSA implementation (maintaining 2014 compliance year), how soon can trailer standards be set?,  potential for harmonization with Canada and Mexico.
                                   6/13/2011
             Marc Miller, Tony Greszler, and Dave Smith  -  Volvo
Discussed issues of concern to Volvo including handling of vocational tractors, must every tire size be tested or can test results be interpolated between tire sizes, how does PTO load differentiate between accessory load and direct PTO shaft load, and need to address health and safety concerns with anti-idling technologies.
                                   6/13/2011
                          Jed Mandel and Tim Blubaugh
Discussed issues of concern to EMA and its members including EMA's strong desire that the joint NHTSA/EPA program look and act as a single national program for the industry.  Strong desire to avoid dual certification, dual compliance and dual penalty investigations.
                                   6/15/2011
                        David Kayes  -  Daimler Trucks
Discussed issues of concern to Daimler including the potential use of advanced technology credits to offset new technology introduction in sleeper cab tractors.
                                   6/15/2011
                             Tim Blubaugh  -  EMA
Discussed issues of concern to EMA and its members including how early compliance credits would be calculated for engines versus vehicles given the current industry practices that shift the model years between vehicles and engines.   Also discussed emissions related components in the context of components that could never fail in their emissions role (e.g. weight reduction  -  parts can't get heavier in-use).  Finally discussed a number of issues related to improvements to coastdown test procedures including the appropriate location of a wind speed anemometer,  acceptable wind speeds during a test, and appropriate trailer gap for testing given current industry practices.
                                   6/17/2011
     Hilary Sinnamon, Jackie Roberts  -  Environmental Defense Fund (EDF) 
Discussed issues of concern to EDF including the degree to which the rule was likely to lead to increased production of specific vehicle components and which sectors of truck production were most likely to increase due to the need for new parts.
                                   6/17/2011
                             Tim Blubaugh  -  EMA
Discussed issues of concern to EMA and its members including treatment of mass reducing technologies, means to ensure alternative engine standards accomplished real reductions, the treatment of advanced technology credits and questions about additional testing to inform the agencies' decisions on aerodynamic test procedures.
                                   6/20/2011
                             Marc Miller  -  Volvo
Discussed issues of concern to Volvo including concern that individual class 5 vehicle platforms would have no opportunity for credit trading with cross class restrictions and best means to determine aerodynamic performance of low and mid roof day cab tractors derived from high roof tractors.
                                   6/20/2011
                        Pat Quinn  -  the Accord Group
Discussed issues of concern to the Heavy Duty Fuel Economy Leadership group including the groups interest in working with the agencies during development of any future heavy-duty regulation.
                                   6/22/2011
                            Jackie Roberts  -  EDF
Continued discussion from 6/17 that had been cut short due to a fire alarm at EPA.  Discussed specific truck technology changes.
                                   6/27/2011
Heavy Duty Fuel Economy Leadership Group  -  meeting with EPA at Ariel Rios (Margo Oge, Chet France in DC, Byron Bunker by video)
Discussed issues of concern to the group including hybrid certification procedures and the value in encouraging hybrid technologies, desire for a single harmonized test procedure, and in the long term creating a complete vehicle certification process and desire to work with the agencies in the future on any trailer regulations.
                                   7/5/2011
                              Glen Kedzie  -  ATA
Discussed issues of concern to ATA and its members including tampering provisions, vehicle emissions labeling provisions, treatment of add-ons like roof carriers (again tampering), idle shutdown provisions to protect driver safety and will the provisions of the rule allow classic tractors to continue to be produced.
                                   7/6/2011
                             Tim Blubaugh  -  EMA
Discussed issues of concern to EMA and its members including means to measure and account for aerodynamic improvements that reduce wind average drag, definition of date of manufacture, means to account for reductions in N2O emissions, and mechanisms to account for vehicle speed limiters that incorporate soft top features.
                                   7/6/2011
                      Mark Cauchi  -  Environment Canada
Discussed issues of interest to Environment Canada including the potential for Canadian regulations to align with US regulations in the future.
                                   7/12/2011
                             Tim Blubaugh  -  EMA
Discussed issues of concern to EMA and its members including treatment of medium duty engines primarily designed for vocational use but sold into line haul applications.
                                   7/16/2011
          Brian Mormino, Jackie Yeager, and Bob Jorgensen  -  Cummins
Discussed issues of concern to Cummins including treatment of complete versus incomplete vehicles for criteria and CO2 certification.  Cummins position is the CO2 and criteria certification should be paired.  Cummins also raised questions regarding how the agencies intended to handle certification for engine families where the worst case engine selection for NOx was a restricted rating.  Cummins also raised concerns about the proposals language suggesting extension of the heavy-duty pickup and van program to large (Class 4+) vehicles

