UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

NATIONAL VEHICLE AND FUEL EMISSIONS LABORATORY

2565 PLYMOUTH ROAD

ANN ARBOR, MICHIGAN 48105-2498

OFFICE OF

AIR AND RADIATION

                                                                        
          	     

MEMORANDUM

SUBJECT:	Heavy-Duty Hybrid Onboard Diagnostics

FROM:		Amy Kopin

TO:		The Docket

DATE:		July 19, 2011

	

	On May 10th, 2011 we held a conference call with Odyne Systems, LLC to
discuss concerns raised by hybrid manufacturers regarding heavy-duty
onboard diagnostic (OBD) requirements and timing. Hybrid manufacturers,
engine manufacturers, and industry trade groups raised concerns during
the comment period for the heavy-duty greenhouse gas notice of proposed
rulemaking that heavy-duty hybrid applications may not be able to meet
the 2013 heavy-duty OBD regulations that were published in the 2009 OBD
Final Rulemaking.,  Attendees from the EPA and Odyne are shown in the
table below.  The agenda for this meeting is shown on the following page
of this memo.

Attendee 	Affiliation 

Cleophas Jackson 	EPA – Compliance and Innovative Strategies Division 

Anthony Neam 	EPA – Assessment and Standards Division 

Amy Kopin 	EPA – Assessment and Standards Division 

Joe Dalum	Odyne - President and CEO

Dr. Phillip Eidler	Odyne – VP Operations

Matt Jarmuz	Odyne – Applications Engineer and Sales





UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

NATIONAL VEHICLE AND FUEL EMISSIONS LABORATORY

2565 PLYMOUTH ROAD

ANN ARBOR, MICHIGAN 48105-2498

OFFICE OF

AIR AND RADIATION

                                                                        
         	     

EPA-Odyne Heavy-Duty Hybrid OBD Discussion

3pm-4pm EST  	May 10, 2011

Agenda

EPA’s Questions for Odyene:

1. How does Odyne handle warranty issues today?

2. Does Odyne buy engines or vehicles – What’s Odyne’s role in
vehicle assembly process today?

3. Based on Odyne’s comments, EPA understands that they do not believe
they should be responsible for vehicle/engine warranty.  Does Odynes
position in the vehicle creation process support this?

As noted in Odyne’s comments, in 2013 OBD is required on heavy duty
vehicles.  Hybrid systems will be considered part of the engine system
and be required to comply with the comprehensive component portion of
the EPA’s OBD regulation assuming they interact with the engine. 
Through the road hybrid system (where there is no interaction with the
engine system) will not be required to have OBD.

4. How does your hybrid system interact with the engine?

Does it shut off the engine?

Can it add torque to the crank shaft?

Does it supply a load to the engine?

Does it have communication with the engine system?

5. Does Odyne believe their hybrid system will be required to have OBD?

6. If so, what has Odyne done to prepare for 2013?

Odyne’s Questions for the EPA:

1. Why would Odyne’s system need OBD based on the
operation/interaction with the vehicle and engine today?

2. Are there different regulations (OBD, GHG) for PTO based operation
different than hybrid operation?

Attachment:

Comprehensive Component Regulations – can be found starting on page
8391 of the final heavy-duty OBD rulemaking.  Note they are also
discussed in other parts of the final rule, but this is the main text on
‘comprehensive components’ – the entire rule can be accessed here:

  HYPERLINK
"http://www.epa.gov/otaq/regs/im/obd/regtech/hd-obd-frm-02-24-09-notice-
74-fr-8310.pdf" 
http://www.epa.gov/otaq/regs/im/obd/regtech/hd-obd-frm-02-24-09-notice-7
4-fr-8310.pdf 

(double click on file to open .pdf file that contains the regs)

 

 U.S. EPA, NHTSA, and DOT, “Greenhouse Gas Emission Standards and Fuel
Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles,”
republished December 29, 2010.  Available here: 
http://origin.www.gpo.gov/fdsys/pkg/FR-2010-12-29/html/2010-32726.htm

 U.S. EPA, “Control of Air Pollution from New Motor Vehicles and New
Motor Vehicles Engines; Final Rule Regulations Requiring Onboard
Diagnostic Systems on 2010 and Later Heavy-Duty Engines Used in Highway
Applications Over 14,000 Pounds; Revisions to Onboard Diagnostic
Requirements for Diesel Highway Heavy-Duty Vehicles Under 14,000
Pounds,” published February 24, 2009.  Available here:
http://www.epa.gov/otaq/regs/im/obd/regtech/hd-obd-frm-02-24-09-notice-7
4-fr-8310.pdf

