


UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                NATIONAL VEHICLE AND FUEL EMISSIONS LABORATORY
                             2000 TRAVERWOOD ROAD
                           ANN ARBOR, MI  48105-2498


									          	OFFICE OF
										AIR AND RADIATION

December 7, 2010

MEMORANDUM

SUBJECT:	Early Credit Option: Intrerim Provisions of § 1036.150(a) or § 1037.150(a)

FROM:	Lauren Steele/ASD

TO:	Greenhouse Gas Emissions Standards and Fuel Efficiency Standards for Heavy-Duty Engines and Vehicles; Docket EPA-HQ-OAR-2010-0162

      This memo documents a pair of telephone calls between Alec Zacaroli, Senior Counsel at Wallace King Domike & Reiskin, PLLC and staff at EPA/OTAQ, on December 7, 2010.  

      Mr. Zacaroli, when speaking with Lauren Steele (OTAQ/ASD), Cleophas Jackson (OTAQ/CISD) and Julian Davis (OTAQ/CISD), requested clarification of the interim provisions for generating early emission credits under proposed sections 40 CFR 1036.150(a) and 1037.150(a). 
      
      Mr. Jackson provided several clarifications, including that the averaging set for this provision is intended to be all engines or vehicles in the applicable regulatory subcategory, such as all heavy-heavy-duty diesel engines or all medium roof sleeper cab tractors, or the whole fleet in the case of 2b's&3's.  He also clarified that it is not intended that all certified engines or vehicles be early credit generators. He also clarified that data submitted for early certified engines or vehicles would be consistent with that of the GHG reporting rule.
      
      
