 

U.S. Department 										55 Broadway
of Transportation										Cambridge, MA 02142

Research and
Innovative Technology
Administration

Volpe National Transportation Systems Center

July 25, 2011
MEMORANDUM
SUBJECT:	Ex parte meeting with Owner-Operator Independent Drivers Association (OOIDA)
FROM:		Maurice Hicks, NHTSA
TO:		Docket No. NHTSA-2010-0079
This memorandum documents a meeting held on November 1, 2010 between the Owner-Operator Independent Drivers Association (OOIDA) EPA, and DOT regarding the proposed fuel efficiency and greenhouse gas standards for medium- and heavy-duty vehicles and engines for model years 2014-2018.  OOIDA requested a meeting with NHTSA to discuss the effects of the proposed heavy-duty truck fuel efficiency rule on independent owner operators.  The attendees included:
OOIDA: Mike Joyce, Joe Rackavacks, John Spencer
EPA: Byron Bunker, Cheryl Bynum, and Angela Cullen 
NHTSA/DOT: James Tamm, Rebecca Yoon, Gregory Powell, Lixin Zhao, Angel Jackson, and Maurice Hicks, Ryan Harrington
The following topics were discussed during the meeting:
OOIDA asked the following questions with regard to implementation of the heavy-duty program:

   * Whether "classic" tractors could meet the vehicle standards using GEM?  NHTSA staff noted that page 147 of the preamble shows the standard for traditional tractors; 
   * If NHTSA planned on having an in-use requirement?   NHTSA staff responded that the NHTSA regulation applies at the first commercial sale.
OOIDA raised a number of potential impacts on industry from the rule, including: 
   * The agencies' efforts to improve fuel efficiency through weight reduction could reduce the crashworthiness of heavy duty tractors; 
   * The regulation is anticipated to increase the average tractor cost which will impact owner operators; 
   * Second stage manufacturers will be limited in making specific task changes to the OEM's original tractor design in order to maintain the specified fuel consumption performance of the vehicle; 
   * There will be a net zero effect in fuel consumption and CO2 performance from weight reduction approaches due to the additional weight from aerodynamic features such as fairings needed for compliance with the standards.
   OOIDA expressed opposition to aspects of the proposed rule and in some cases provided alternative approaches:
         * OOIDA opposes the use of speed limiters for heavy-duty tractors.  The argued that the use of speed limiters could increase the need for additional trucks to deliver the same amount of freight. 
         * OOIDA opposes the use of auxiliary power units (APU's) in tractors operating in cold conditions, stating that APU's are not effective in extremely cold temperatures and operators will have to keep the vehicle running in order to remain warn.  OOIDA staff provided information on the uses of improved cabin insulators as an alternative. 
         * OOIDA asked that weight reduction through tires should not be considered since manufacturers need to maintain the current performance of tractor tires.   They did not provide data during the meeting to show that low rolling resistance tires have poor performance.

The agencies agreed to consider the above requests and concerns in the development of the final rule.
