


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


									          	OFFICE OF
										AIR AND RADIATION

January 18, 2011

MEMORANDUM

SUBJECT:	Meeting with the Motor & Equipment Manufacturers Association (MEMA)

FROM:	Angela Cullen

TO:		Docket EPA-HQ-OAR-2010-0162

This memorandum documents a teleconference held on Thursday, January 13, 2011 between EPA, NHTSA, and MEMA.  The individuals who participated in the teleconference include:

      EPA: Byron Bunker, Chien Sze, Cle Jackson, and Angela Cullen
      
      NHTSA: Maurice Hicks
      
      MEMA: Leigh Merino and representatives from Bergstrom, Bendix, Delphi, Eaton, Essbar Heating Systems, Honeywell, Reemy, Bosch, SRG Global, Webasto, ZF, and Alcoa

In the meeting, EPA provided clarifications to the questions posed by MEMA included below:
Clarification Questions / Issue Areas for EPA Call 1/13/11
1.       Relative to the regulatory flexibilities, as we understand it, the agencies want to encourage faster adoption of advanced technologies and, as such, have proposed including a 1.5 credit for Hybrid Powertrains (designs that include energy storage systems); Rankine Cycle Engines (waste heat recovery); All-Electric Vehicles; and, Fuel Cell Vehicles. 
Please consider the following questions:
         a.       Agencies requested comments on the technologies identified and whether additional technologies should be added to the list. We interpret that to mean the agency needs a concrete list of advanced technologies and/or advanced technology categories. Is a "fixed list" what the agencies envisioned for the standards? Or would the agency be open to an approach / system that could add, over time, advanced technologies to an active list / living document to include technologies (deemed / defined as "advanced") evolve within those categories listed in the NPRM? 
         b.      Specific question re: Rankine Cycle Engines  -  On Page 74255 the NPRM specifies "Rankine cycle engines" as a proposed advanced credit technology. Is "Rankine" interchangeable with "bottoming cycle" in this context?
         c.       Specific question re: Hybrid Powertrains  -  On Page 74188 the NPRM specifies "the agencies propose to set standards for the chassis manufacturers of vocational vehicles." Can advanced technology credits be generated for hybrid vocational vehicles in the case where the hybrid system integrator is not the chassis manufacturer? If yes, is the chassis manufacturer required to do the testing or is it acceptable for the hybrid system integrator to do the testing for the credits calculation?
2.       For innovative technologies we understand the agencies included them as those technologies "for which the reduction benefits are not captured over the test procedure used to determine compliance with the standards"   -  and are, therefore, "off-cycle." The agencies continue on to say that eligible innovative technology "are newly introduced in one or more vehicle models or engines, but that are not yet widely implemented in the heavy-duty fleet." 
We would like clarification on how the agencies interpret "newly introduced" and "widely implemented."
3.       We notice that under the "Definitions" section of the proposed regulatory text (Subpart I -- Definitions and Other Reference Information§ 1036.801 Definitions), there are no proposed definitions for either "advanced technologies" or "innovative technologies." Was that intentional? 
4.       Page 74209 (center column) refers to "four separate N2O measurement methods" and that "EPA expects that most manufacturers would use photo-acoustic measurement equipment". What are the other acceptable measurement methods?
5.       Can the agencies share with us what was the volume mix of diesel and gasoline vehicles used to establish the 2010 common baseline for the pickups and vans?
6.       In the pickup and vans category, can credits be applied across fuel types within this category? For example, can credits on diesel vehicles be applied to compensate for deficiencies on gasoline vehicles?
7.      Why are improved accessories for HD pickups and vans only considered for diesel engine vehicles and not gasoline engine vehicles  

