 

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

Research and
Innovative Technology
Administration

Volpe National Transportation Systems Center

June 16, 2011
MEMORANDUM
SUBJECT:	Ex parte meeting with Allison Transmission
FROM:		Coralie Cooper, Volpe
TO:		Docket No. NHTSA-2010-0079
This memorandum documents a meeting held on May 19, 2011 between Allison Transmission, 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.  The attendees included:
Allison: Debbie Gordon, Kevin Rogers, Curt Vapor, George Pelton, Mark Janson, Bob Leopold,  Robert Meyers
EPA: Cle Jackson, Angela Cullen, Houshan Zhang, Allen Duncan, Bill Courtis, Peter Smith, James Sanchez
DOT: Coralie Cooper, Maurice Hicks
The following topics were discussed during the meeting:
Vehicle testing:  Allison staff stated the effect of the transmission on GHG emissions and fuel consumption cannot be accurately assessed in isolation, but only with the entire vehicle system.  Thus, Allison stated, the agencies should not finalize a protocol for testing transmissions at this time.  Allison recommended excluding transmissions as proposed in the NPRM.

Drive cycle for certification testing:  Allison staff noted that numerous comments were submitted on the proposed drive cycles, and especially for vocational vehicles, which said the cycles do not reflect real world operation.   Commenters were generally in agreement that steady-state cruise is over-represented in the drive cycles and transient operation under-represented.    Allison suggested a number of improvements to the drive cycles, including: 
   * weight the cycles on percent time and not distance  -  time weighting needs to be made clear in regulations since conflicting language exists in the NPRM.  Likewise, PTO operation needs to be measured by time; 
   * include grade in the drive cycles since these impact emissions and fuel consumption.  If grade cannot be added, then the percent time spent in transient mode should be increased; 
   * include vocational sub-group weightings (there is currently only one vocational vehicle test cycle weighting as the NPRM is written).  Adding sub group weightings would more accurately reflect the vehicles in the fleet today; 
   * do not include straight line acceleration in the GEM drive cycles since straight line acceleration does not reflect normal acceleration curves.  They added that straight line acceleration is biased toward automatic manual transmissions;
   * Use a European-type approach for drive cycles, which include more transient operation.
Hybrid Testing/Innovative Technology Program:  in order to avoid gaming the certification process, Allison stated that a common vehicle configuration which is actually built by OEMs needs to be defined for the "A" vehicle.  They added the "B" vehicle needs to be the exact vehicle that goes into production.  In addition, the vehicle system needs to be defined:
      * Engine, engine calibration, and after-treatment system;
      * Automatic transmission system must replicate the actual, integrated vehicle system;
      * Transmissions system components must be defined and required for testing;
      * Hybrid system components, such as energy storage, electrical system/accessory loads need to be defined and included in testing.
The agencies agreed to consider the above requests in the development of the final rule.
