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


									     OFFICE OF
									AIR AND RADIATION

July 19, 2012


MEMORANDUM

SUBJECT:  Meeting July 18, 2012 between Pat Raher Esq. and EPA representatives

FROM:  Steven Silverman, Attorney OGC
	

TO:  EPA Docket # EPA-HQ-OAR-2010-0799
--------------------------------------------------------------------------------


On July 18, 2012, Pat Raher (counsel for Daimler-Mercedes) met with various EPA representatives including Office Director Margo Oge, Ed Nam, Matt Spears and myself.  Mr. Raher clarified certain aspects of Daimler's suggestion that credits generated by certain heavy duty engines should be transferable to the light duty sector.  Specifically, the company's suggestion is that a medium heavy duty engine could generate credits which could be used in the light duty sector if a 4 cylinder engine is used which engine is also used in light duty applications and the total amount of credits is capped.  We noted that this suggestion was well beyond the scope of the proposal, and also would require amending the heavy duty rules which restrict credit transferability to certain specified averaging sets within the heavy duty sector.  However, we noted that the issue could be appropriate for consideration in later model year heavy duty GHG rules, or in the midterm review of the MYs 2012-2025 light duty rules.
.
