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


									     OFFICE OF
									AIR AND RADIATION
3/8/16

MEMORANDUM

SUBJECT: Daimler visit on Phase 2 GEM and Road grade comments

FROM: Houshun Zhang

TO:  Greenhouse Gas Emissions Standards and Fuel Efficiency Standards for Medium- and
Heavy-Duty Engines and Vehicles - Phase 2 - Docket EPA-HQ-OAR-2014-0827



This memo documents a phone conference call with Daimler on March 8, 2016 on road grade issues related to the Phase 2 greenhouse gas and fuel efficiency standards for heavy-duty vehicles.  Five people from Daimler are Gerald Freitag, Dave Kayes, and Dod Keski-Hynnila.

During the meeting, Daimler expressed their concerns on the road grade profile called Profile D.  Their data showed that this profile would distort the market and technology development because the vehicle has to run the full throttle position for too long, which is more than 22%.  In contrast, their data shows the real life truck only spent 13% on the 100% loads.  They recommended that the agency consider revising the road grade that can better represent the real life driving condition.
