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2000 Town Center—Suite 1140, Southfield, MI 48075 • Phone 248.357.4717 • Fax 248.357.4740 • www.autoalliance.org March 31, 2009

Karl Simon Director, Compliance and Inno vative Strategies Division U.S. EPA Office of Transpor tation and Air Quality
2000 Traverwood Drive Ann Arbor, MI  48105

­­ Delivered via email ­­

RE: Request for approval of new scheduled maintenance under §86.1834

­ 01(b)(7)(ii))

Dear Mr. Simon:

The Alliance of Automobile Manuf acturers (Alliance) requests th at EPA approve as a "new
scheduled maintenance" the refi ll of DEF (Diesel Exhaust Fluid) for SCR (Selective Catalytic Reduction) emission control syste ms. This request is an industr y‐wide request for light‐duty
and chassis certified vehicles f or 2 model years (Model Years 2 009 and 2010).

This request is for maintenance which did not exist prior to th e 1980 model year.
We recommend that the maintenanc e category for DEF refill be em ission‐related, critical

maintenance.

We further recommend that, for Model years 2009 and 2010, the t echnologically necessary SCR maintenance interval (i.e., DEF tank refill interval) shoul d be set the same as the service interval (oil change interval) in miles.

The following is our substantiation of this request:

1) Background

On March 7, 2007, EPA issued a Dea r Manufacturer guidance lette r (CISD 07‐07) setting out its SCR vehicle cert ification requirements for ligh t‐duty and heavy‐duty manufacturers. The guidance addressed 40 CFR §86.004‐25, §86.09 4‐25 & §86.1834‐2

01 Allowable Maintenance; and 4 0 CFR §86.094‐22 & §86.1833‐01 A djustable
Parameters.

On February 18, 2009, EPA issued a nother Dear Manufacturer guid ance letter (CISD‐ 09‐04) providing additional guidan ce for HD truck manufacturers . The guidance set out minimum DEF tank sizes, and allowed a minimum DEF tank size of 2 times the fuel tank range if the vehicle is equ ipped with a DEF tank level ind icator (2:1 refill interval).

2) Reasons for why DEF refill is an emission

­ related, critical maintenance

EPA noted in CISD 07‐07 that sinc e the SCR catalyst does not fu nction without the use of a reducing agent, 40 CFR § 86.1834‐01(b)(4)(ii)(F) and §86.00 4‐25(b)(4)(iii)(F) would apply to the SCR catalyst and all of the associated hardw are, including but not limited to, the reducing agent, the reducing agent storage tank , the dosing valve, and all lines and hoses. We agree with EP A that DEF refill is an emissi on‐related, critical

maintenance.

3) Reasons for why the technologically necessary SCR maintenance interval should be
the same as the service interval for Model Years 2009 and 2010

The reasons for why the technolo gically necessary SCR maintenan ce interval should be
the same as the service interval (oil change interval) are very much the same reasons that EPA found persuasive for determining the 2:1 heavy‐duty ve hicle DEF refill interval. Namely, vehicles will be designed and equipped to ens ure vehicle compliance with emission standards, DEF wil l be readily available and acce ssible to drivers, maintenance is likely to be perf ormed and there is limited spac e available on vehicles for a large DEF tank.

a) Vehicles will be designed and equipped to ensure compliance with emissions
standards

i) Driver Warning Manufacturers will equip vehicles with an escalating audible an d visual warning chain that provides adequate tim e to re‐fill the DEF. USCAR has developed a recommended practice for manufacturers to use as a standardized warning chain. This warning chain has also been adopted as an SAE industry‐wid e recommended practice. SAE has also standardiz ed the DEF indicator symbol. M anufacturers will use an escalating mix of DEF level indicator, messages in the i nstrument cluster, engine shutdown lamp, or audible warnings to warn the driver of low DEF levels.

ii) Driver Inducement Manufacturers will equip vehicles with escalating and sufficien tly onerous levels of
inducement to ensure that the DE F is refilled. This escalating inducement also includes identification of incorrect reducing agent.3

iii) Tamper Resistant Design Manufacturers will design the SCR system to be tamper resistant consistent with the EPA’s March 27, 2007 guidance letter. The actions listed be low will trigger illumination of a warning lamp:

• Disconnected DEF tank level sensor

• Blocked DEF line or dosing valve

• Disconnected DEF dosing valve

• Disconnected DEF pump

• Disconnected SCR wiring harness

• Disconnected NOx sensor (that is incorporated with the SCR syst em)

• Disconnected DEF quality sensor

iv) Freeze Protection Manufacturers will design and equ ip vehicles with DEF Dosing Fr eeze Protection Systems which will prevent or minimize SCR performance degradat ion due to freezing of DEF. This can includ e DEF tank heaters, line heater s, and location of tank within a heated space.

b) DEF will be readily available and accessible to drivers

i) DEF is available at dealerships, gas stations and truck stops The manufacturers of SCR vehicles have worked with franchised d ealerships to supply DEF to their customers. Se veral of these manufacturers h ave agreements with gasoline station chains to ensure availability of DEF at t hose refill stations. In addition, several truck stops ha ve announced publicly their int ention to stock DEF. To further ensure the quality of DEF at these retail locations, the American
Petroleum Institute will be cond ucting a quality control progra m with the support of distributor and retailer licensing agreements.

ii) An organized industry

­ wide SCR Stakeholder Group is ensuring wide availability of DEF DEF infrastructure development i s making significant progress. Industry‐wide standards for DEF infrastructure, a necessary enabler for the w idespread availability of DEF, have been put in place, including ISO DEF specifications, API's DEF quality standard, SAE DEF spe cifications, and USCAR and SAE warning chain
standards. The SCR Stakeholder G roup has established itself as a focal point for infrastructure development discussions by   producers, supplier s, distributors and
users of DEF.

iii) Drivers can locate DEF through locator website DOE/NREL has established a locator website for drivers to use t o locate supplies of

DEF.4



### iv) Public awareness of availability is increasing through DEF public relations
activities

Numerous press releases and public relations activities have been distributed
related to the development of DEF infrastructure. Announcements of new truck
stops planning to add DEF and new industry DEF websites have been released.
Attached please find three recent examples of press releases: Pilot Travel Centers LLC, TravelCenters of America LLC, and Cummins Filtration.



### c) Maintenance is likely to be performed on schedule
There are a number of reasons why the DEF refill maintenance is likely to be performed. Vehicles will be equipped with an escalating warning chain which will audibly and visually signal that the maintenance needs to be performed. In the unlikely

event that the warnings are not heeded and the maintenance is not performed, the performance of the vehicle will be noticeably and significantly degraded.



### d) There is limited space available on light duty vehicles for a large D EF tank Light duty vehicles are constrained in the amount of space that can be dedicated to a DEF tank. For example, one SCR light duty vehicle in current production must find

space to accommodate an 8 gallon DEF tank in addition to the separate fuel tank of 21 gallons. Furthermore, the addition of weight from a large quantity of DEF reduces the
fuel economy of vehicles.

For these reasons, the Alliance requests that EPA approve a new scheduled maintenance
interval of DEF refill for light-duty and chassis certified vehicles for Model years 2009 and
2010 that coincides with the manufacturer's service interval (oil change interval).

Sincerely,

Giedrius Ambrozaitis Director, Environmental Affairs

cc: Linc Wehrly, Compliance and Innovative Strategies Division

Laura Baker, Compliance and Innovative Strategies Division

Attachments

### Pilot Travel Centers LLC Provides Details about Diesel Exhaust Fluid Availability

Knoxville, TN – February 8, 2009

– Pilot Travel Centers LLC has announced

the details and scheduled rollout for Diesel Exhaust Fluid (DEF) availability at its

North American truck stops. DEF is a requi red fluid for 2010 selective catalytic

reduction (SCR) systems that reduce No x through a catalytic process in the

exhaust stream.

Pilot will rollout 25 bulk dispensing units per quarter, starting in Q3 2009 through

Q2 2010. Ultimately, approximately 100 of Pilot’s locations will have bulk

dispensing capabilities at the fuel island where it will be most convenient. All 328

truck stops will have the packaged quantities availabl e. The company will begin

ordering the equipment for the bulk dispensi ng units within the next few weeks.

The equipment will be state of the art and designed to store, pump, and transact

DEF to customers in a wide vari ety of climates and conditions.

“Many of our customers will be purchasi ng SCR-equipped trucks in 2010, so as

they began coming to us to learn more about SCR and DEF, we did a lot of

investigating. We determined there was a strong opportunity to not only fulfill our

customers’ needs, but to be an industr y leader,” said Patrick Deptula

Director of Design and Construction, P ilot Travel Centers. “By working with

Detroit Diesel and Daimler Trucks North America – who are also leaders with

their BlueTec 2010 technology – we l earned even more about the benefits of

those systems.”

Because a typical truck can go approxim ately 300 miles on just one gallon of

DEF, Pilot’s 328 convenient locations – including the 100 bulk dispensing

locations – are well situated for the periodic refills.“We will continually review our rollout pl an for bulk dispensing locations to ensure

we are meeting the needs of our customers every step of the way,” said Deptula.

“This includes having convenient pay-at- the-pump transactions that can be

simply completed while the driver is also filling up with diesel fuel. Our goal in

the process is to make everything as seamless as possible for our customers.”

Added Mark Lampert, senior vice presi dent of sales for Daimler Trucks North

America: “Our customers ar e excited to adopt BlueTec emissions technology in

2010 to take advantage of all the fuel economy and performance benefits it

delivers. But the only missing piec e had been the convenient widespread

availability of DEF. Thanks to Pilot’s bold and groundbreaking first step, as well

as the rest of the DEF infr astructure supply chain coming together to prepare for

SCR, this positions Daimler Trucks and our customers very well for 2010.”

For a complete list of all North Am erican Pilot Travel Centers, go to

www.pilotravelcenters.com

.

###FOR IMMEDIATE RELEASE

Contact: Tom Liutkus TravelCenters of America
440-808-7364 liutkus.tom@tatravelcenters.com

TA Shares Further DEF Supply Details More options and convenience for customers

Louisville, KY, March 19, 2009 -- TravelCenters of America LLC announced today further details of their plans distribution of diesel exhaust fluid, or DEF, in preparation for the SCR technology in use by most major truck manufacturers for the 2010 models. The announcement was made during the CEO Summit on SCR technology at the Mid American Truck Show in Louisville, Kentucky. The CEOs and Presidents of TravelC enters of America LLC, Daimler Trucks North America LLC, Volvo Trucks, Cummins Engine Bu siness, Mack Trucks, and Terra Industries all participated in the summit,

TravelCenters of America LLC is uniquely pos itioned as an important part of future DEF distribution infrastructure. Full service TA and Petro branded facilities will offer multiple supply solutions for virtually every need and for the conveni ence of our customers. DEF will be available in pre-packaged containers in the travel stores an d fuel island buildings in 235 locations, in bulk quantities at key locations nationwide and in bulk quantities at substantially all TA and Petro:Lube truck maintenance facilities. In addition, t he RoadSquad brand fleet of over 400 emergency roadside assistance vehicles will carry quantit ies of DEF to accommodate our customer’s over the road emergencies.

TravelCenters of America LLC expects to roll out its distribution plans during the second quarter of 2009. Prepackaged and emergency quantities ar e expected to be available at all facilities before the end of the second quarter 2009. Bulk quantities are expected to be available in truck maintenance facilities and on-island locations beginning in the during the second half of 2009.

About TravelCenters of America LLC

TravelCenters of America LLC (TA), headquartered in Westlake, Ohio is a leading travel center business in 41 states and Canada operating under the TravelCenters of America and Petro
brands. With convenient locations on interstate exits, TA offers its cu stomers diesel and gasoline fueling services, full and quick-se rvice restaurants, heavy truck maintenance services, 24-hour convenience stores, electronic communication (WiFi) and other services --- all within large, high traffic facilities. For more information on TravelCenters of America, please visit
www.tatravelcenters.comSupply Option Illustrations

Examples of options available for pre-packaged DEF. TA and Petro locations are expected to have containers of DEF throughout the U.S. by end of June 2009.

TA and Petro also expect to offer an exclusive method of supply of DEF through TA and
Petro:Lube truck service center s. TA and Petro:Lube branded locations include nearly 1,000 service bays across the U.S. Trucks are expecte d to be able to fill-up or top off DEF conveniently during other routine mainte nance or repair services. This se rvice will be made available as early as the end of June 2009. TA has 164 and Petro:Lub e has 67 truck service c enters that service all makes and models of Class 8 trucks. TA and most Petro:Lube locations are ServicePoint® authorized light duty warranty repair centers for Fr eightliner and Western Star vehicles pursuant to TA’s long-standing agreement with Daimler North America LLC.TA and Petro locations expect to install at-island dispensers at selected high volume locations beginning in the second half of 2009. Lanes with DEF availability will be clearly marked for driver convenience. Several technologies will be te sted to identify the most cost efficient and convenient solution for our customers.TravelCenters of America LLC oper ates its RoadSquad brand of emer gency vehicles out of its TA and Petro branded locations. RoadSquad’s network of over 400 service vehicles will bring out DEF to refill on an emergency basis. RoadSquad service is available 24 hours a day, every day of the year by calling 1-800-824-7467.

Note: Hi-resolution copies of all but the plastic c ontainer photos can be requested by contacting Jennifer Ina within TravelCenters of America LLC’s Advertising & PR Department, either by calling (440)808-3256 or by e-mailing her at Ina.jennifer@tatravelcenters.comDiesel Progress – Online Edition

Industry News

DEF Availability Oct. 1 For Cummins

March 18, 2009

In an effort to address lingering concerns about the av ailability of diesel exhaust fluid (DEF) for its 2010 engines, Cummins Inc. announced that as of Oct. 1 of this year, its Fleetguard branded DEF would be available at all of its engine distributors, as well as through most of its Cummins Filtration organization.

In all, the company said the substance could be pur chased at 20 Cummins distributors at more than 187 locations throughout the U.S., Canada and Mexico. DEF will also be available through the Cummins Filtration network, which includes over 20,000 locations with nearly 8000 retailers in North America.

Cummins Filtration has been providing DEF since 2003, formerly sold under the StableGuard Urea name. Fleetguard DEF product is currently available in seve ral packaging options, including bulk, 330 gal. plastic totes, 275 gal. disposable totes and 55 gal. plastic drums. Smaller packaging sizes and dispensing equipment are expected to be available by mid-2009.

“Customer needs will vary based on consumption, fueling procedures and other factors. Cummins Filtration is committed to offering dependable DEF suppl y solutions to meet these different customer needs,” said KC Hall, director of Diesel Exhaust Fl uid Business Development. “While some customers will enjoy delivery of DEF produc t along with their other f iltration products, other cust omers will opt for specific DEF supply arrangements to streamline their business processes.”