From: "Debbie L. Gordon" <debbie.gordon@allisontransmission.com>

To: Byron Bunker/AA/USEPA/US@EPA Date: 05/16/2011 05:31 PM Subject: RE: Your questions from W ednesday


### Byron, Thank you for getting back to me. I appreciate the information with regard to the calculation of g/mile or ton
- mile calculation but to clarify on my previous question, we have been trying to determine how the drive cycle weightings were developed for tran sient and steady state operations at 55 mpg and 65 mpg. We have looked at preamble, RIA and supporting documents that are in the docket, but cannot determine whether the weightings themselves were based on time or distance; i.e., whether the percentages a re derived from data representing the relative amount of time a vehicle spends at these mpg's, or the amount of distance that vehicles travel at these steady state modes. Could you clarify as to the source of the data and the basis for the calculation? I have some examples shown below that get to the nature of our questions. If you can reply in advance before Thursday, that would be great, but if not, we can discuss face

- to
- face. Thank you again. Best regards, Debbie

One source of confusion is found in the RIA: 

### Oak Ridge National Laboratory evaluated the fuel efficiency effect of tires on Class 8 heavy trucks. The estimation is based on FHWA’s Highway Statistics and the Census Bureau’s Vehicle In

- Use Survey

(VIUS). The study found that Class 8 sleeper cabs use an average of 6.8% of their fuel idling. 19 

### The study collected fleet data related to real

- world highway environments over a period of two years. The fleet consisted of six trucks which operate widel y across the United States. In the Transportation Energy Data Book (2009) 20 

### Table 3

- 5: Combination Tractor Drive Cycle Weighting Table 5.11 was anal yz ed and found on average that the line haul **trucks spent 5% of the miles** at speeds less than 50 mph, 17% between 50 and 60 mph, and **78% of the time**  at speeds greater than 60 mph. The text highlighted in red appears to be weighted on distance whereas the text in green appears to be weighted on time. Additionally, when the drive cycle is described for hybrids, with and without PTO, it is also c onfusing if it is to be distance

- based because the PTO operation would have to be based on time since the vehicle is stationary during that operation. The Figure below was submitted as Attachment 4 in our comments. As you can see, the results of these c alculations can be very different when considering % time vs. % distance.**From:** Bunker.Byron@epamail.epa.gov [mailto:Bunker.Byron@epamail.epa.gov]

**Sent:** Friday, May 13, 2011 4:57 PM **To:** Debbie L. Gordon **Cc:** Jackson.Cleophas@epamail.epa.g ov **Subject:** Your questions from Wednesday Hi Debbie, I am sorry that it has taken me so long to respond. Here are m y responses to your questions from our call W ednesday. 1) Can EPA update Allison on our testing and reasons for wanting to retest? The person best able to talk about the completed testing will be on travel on the 18th. W e are trying to find someone else that can walk us through the results. I will confirm on Monday if we will be able to go through the test results. W e will definit ely

be able to explain our reasons for retesting. 2) Are the EPA drive cycles time based or distance based? The vehicle drive cycles are expressed as speed versus time. However it is the actual distance traveled (either literal chassis roll revolution s or integrated actual attained speed) that determines the distance used in the g/mile or ton
- mi le calculation. So the vehicle does it best to follow a speed vs time trace, but the actual distance traveled is what is used in determining the compliance met ric. 3) Can EPA respond to questions i
- x on pages 37
- 38 of Allison's comments? Since most of the questions are comments on the proposal and not simply questions for information, I would prefer to talk about the issues raised by the questions during our me eting on the 18th. Thanks, By ron

****************************************************************** By ron Bunker Center Director
- Heavy
- Duty Onroad Center Assessment and Standards Division Office of Transportation and Air Quality US Environmenta l Protection Agenc y 2000 Traverwood Drive Ann Arbor, MI 48105 (734) 214
- 4155 (734) 214
- 4050 (fax) (734) 353
- 9623 (cell) e - ma il: bunker.byron@epa.gov **********************************************************