PSI Remarks: EPA GHG-2 Proposed Rulemaking Au g ust 6, 2015 Good afternoon. M y name is AI Cohn, Director of New M arket Development and Eng ine eri ng Support for Pressure Systems International, better known as PSI , which is the global innovator beh in d automatic tire inflat i on systems (ATIS). My interest in p resenting at this hearing i s to address the definition of an a utomatic tire inflation syste m and the requirements of a ' qualifi ed' ATIS system. Our company invented our automatic tire infl at ion system 22 years ago and mar ket it globally. In N.A

. { North America) we market it under the Meritor bra nd name- t he Meritor Tire Inflation System by PSI. Commerc ial trai l er tires receive t he least amount of maintenance on commercial tractor/tra il er comb in atio ns. Tod ay, we estimate that approximately half of the com mercial trail e rs be in g produced in N .A. have some typ e of tire so lution , with th e overwhelming majority being ATIS. We al so esti mate that over 1 million trai l ers are current ly running wi th ATIS today. The benefits of A TIS include increasing fuel economy, red ucing greenhouse gas emissions , 

### & sign ificant ly reducing tire 

### & safety related roadside se rvice ca ll s. It also dramatica ll y reduces road debris from tire cas in gs, and better utilization of cas in gs for retreads for lower oil consumption by the tire manufacturers. A typical return on investm e nt i s we ll under 12 months

. Th e basic principal of ATIS is to insure that tires main tain a min i mum specified tire pressure as determined by th e fleet. However, there are numerous 'tire so luti o ns' in the market today, and there are opera tio nal characteristics between so me of those that classify themselves und er th e ATIS heading. Wit h most ATIS syst e ms air is automatically added whenever an individual tire pressure drops below the system sett ing, eit he r whi le t he trai l er is in a static or dynamic s t ate. I wish to clarify two (2) important items in the proposed ru lemaking. The definit ion of automatic t i re inflat ion listed in Subpa rt 1 , Definitions & Other Reference In fo rm at i on, is not co nsistent with t he historical in dustry definitions.TMC, The Technology Maintenance Council, of the American Trucking Association, in their Recommended Practice, RP239A (most recently updated in 2014) uses the following widely accepted definition of A TIS: 

### Automatic Tire Inflation Systems maintain tire pressure at a single preset level and are pneumatically or electronically activated. A warning lamp indicates to the driver that the system has been activated and air is being added to a tire. These systems eliminate the need to manually inflate tires

. The curre nt definition included in the rulemaking states: 

### A TIS means a system installed on a vehicle to keep each tire inflated to within 10% ofthe target value with no operator input. Assigning an arbitrary number of 10% is not cons istent with the laws of tire physics. Tire pressure increases by 15- 20% when the tire is hot and running on a fully loaded vehicle at 75 mph on asphalt roads on a sunny day. Tires coo l back down to the specified tire pressure after a few hours. The issue with tires and reduced fuel economy & increased greenhouse gas emissions is because of tire underinflation. ATIS systems assure that tires will always be running at the recommended cold tire inflation pressure. The second issue to address is a clarification regarding "q ualified " automat i c tire inflation systems. Page 1026, §Section 1037

. 107 Emission stan dard s for trailers of the proposed rul emaking, discusses the use of low rolling resistance tires and that "q ualified" automatic tire inflation systems a re required on non-box trailers effect ive MY 2018. It is our recommendation that the term " qualified" be expanded

. SAE Recommended Practice J2848-2 , dated June 2011, is an RP on the subject of ATIS. It is the industry standard that details the basic operational requirements for any A TIS. This RP should be referenced in the proposed rulemaking when "qualified" automatic tire inflation systems are discussed. Thank you very much for all ow in g m e to address th is group and will be happy to entertain any questions or comments. (2 Attachments: TMC RP239A and SAE J2848

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