From: brian.c.mormino@cummins.com

To: Byron Bunker/AA/USEPA/US@EPA Cc: gary.c.salemme@cummins.com, jackie.m.yeager@cummins.com, morgan.andreae@cummins.com, robert.a.jorgensen@cummins.com, zhen.sun

Jackson/AA/USEPA/US@EPA, Angela Cullen/AA/USEPA/US@EPA, Charles Moulis/AA/USEPA/US@EPA Date: 05/02/2011 10:12 PM Subject: Materials By ron: Attached and below are the materials from our visit last week. Please let me know if you have any questions, BCM **Vehicle Cycle Slides Child Ratings Compliance Slides**  **Innovative Technology Program Slides Family Discussion**  Suggested change: Decouple GHG families from Criteria Pollutant families Comparison with LDOH: Criteria Pollutant families ("Test Groups") decoupled from CAFE (and GHG) fa mi lies ("Model T ypes ") LDOH Test Group Determination For Criteria Pollutants §86.1827

– 01 ( - 12): Test group determination. This section applies to the grouping of vehicles into test grou ps within a durability group. (a) To be included in the same test group, vehicles must be identical in all following respects: (1) Durability group; (2) Engine displacement (within a total band width of 15 percent of the largest displacement or 50 CID, which - ever is larger); (3) Number of cy linders or combustion chambers; (4) Arrangement of cylinders or combustion chambers (e.g. in - line, v - shaped); 5) Subject to the same emission standards (except for CO2), or FEL in the case of cold temperature NMH C standards, except that a manufacturer may request to group vehicles into the same test group as vehicles subject to more stringent standards, so long as all the vehicles within the test group are certified to the most stringent standards applicable to an y vehicle within that test group. Light - dut y trucks and light dut y vehicles may be included in the same test group if all vehicles in the test group are subject to the sam e emission standards, with the exception of the CO2 standard and/or the total HC stan dard.Greenhouse gas emission standards for light- duty vehicles, light- duty trucks, and medium - duty passenger

vehicles. §86.1818 - 12 : (ii) Calculation of fleet average CO2 standards for light trucks: In each model year manufacturers must comply with t he CO2 exhaust emission standard for their light truck fleet, calculated for that model year as follows: (A) A CO2 target value shall be determined according to paragraph (c)(3)(i) of this section for each unique combination of model type and footprint va lue. (B) Each CO2 target value, which represents a unique combination of model type and footprint value, shall be multiplied by the total production of that model type/footprint combination for the appropriate mo del year. (C) The resulting products shall be summed, and that sum shall be divided by the total production of light trucks in that model year. The result shall be rounded to the nearest whole gram per mile. This result shall be the applicable fleet average CO2 standard for the manufacturer‘s ligh t truck fleet. Note: - Model type is defined in 40 CFR 600.002 - 08 as ... a unique combination of car line, basic engine, and transmission class. The fleet average is calculated on the basis of model type emissions Calculation of FTP-based and HFET -base d fuel economy and carbon -related exhaust emission values for a model type. §600.208 - 12: (2) In order to highlight the fuel efficiency and carbon - related exhaust emission values of certain designs otherwise included within a model type, a manufacturer ma y wish to subdivide a model type into one or mo re additional model types. This is accomplished by separating sub - configurations from an existing base level and placing them into a new base level. The new base level is identical to the existing base level e xcept that it shall be considered, for the purposes of this paragraph, as containing a new basic engine.....