1

U.S. Department 

of Transportation

Research and

Innovative Technology

Administration

Volpe National Transportation Systems Center

June 16, 2011

MEMORANDUM

SUBJECT: Ex parte meeting with 

FROM: Coralie Cooper, Volpe

TO: Docket No. NHTSAThis memorandum documents a meeting held on 

DOT regarding the proposed fuel efficiency and greenhouse gas standards for medium

vehicles and engines for model years 2014

Allison: Debbie Gordon, Kevin Rogers, 

Meyers

EPA: Cle Jackson, Angela Cullen, Houshan

DOT: Coralie Cooper, Maurice Hicks

The following topics were discussed during the meeting:

Vehicle testing: Allison staff stated 

consumption cannot be accurately assessed in isolation, but only with the entire vehicle system. Thus, 

Allison stated, the agencies should not finalize 

recommended excluding transmissions as proposed in the NPRM.

Drive cycle for certification testing: Allison 

proposed drive cycles, and especially for vocational vehicles, 

world operation. Commenters were generally in agre

represented in the drive cycles and transient operation under

number of improvements to the drive cycles, including: 

 weight the cycles on percent

regulations since conflicting language exists in the NPRM. Likewise, PTO operation needs to be 

measured by time; 

Volpe National Transportation Systems Center

eeting with Allison Transmission

Volpe

-2010-0079

This memorandum documents a meeting held on May 19, 2011 between Allison Transmission

DOT regarding the proposed fuel efficiency and greenhouse gas standards for medium

vehicles and engines for model years 2014-2018. The attendees included:

Allison: Debbie Gordon, Kevin Rogers, Curt Vapor, George Pelton, Mark Janson, Bob Leopold

EPA: Cle Jackson, Angela Cullen, Houshan Zhang, Allen Duncan, Bill Courtis, Peter Smith, James Sanchez

DOT: Coralie Cooper, Maurice Hicks

The following topics were discussed during the meeting:

Allison staff stated the effect of the transmission on GHG emissions and fuel 

ely assessed in isolation, but only with the entire vehicle system. Thus, 

agencies should not finalize a protocol for testing transmissions at this time

transmissions as proposed in the NPRM.

: Allison staff noted that numerous comments were submitted on the 

proposed drive cycles, and especially for vocational vehicles, which said the cycles do not reflect real 

world operation. Commenters were generally in agreement that steady-state cruise is over

represented in the drive cycles and transient operation under-represented. Allison suggested a 

number of improvements to the drive cycles, including: 

percent time and not distance – time weighting needs to be made clear in 

regulations since conflicting language exists in the NPRM. Likewise, PTO operation needs to be 

55 Broadway

Cambridge, MA 02142

Transmission, EPA, and 

DOT regarding the proposed fuel efficiency and greenhouse gas standards for medium- and heavy-duty 

Leopold, Robert 

ill Courtis, Peter Smith, James Sanchez

the effect of the transmission on GHG emissions and fuel 

ely assessed in isolation, but only with the entire vehicle system. Thus, 

nsmissions at this time. Allison 

staff noted that numerous comments were submitted on the 

said the cycles do not reflect real 

state cruise is overrepresented. Allison suggested a 

ting needs to be made clear in 

regulations since conflicting language exists in the NPRM. Likewise, PTO operation needs to be 
2

 include grade in the drive cycles since these impact emissions and fuel consumption. If grade 

cannot be added, then the percent time spent in transient mode should be increased; 

 include vocational sub-group weightings (there is currently only one vocational vehicle test cycle 

weighting as the NPRM is written). Adding sub group weightings would more accurately reflect 

the vehicles in the fleet today; 

 do not include straight line acceleration in the GEM drive cycles since straight line acceleration 

does not reflect normal acceleration curves. They added that straight line acceleration is biased 

toward automatic manual transmissions;

 Use a European-type approach for drive cycles, which include more transient operation.

Hybrid Testing/Innovative Technology Program: in order to avoid gaming the certification process, 

Allison stated that a common vehicle configuration which is actually built by OEMs needs to be defined 

for the “A” vehicle. They added the “B” vehicle needs to be the exact vehicle that goes into production.

In addition, the vehicle system needs to be defined:

 Engine, engine calibration, and after-treatment system;

 Automatic transmission system must replicate the actual, integrated vehicle system;

 Transmissions system components must be defined and required for testing;

 Hybrid system components, such as energy storage, electrical system/accessory loads need 

to be defined and included in testing.

The agencies agreed to consider the above requests in the development of the final rule.