July 14, 2011

Mr. Cleophas Jackson

Assistant Division Director Compliance and Innovative Strategies Division Office of Transportation and Air Quality U.S. Environmental Protection Agency 2565 Plymouth Road Ann Arbor, MI 48105

Subject: Heavy- Duty Hybrid Powertrain Systems and Heavy Diagnostic Requirements

Dear Mr. Jackson:

Eaton Corporation is a member of the Hybrid Manufac turers Regulatory Collaboration (HMRC). The HMRC was formed to bring together companies inv olved in the heavy hybrid vehicle industry for purposes of addressing common issues associated with regulations affecting hybrid vehicles. HMRC’s othe r current members are Allison Transmission, Inc ., and BAE Systems Inc.

HMRC would like to express its sincere appreciation to you and your staff at EPA for addressing issues that have recently become apparen t regarding heavy powertrain systems and heavy strongly believe that your actions will make it pos sible to avoid a serious disruption of the hybrid heavy- duty vehicle industry and adverse impacts on the ma rket for such vehicles. This in turn will ensure the viability of heavy role in allowing compliance with the Greenhouse Gas Emissions Standards and Fuel Efficiency Standards for Medium promulgated by EPA.

In addition, HMRC appreciates the fact to working with HRMC members and others to clearly define compatibility requirements, and expects that EPA will realistically assess the progress being made toward those goals in determining whether additiona

members believe that resolution of all of these iss ues by the 2016 provided for by EPA will be extremely challenging b ut will strive to achieve that goal.

HMRC understands the need for and sup powertrain systems are compatible with existing hea vy Compliance and Innovative Strategies Division Office of Transportation and Air Quality U.S. Environmental Protection Agency

Duty Hybrid Powertrain Systems and Heavy

- Duty Engine On

Eaton Corporation is a member of the Hybrid Manufac turers Regulatory Collaboration

The HMRC was formed to bring together companies inv olved in the heavy hybrid vehicle industry for purposes of addressing common issues associated with regulations affecting hybrid vehicles. HMRC’s othe r current members are Allison

., and BAE Systems Inc.

HMRC would like to express its sincere appreciation to you and your staff at EPA for addressing issues that have recently become apparen t regarding heavy

- duty hybrid powertrain systems and heavy -duty engine on-board diagnostic (OBD ) requirements. We strongly believe that your actions will make it pos sible to avoid a serious disruption of the

duty vehicle industry and adverse impacts on the ma rket for such vehicles. This in turn will ensure the viability of heavy -duty hybrid vehicles in playing an integral role in allowing compliance with the Greenhouse Gas Emissions Standards and Fuel Efficiency Standards for Medium - and Heavy- Duty Engines and Vehicles being

In addition, HMRC appreciates the fact that EPA has quickly shown a strong commitment to working with HRMC members and others to clearly define compatibility requirements, and expects that EPA will realistically assess the progress being made toward those goals in determining whether additiona l time is required to achieve them. HMRC

members believe that resolution of all of these iss ues by the 2016

- 2017 model provided for by EPA will be extremely challenging b ut will strive to achieve that goal.

HMRC understands the need for and sup ports the goal of ensuring that heavy powertrain systems are compatible with existing hea vy

- duty engine OBD requirements. Duty Engine On -Board

Eaton Corporation is a member of the Hybrid Manufac turers Regulatory Collaboration

The HMRC was formed to bring together companies inv olved in the heavy -duty hybrid vehicle industry for purposes of addressing common issues associated with regulations affecting hybrid vehicles. HMRC’s othe r current members are Allison

HMRC would like to express its sincere appreciation to you and your staff at EPA for duty hybrid ) requirements. We strongly believe that your actions will make it pos sible to avoid a serious disruption of the

duty vehicle industry and adverse impacts on the ma rket for such vehicles. hybrid vehicles in playing an integral role in allowing compliance with the Greenhouse Gas Emissions Standards and Fuel Duty Engines and Vehicles being

that EPA has quickly shown a strong commitment to working with HRMC members and others to clearly define compatibility requirements, and expects that EPA will realistically assess the progress being made toward those l time is required to achieve them. HMRC

2017 model -year as provided for by EPA will be extremely challenging b ut will strive to achieve that goal.

ports the goal of ensuring that heavy -duty hybrid

duty engine OBD requirements.Page 2 of 5 Cleophas Jackson, U.S. Environmental Pr otection Agency July 14, 2011

HMRC members currently produce hybrid powertrain sy stems that conform to all mechanical/electrical interface specifications and operational specifications provided by heavy-duty engine manufacturers; nevertheless, ther e are a number of issues associated with ensuring compatibility with heavy-duty engine OBD requirements. Resolution of these issues, which are described in the attachment to this letter, will require time and the cooperative efforts of hybrid powertrain system man ufacturers, engine manufacturers, heavy-duty vehicle OEMs, industry associations such as the Society of Automotive Engineers and the Engine Manufacturers Association, and, importantly, regulatory agencies. Further, HMRC believes that the failure of good faith efforts on the part of regulatory agencies or the affected industry to mee t key deadlines necessary for compliance must lead to reconsideration of the timi ng of the compliance goal.

In closing, HMRC would again like to express apprec iation for EPA’s timely and responsive action to address concerns regarding OBD and heavy-duty hybrid vehicles. As our cooperative efforts progress, HMRC members m ay provide further questions and/or request further direction as new realization s occur as a result of the knowledge gained along the path of development. Finally, rea lizing that there may be personnel and other changes within regulatory agencies and indust ry over the timeline of this work, we would request that this document and its attachment be included in the Federal Register docket for this proceeding for use as a future refe rence and to help provide continuity in the guidance provide by the regulatory agencies.

Best Regards,

Ian D. McKenzie Chief Engineer, On-Board DiagnosticsPage 3 of 5 Cleophas Jackson, U.S. Environmental Pr otection Agency July 14, 2011



## ATTACHMENT

HMRC believes that the points summarized below are highly pertinent to the issues that exist with heavy-duty hybrid powertrain systems and heavy-duty engine on-board diagnostic (OBD) requirements. HMRC also believes that these issues must be considered now and in the future when assessing hea vy-duty engine OBD requirements for engines used in combination with hybrid powertr ain systems.

1. The heavy-duty vehicle industry is non-verticall y integrated and a single vehicle OEM or body builder may source from multiple compon ent or system suppliers, who are different and independent and integrate an engine, transmission, and other devices, including hybrid powertrain systems. As vehicle purchasers dictate the “build” of a hybrid vehicle, market acceptance of hybrids requires that hybrid powertrain systems be compatible with a wide range of engines and other
components.

2. Because hybrid powertrain systems modify heavy-d uty engine duty cycles in order to achieve reductions in fuel consumption and green house gas emissions, there is confusion regarding how heavy-duty engine OBD requi rements are applied to hybrid powertrain systems.

3. Heavy-duty engine manufacturers are currently ch allenged by requirements to create OBD systems for their conventional products for the first time. Given this new and significant level of effort, they have not been able to provide the specifications that HMRC members require to ensure compatibility of hybrid powertrain systems with OBD compliant engines. In order to be successful in ensuring compatibility, HMRC members need not only the commitment of time and resources by engine manufacturers, but agreemen t from the engine manufactures that the OBD algorithms as well as the engine control software and hardware are mature and stable. It is also importa nt that some mechanism be created to address the concerns of hybrid powertrai n system manufacturers if there are future changes.

4. OBD-compliant heavy-duty engines have only recen tly begun to enter the market, generally on engines of larger displacement and pow er ratings than typically selected for use in hybrid vehicle applications. O BD-compliant engines of the types that are generally used in hybrid application s have not yet been introduced and HMRC members do not yet have familiarity integr ating hybrid powertrain systems with OBD-compliant versions of these engine s. Time is required for HMRC members to obtain OBD-compliant engines and ga in experience integrating hybrid powertrain systems with those en gines in order to ensure compatibility with engine OBD monitoring systems

5. Compliance with heavy-duty OBD requirements crea tes a new level of complexity in hybrid powertrain and engine integration. Prese ntly, hybrid powertrain integration is accomplished with proprietary commun ication interfaces that are different for each HMRC member. Time will be requi red to understand what changes will be needed to address the integration c hallenges that must be overcome in order to ensure OBD compliance. Once t hat understanding has been achieved, additional time will be required to develop generic industryPage 4 of 5 Cleophas Jackson, U.S. Environmental Pr otection Agency July 14, 2011

standard practices and apply those to the integrati on of hybrid powertrain systems to achieve OBD compliance.

6. Regulatory agencies have not yet published guida nce regarding the requirements that HRMC members will have to satisfy in order to demonstrate the compatibility of hybrid powertrain systems with OBD-compliant hea vy-duty engines. Establishment of these requirements is critical to achieving the common goal of OBD compliance for heavy-duty hybrid vehicles and m ust be completed quickly. HMRC believes that the requirements for demonstrati ng compatibility need to be available several years prior to the OBD compliance date in order to allow sufficient response time for all parties involved. Significant agency resources (i.e., technical, engineering, and program management) wil l have to be rapidly made available to develop this guidance so that the regu latory requirements for the certification of engines integrated with hybrid pow ertrain systems can be articulated and communicated to engine manufacturer s, HMRC members, and other interested parties. One example of where gui dance is needed in detailing

the exact criteria that have to be satisfied for th e agency to determine that a hybrid powertrain system is compatible with an OBD compliant engine. In this case, HMRC strongly supports criteria based on engi neering and technical analysis and strongly opposes criteria that are bas ed on engine and/or chassis dynamometer testing as the latter are overly expens ive and unnecessary. Another example where agency guidance in needed qui ckly is with respect to the requirements and criteria that will apply to all pa rties involved in the production of hybrid vehicles since significant business risk and various industry business functions (such as warranty requirements, service s upport for the end user, periodic field test reporting, intellectual propert y disclosure, to name a few) would likely be impacted. Again, the need for specific r equirements in these areas and the associated cost must be carefully considered by EPA. Finally, regulatory agencies and the affected industry need to create a n overall timeline identifying key deadlines by when “deliverables” such as agency guidance and industry standards must be finalized, so that sufficient inf ormation is exchanged at pivotal milestones. Without such a timeline, it is likely that there will be delays in achieving objectives in the critical path of achiev ing the goal of full OBD compliance in the 2016-2017 model-year timeframe. Failure of good faith efforts on the part of regulatory agencies or the affected industry to meet key deadlines

on the timeline must lead to reconsideration of the timing of the compliance goal.

7. Low sales volumes (roughly 11,000 heavy-duty hyb rid powertrain systems have been sold nationwide over the last 11 years) limit resources available to HMRC members for ensuring compatibility with OBD-complia nt heavy-duty engines and the ability to recover costs associated with demons trating compatibility. These resource limits directly affect business decisions regarding continued participation in the hybrid powertrain market and need to be care fully considered by regulatory agencies in establishing compliance dates and requi rements. Further, regulatory agencies must recognize that policies regarding emi ssion control system warranty and other requirements for hybrid powertrain system s can add additional costs that are difficult to recover. Again, the potentia l for recovery of any added costs is a key consideration in business decisions made by H MRC members.

8. Engine manufacturers whose primary products are engines for conventional vehicles face even greater resource limitations in dealing with hybrid-related OBD compatibility issues. Given this and low hybrid po wertrain system sales volumes,Page 5 of 5 Cleophas Jackson, U.S. Environmental Pr otection Agency July 14, 2011

engine manufacturers may just decide to prohibit t he use of their products with hybrid powertrain systems and that decision would i mmediately destroy the industry.

9. EPA must recognize that its demand for full OBD compliance in the 2016-2017 model-year timeframe for engines operated with hybr id powertrain systems, as opposed to a later compliance date, introduces a si gnificant cost-recovery obstacle for HMRC members who will have to engage i n accelerated engineering development programs and other activities that requ ire significant additional capital resources. As the hybrid industry, engine manufacturers, industry organizations, and regulatory agencies move forward in their efforts to achieve OBD compliance, the ability of companies to recover compliance costs has to be a key consideration if the hybrid industry is to su rvive.