1

U.S. Department 

of Transportation

Research and

Innovative Technology

Administration

Volpe National Transportation Systems Center

July 25, 2011

MEMORANDUM

SUBJECT: Ex parte meeting with 

FROM: Maurice Hicks, NHTSA

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

Independent Drivers Association (OOIDA) 

greenhouse gas standards for medium

OOIDA requested a meeting with NHTSA to discuss the effects of the proposed heavy

efficiency rule on independent owner operators. The

OOIDA: Mike Joyce, Joe Rackavacks, John Spencer

EPA: Byron Bunker, Cheryl Bynum, and Angela Cullen 

NHTSA/DOT: James Tamm, Rebecca Yoon, Gregory Powell, Lixin Zhao, Angel Jackson, and Maurice Hicks

Ryan Harrington

The following topics were discussed during the meeting:

OOIDA asked the following questions with regard to implementation of the heavy

 Whether “classic” tractors could meet the vehicle standards using GEM

that page 147 of the preamble shows the standard for traditional tractors

 If NHTSA planned on having an in

regulation applies at the first commercial sale.

OOIDA raised a number of potential impacts on industry from the rule, including: 

 The agencies’ efforts to improve fuel efficiency through weight reduction 

crashworthiness of heavy duty tractors; 

Volpe National Transportation Systems Center

eeting with Owner-Operator Independent Drivers Association (OOIDA)

, NHTSA

-2010-0079

This memorandum documents a meeting held on November 1, 2010 between the Owner

Independent Drivers Association (OOIDA) EPA, and DOT regarding the proposed fuel efficiency and 

greenhouse gas standards for medium- and heavy-duty vehicles and engines for model years 2014

OOIDA requested a meeting with NHTSA to discuss the effects of the proposed heavy-duty truck fuel 

e on independent owner operators. The attendees included:

OOIDA: Mike Joyce, Joe Rackavacks, John Spencer

Byron Bunker, Cheryl Bynum, and Angela Cullen 

James Tamm, Rebecca Yoon, Gregory Powell, Lixin Zhao, Angel Jackson, and Maurice Hicks

The following topics were discussed during the meeting:

questions with regard to implementation of the heavy-duty program

tractors could meet the vehicle standards using GEM? NHTSA staff noted 

that page 147 of the preamble shows the standard for traditional tractors; 

f NHTSA planned on having an in-use requirement? NHTSA staff responded that the NHTSA 

regulation applies at the first commercial sale.

OOIDA raised a number of potential impacts on industry from the rule, including: 

efforts to improve fuel efficiency through weight reduction could 

of heavy duty tractors; 

55 Broadway

Cambridge, MA 02142

Operator Independent Drivers Association (OOIDA)

the Owner-Operator 

regarding the proposed fuel efficiency and 

duty vehicles and engines for model years 2014-2018. 

duty truck fuel 

James Tamm, Rebecca Yoon, Gregory Powell, Lixin Zhao, Angel Jackson, and Maurice Hicks, 

duty program:

NHTSA staff noted 

NHTSA staff responded that the NHTSA 

could reduce the 
2

 The regulation is anticipated to increase the average tractor cost which will impact owner 

operators;

 Second stage manufacturers will be limited in making specific task changes to the OEM’s original 

tractor design in order to maintain the specified fuel consumption performance of the vehicle;

 There will be a net zero effect in fuel consumption and CO2 performance from weight reduction 

approaches due to the additional weight from aerodynamic features such as fairings needed for 

compliance with the standards.

OOIDA expressed opposition to aspects of the proposed rule and in some cases provided alternative 

approaches:

 OOIDA opposes the use of speed limiters for heavy-duty tractors. The argued that the 

use of speed limiters could increase the need for additional trucks to deliver the same 

amount of freight.

 OOIDA opposes the use of auxiliary power units (APU’s) in tractors operating in cold 

conditions, stating that APU’s are not effective in extremely cold temperatures and 

operators will have to keep the vehicle running in order to remain warn. OOIDA staff 

provided information on the uses of improved cabin insulators as an alternative. 

 OOIDA asked that weight reduction through tires should not be considered since 

manufacturers need to maintain the current performance of tractor tires. They did not

provide data during the meeting to show that low rolling resistance tires have poor 

performance.

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