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U.S. Department of Transportation **Research and Innovative Technology**  **Administration** Volpe National Transportation Systems Center Ju ly 25 , 2011 MEMORANDUM SUBJECT: Ex parte m eeting 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 rul e 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

 W hether “classi c” tractors could meet the vehicle standards using GEM that page 147 of the preamble shows the standard for traditional tractors  I f 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:
 T he 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 reduc e the2  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 ;  Th ere will be a net zero effect in fuel consumption and CO 2 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 o f 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 f reight.  OOIDA opposes the use of a uxiliary p ower u nits (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. OOID A 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.