### Docket 10 No. EPA-HQ-OAR-2014-0827 Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and H eavy-Duty Engines and Vehicles- Phase 2

Comments submitted by: Odyne Systems, LLC W237 N2878 Woodgate Road Suite 2 Pewaukee, WI 53072 U.S

. 262-544-8405 www .odyne .com 

### Bill Mammen Director of Systems & 

### Controls ENVIRONMENTAL PROTECTlON AGENCY 40 CFR Parts 9, 22, 85, 86,600, 1033, 1036, 1037, 1039, 1042, 1043, 1065, 1066, and 1068 DEPARTMENT OF TRANSPORTATION National Hi ghway Traffic Safety Admin istration 49 CFR Parts 512, 523, 534, 535, 537, and 538

Introduction: Odyne Systems, LLC develops and manufacturers hybrid drive systems for medium and heavy-duty vehicles. Odyne's advanced plu g-in hybrid technology enables trucks over 14,000 pounds to have substantially lower emiss ion s, imp roved performan ce, quieter job site operation, lower fuel consu mption, and reduced operating and maintenance costs. Founded in 2009, Odyne has continued to adva nce the state of hybrid technology. The company prov ides plug-in hybrid systems to lead in g fl eets ac ro ss the country and was th e on l y company se lected by EPRI (the E lectric Power Res ea rch In stitute) and the U.S

. Departm ent of Energy to develop and supply advanced plug-in hybrids and Smart Grid 

### 1 Smart Charging technology for trucks over 14,000 pounds in a large nationwide program. Through the program, Odyne demonstrated its hybrid technology significantly reduces fu el consumption, GHG emissions and criteria emissions for typical vocational work truck applications involvin g a comb ination of driving and statio nary operations at the jobsite (full work day). Odyne works closely with leading truck chassis, engi ne, and transm ission manufacturers to integrate its hybrid system with the powertrain at the intermediate stage of chassis manufacturin g. Our PHEV tec hnology has been deployed across the country, including right here in Chicago (COM ED) in various vocational truck app li cations, demonstrating real world fuel and emiss ions sav ings tod ay. Odyne applauds the efforts of the EPA and NHTSA to work with industry in ensuring the most fuel efficient technologies are developed and deployed to increase fuel efficiency and Page 11Docket ID No. EPA-HQ-OAR-20 1 4-0827 Greenhouse Gas Emi ssions and Fue l Efficiency Standards for Medium- a nd Heavy-Duty Engines and Vehicles- Phase 2

r educe GHG em iss ions in the medium and h eavy-duty truck sector. Thank you for the opportunity to spea k before yo u here today on Proposed Phase Two rules.

Comments : While scenario three, which r es u lts in fu ll compliance by 2027 fo r a ll truck classes would represent a positive gu id epost for the indu stry, Odyne believes that the cost effective technologies exist to meet timelines and techno logy adoption scenarios laid out in sce na rios fou r and five, incl udi ng fleet ado ption r ates of p lug-in hybri d tech nology- a technology Odyne Systems has developed and deployed in partnership with t h e DOE and private fleets- above and beyond the assume d 10 % market penetration rate by 2027 and at efficiency improvements (16% specifically for vocational) far beyond the current proj ections for vario u s app li cations of vocational vehicles.
In rea l world applications vocational vehicles deployed with Odyne hybrid technology, we have seen fuel efficie ncy improvements of 46% in driving a lone, an d 64% in fuel savings when accounting for the average fu ll work day; including driving, idling, and hybrid power take off (PTO) activities. Based o n testing paid for by the U. S. Department of Energy and the s ta te of California, Odyne technology cu rrently d e li vers 64% lower C02 and 95% lower NOx emissio n s (based on full work day) than non-hybrid medium and heavy duty trucks meeting current standa rd s. Odyn e be li eves that imp rove m ents in drivetra in, hybrid contro l sys tem optimizatio n- both from technology adva n cements and increased data in corporation of workday ass umption s, and duty-cycle optimizati on- a long with contin ually decreasing costs for components (as EPA has very accurate ly estim ated going forward) and continuing vo latility in fossil fuel prices will drive the value proposition fo r hyb rid deployment in th e coming years. Odyne believes hybrid s will p lay a larger role in fleet procurement in the next decade at efficiency rates h igher than is currently modeled in Scenario 3's assumptions. At a minimum, we would recommend the EPA increase full comp liance fuel efficiency increases for the vocational sector beyond the 16% to 20% or hi gher, a nd Odyne wo uld welcome workin g with the EP A on estab li shing specif ic assumption s and targets based on its d ata from th e trucks on the road today and with technologies currently u nder development. The California Air Resources Board (CARB) has put a s trong focus on hybrid techn ology in its effo rts to achi eve its zero emission goa ls, as improvements in e lectrification techno logies are necessary to go ing beyond incremental fuel efficiency increases. Odyne would also r ecommend any methods to streamline Phase Two r egu lation s with CARB Innovative Technology R egu lation (ITR) efforts to ease regulatory burden on Innovative Technology in t hi s space, and set common goa ls for the heavy duty industry to meet.

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## I 2Docket 1D No. EPA-HQ-OAR-2014-0827 Greenhouse Gas Emissions and Fue l Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles- Phas e 2 Odyne understands the difficulty in modeling fuel efficiency improvements for hybrid technology within the GEM, as hybrid systems interact with the transmission, drivetrain, and engine. In addition to auxiliary activities beyond driving not currently modeled in the GEM. But Odyne strongl y believes that it is important to model the full day vocational vehicle duty cycle, including driving, idling, and stationary operation of truck mounted equipment through a Power Take-off (PTO). Modeling the en tire duty cycle would be consistent with efforts by CARS to understa nd the tota l emiss ions produced by the vehicle throughout the entire day. By not basing the proposed standards for vocational vehicles on the use of hybrid PTO mode, the EPA could miss out on a significant opportunity to increase full work day fuel efficiency for vocational vehicles. The segment of the vocational chassis market using Power Take-offs (PTOs) is s ignificant. Ody ne estimates that there are approximately 100,000 Power Take- of f s sold ann ually for medium and h eavy duty trucks, and over 1 million on the road. In addition, the accounting for the efficiency improvements from hybrid technology is not as clear as it cou ld be in the proposed GEM model. Odyne would welco m e the oppo rtuni ty to work with the EPA on best practices and potential pathways for mode li ng fuel efficiency increases from various applications of hybrid PTO mode, in addition to hybrid propulsion.
Should the EPA in its final rule decide not to base its standards for vocational trucks on the use of hybrid or e-PTO, Odyne strongly encourages the EPA to develop and establish clear and bounding conditions for technologies to become eligib le for "off-cycle" cre dits. In Phas e 1, the process was unclear for technologies to b ecome eligible for these credits which we believe was a major hindrance for indu stry to drive these types of innovations. Odyne and other aligned stakeholders like the EDTA and CaiStart would also welcome the opportunity to work with the EPA on developing these cond itions and cle a r timelines for earning "off-cycle" credits for the dep loy ment of hybrid PTO technologies. 

### **** Testing truck emiss ions requ ires a concise understanding of the full work day for all classes of trucks and vocation. For vocational vehicles, with thei r myriad of app li cations, th is can be a difficult task. However, Odyne has been tracking full day duty cycles for Utility work trucks covering Aerial 

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## I Underground applications for the past 5 years, a longside leading organizations including EPRl, DO E, CEC, and SCAQMD. Odyne appreciates the EPA's focus on the importance of accurate mode li ng here. We have also done testing at facilities like SWRI and CE-CERT to verify fuel economy a nd emission benefits. The EPA has done well in identifying the importan ce of the fu ll work day (real world u sage) a nd separating it into driv in g (traffic) and stationary (parked). Our system impacts both categories and needs to be acco unted for appropriately s ince we are not just an idle reduction technology. Ou r understanding is that the EPA has chosen the HOT drive cycle for the transient portion of testing, and CARS has chose n the UDDS drive cycle, both Page 

## 13Docket ID No. EPA-HQ-OAR-2014-0827 Gree nho use Gas Em issions and Fue l Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles- Phase 2 drive cycle r ep r esent how our customers drive th eir vehicles. Odyne would highly suggest h aving a common drive cycle used by CARS a n d EPA (preferably the HO T cycle) to be used across all testing and it is impo rtant to evaluate this over a realistic period of time or distance instead ofjust the single dri ve cycle. Ody n e has found that our customers drive a n average of 25 mil es a day (1.5 hrs). Besides th e benefits that hybrids provide to t he drivi ng portion (MP G improvements) it a lso has an impact on the id le time which can be very significant. So the idle time is currently broken into two categories: traffic and parked. Odyne believes that the parked id le should also be broken down to normal and work Qobsite) idle. The reaso n is that n ormal id le occurs around 7SORPM and work idle can range from 800 to 2000RPM which has a greater imp act on fuel consumption and emissions. I t is also important to account for t h e amount and type of work being done since that relates to work being done on the I C engine or replaced by the hybrid system. We have found that the typical duty cycle of the total ti m e in work mode ( PTO mode, wo rk load) relative to the actua l t im e running the applicatio n is around 20%. Based on our customers work day we see and average of 1.6 hours just parked (nonPTO) and an additional 2.8 hours parked in t h e work mode (PTO, ePTO). Th e curren t test procedure is a charge sustaini ng proced ure. That procedure cou ld be s u fficient f or a HEV application but not for a PHEV app lication. In Odyne's PHEV application we do not charge t h e system all the way back to fu ll in the fie ld and handle charging primarily w ith p lug-in charging from the power grid. So Odyne would r eco mmend t hat th e test proced ures u sed in a final rul e accou n t for scena r ios with a charge depleting battery syste m , to be rec harged from the grid in off hours, resu lts in real world overall fue l efficiency increases. 

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Critical to achieving t h e highest level of fuel efficiency increases in medium a nd heavy-duty trucks, is the abil ity to develop regu lations that encourage the deployment of both incremental efficiency improvement techno logy and more advanced technologies. While Odyne Systems a nd others in th e stakeholder community understand the rationale for the EPA to assume that t h ese advanced techno logies w ill be dep loyed within standard compliance without additional credits, we believe that includ ing adva nc ed technology credits in the Phase 2 final rules will be critical for the development and near term deployment of these sorts of technologies t hat may not be considered by techn ology d eve lopers and ma nufacturers without these cred its- eve n if th ey are deployed in s ma ll volumes. The current efficiency improvement assumptions of 16% across the nine categories of vocational vehicles proposed in scenario three would not likely drive increme ntal deployment of adva nced technologies, like advanced hybrid systems based on efficiency increases from weight reduction, LRR tires, engine improvements, start/stop and id le improvement techno logies. More stringent sta nd ards-- like those proposed in scena rio s four a nd five-- would need to be instituted for advanced technology like Odyne's Page 

## 14Docket ID No. EPA-HQ-OAR-2014-0827 Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and Heavy

- Duty Engines and Vehicles- Phase 2

to b e deployed through standard compliance. But even at that point, we believe OEMs should be given an inc e ntive to drive accelerated adoption of more advanced technologies to drive further private sector R&D in these tech no logies, provide realistic pathways for proving and commercializing these technologies, and lowering the their costs-- all resulting in accelerated fleet wide increases in fuel efficiency.
The CARS ITR was deve loped to achieve a similar purpose, with the assumption that given the h igh ly regulated nature of the heavy duty industry, new tech no logies need incentiveeven in small volumes - to be tested and proven, and advanced credits can serve as the catalysts to drive the development of these technologies, while also enabling the potential for earlier widespread adoption of technologies that cou ld move the industry even beyond the emission requ irements set out in this rulemaking. As noted above, any methods to streamline EPA and NHTSA ru lemaking with CARS regu latory efforts wou ld be extremely helpfu l to the industry.



### ** * ** Odyne Systems also applauds the EPA in its understanding that regulatory burden on small and innovative manufacturers can be detrimental to the dep loyment of advanced technologies, like hybrid systems. In its proposal for developing a "delegated assembly" procedure for certified manufacturers to de legate some parts of assembly to secondary manufacturers, it may be helpful to include technologies like hybrid systems that connect with the powertrain- as they are often installed by secondary manufactures to the chassis or engine manufacturer

- as a explicitl y specified technology in addition to air cond itioning systems, etc. This can he lp compan ies like Odyne provide advanced efficiency technologies to OEMsjcertified manufacturers to dramatically increase the efficiency rating of their vehicles, without placing undue regu latory burden on smaller manufacturers to be in the busin ess of se lli ng credits.



### ***** Overall, Odyne would again like to thank the EPA and NHTSA for its efforts in developing these proposed regulations in Phase 2. We look forward to working with the EPA and NHTSA teams go ing forward as t h e r ul es become fina l over the next year.

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- OAR-2014-0827 Greenhouse Gas Emissions and Fuel Efficiency Standards for M ediu m - and Heavy-Duty Engines and Vehicles- Ph ase 2



### Additional item s to be address in final comments:

• Use of certifi ed non- r oad engines to be used in the identified types of heavy-duty highway ve hicl es • Use of engines from chass is ce rtifi ed vehicles in certain heavy-duty ve h icle • Use of Mild hybrids an d other mea n s to el imin ate fue l co n su mpti o n w hen ve hicl e is stopped (in traffic, not parked) and rege nerative b raki ng capabilities • De te riora tion Factors f or hybrid s • Mainten a n ce costs for hybrids • Useful Life for hybrids

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