Docket 10 No. EPA-HQ-OAR-2014-0827 

Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and Heavy-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 Highway Traffic Safety Administration 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 plug-in hybrid technology enables trucks over 

14,000 pounds to have substantially lower emissions, improved performance, quieter job 

site operation, lower fuel consumption, and reduced operating and maintenance costs. 

Founded in 2009, Odyne has continued to advance the state of hybrid technology. The 

company provides plug-in hybrid systems to leading fl eets across the country and was the 

only company selected by EPRI (the Electric Power Research Institute) and the U.S. 

Department 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 involving a combination of driving and stationary operations at the jobsite 

(full work day). Odyne works closely with leading truck chassis, engine, and transmission 

manufacturers to integrate its hybrid system with the powertrain at the intermediate stage 

of chassis manufacturing. 

Our PHEV technology has been deployed across the country, including right here in Chicago 

(COM ED) in various vocational truck applications, demonstrating real world fuel and 

emissions savings today. 

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 

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Docket ID No. EPA-HQ-OAR-2014-0827 

Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- a nd Heavy-Duty 

Engines and Vehicles- Phase 2 

reduce GHG emissions in the medium and heavy-duty truck sector. Thank you for the 

opportunity to speak before you here today on Proposed Phase Two rules. 

Comments: 

While scenario three, which results in full compliance by 2027 for all truck classes would 

represent a positive guidepost for the industry, Odyne believes that the cost effective 

technologies exist to meet timelines and technology adoption scenarios laid out in 

scenarios fou r and five, including fleet adoption rates of plug-in hybrid technology- a 

technology Odyne Systems has developed and deployed in partnership with the DOE and 

private fleets- above and beyond the assumed 10% market penetration rate by 2027 and 

at efficiency improvements (16% specifically for vocational) far beyond the current 

projections for various appli cations of vocational vehicles. 

In real world applications vocational vehicles deployed with Odyne hybrid technology, we 

have seen fuel efficiency improvements of 46% in driving alone, and 64% in fuel savings 

when accounting for the average full work day; including driving, idling, and hybrid power 

take off (PTO) activities. Based on testing paid for by the U.S. Department of Energy and 

the state of California, Odyne technology currently delivers 64% lower C02 and 95% lower 

NOx emissions (based on full work day) than non-hybrid medium and heavy duty trucks 

meeting current standards. 

Odyne beli eves that improvements in drivetrain, hybrid control system optimization- both 

from technology advancements and increased data incorporation of workday assumptions, 

and duty-cycle optimization- along with continually decreasing costs for components (as 

EPA has very accurately estimated going forward) and continuing volatility in fossil fuel 

prices will drive the value proposition for hybrid deployment in the coming years. Odyne 

believes hybrids will play a larger role in fleet procurement in the next decade at efficiency 

rates higher than is currently modeled in Scenario 3's assumptions. At a minimum, we 

would recommend the EPA increase full compliance fuel efficiency increases for the 

vocational sector beyond the 16% to 20% or higher, and Odyne would welcome working 

with the EPA on establishing specific assumptions and targets based on its data from the 

trucks on the road today and with technologies currently under development. 

The California Air Resources Board (CARB) has put a strong focus on hybrid technology in 

its efforts to achieve its zero emission goals, as improvements in electrification 

technologies are necessary to going beyond incremental fuel efficiency increases. Odyne 

would also recommend any methods to streamline Phase Two regulations with CARB 

Innovative Technology Regulation (ITR) efforts to ease regulatory burden on Innovative 

Technology in this space, and set common goals for the heavy duty industry to meet. 

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Docket 1D No. EPA-HQ-OAR-2014-0827 

Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty 

Engines and Vehicles- Phase 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 strongly 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 entire duty cycle would be 

consistent with efforts by CARS to understand the total emissions 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 significant. Odyne estimates that there are approximately 

100,000 Power Take-offs sold annually for medium and heavy 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 could be in the proposed GEM model. Odyne would 

welcome the opportunity to work with the EPA on best practices and potential pathways 

for modeling 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 eligible for "off-cycle" credits. In 

Phase 1, the process was unclear for technologies to become eligible for these credits which 

we believe was a major hindrance for industry 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 conditions and clea r timelines for 

earning "off-cycle" credits for the deployment of hybrid PTO technologies. 

**** 

Testing truck emissions requires a concise understanding of the full work day for all classes 

of trucks and vocation. For vocational vehicles, with their myriad of appli cations, this can 

be a difficult task. However, Odyne has been tracking full day duty cycles for Utility work 

trucks covering Aerial I Compressor I Digger I Underground applications for the past 5 

years, alongside leading organizations including EPRl, DOE, CEC, and SCAQMD. Odyne 

appreciates the EPA's focus on the importance of accurate modeling 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 importance of the full work day (real 

world usage) and separating it into driving (traffic) and stationary (parked). Our system 

impacts both categories and needs to be accounted for appropriately since we are not just 

an idle reduction technology. Our understanding is that the EPA has chosen the HOT drive 

cycle for the transient portion of testing, and CARS has chosen the UDDS drive cycle, both 

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Docket ID No. EPA-HQ-OAR-2014-0827 

Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty 

Engines and Vehicles- Phase 2 

drive cycle represent how our customers drive their vehicles. Odyne would highly suggest 

having a common drive cycle used by CARS and EPA (preferably the HOT cycle) to be used 

across all testing and it is important to evaluate this over a realistic period of time or 

distance instead of just the single drive cycle. 

Odyne has found that our customers drive an average of 25 miles a day (1.5 hrs). Besides 

the benefits that hybrids provide to the driving portion (MPG improvements) it also has an 

impact on the idle time which can be very significant. So the idle time is currently broken 

into two categories: traffic and parked. Odyne believes that the parked idle should also be 

broken down to normal and work Qobsite) idle. The reason is that normal idle occurs 

around 7SORPM and work idle can range from 800 to 2000RPM which has a greater impact 

on fuel consumption and emissions. It is also important to account for the amount and type 

of work being done since that relates to work being done on the IC engine or replaced by 

the hybrid system. We have found that the typical duty cycle of the total time in work 

mode (PTO mode, work load) relative to the actual time running the application 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 the work mode (PTO, ePTO). 

The current test procedure is a charge sustaining procedure. That procedure could be 

sufficient for a HEV application but not for a PHEV application. In Odyne's PHEV 

application we do not charge the system all the way back to fu ll in the field and handle 

charging primarily with plug-in charging from the power grid. So Odyne would 

recommend that the test procedures used in a final rul e account for scenarios with a charge 

depleting battery system, to be recharged from the grid in off hours, results in real world 

overall fuel efficiency increases. 

  

Critical to achieving the highest level of fuel efficiency increases in medium and heavy-duty 

trucks, is the ability to develop regulations that encourage the deployment of both 

incremental efficiency improvement technology and more advanced technologies. While 

Odyne Systems and others in the stakeholder community understand the rationale for the 

EPA to assume that these advanced technologies will be deployed within standard 

compliance without additional credits, we believe that including advanced technology 

credits in the Phase 2 final rules will be critical for the development and near term 

deployment of these sorts of technologies that may not be considered by technology 

developers and manufacturers without these credits- even if they are deployed in small 

volumes. The current efficiency improvement assumptions of 16% across the nine 

categories of vocational vehicles proposed in scenario three would not likely drive 

incremental deployment of advanced technologies, like advanced hybrid systems based on 

efficiency increases from weight reduction, LRR tires, engine improvements, start/stop and 

idle improvement technologies. More stringent standards-- like those proposed in 

scenarios four and five-- would need to be instituted for advanced technology like Odyne's 

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Docket 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 be deployed through standard compliance. But even at that point, we believe OEMs 

should be given an incentive to drive accelerated adoption of more advanced technologies 

to drive further private sector R&D in these technologies, 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 developed to achieve a similar purpose, with the assumption that given 

the highly regulated nature of the heavy duty industry, new technologies 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 could move the industry even beyond 

the emission requirements set out in this rulemaking. As noted above, any methods to 

streamline EPA and NHTSA rulemaking with CARS regulatory efforts would be extremely 

helpful 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 deployment of advanced 

technologies, like hybrid systems. In its proposal for developing a "delegated assembly" 

procedure for certified manufacturers to delegate 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 explicitly specified technology in addition to air conditioning 

systems, etc. This can help companies like Odyne provide advanced efficiency technologies 

to OEMsjcertified manufacturers to dramatically increase the efficiency rating of their 

vehicles, without placing undue regulatory burden on smaller manufacturers to be in the 

business of selling 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 going forward as the rules become fina l over the next year. 

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Docket lD No. EPA- HQ- OAR-2014-0827 

Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty 

Engines and Vehicles- Phase 2 

Additional items to be address in final comments: 

• Use of certified non-road engines to be used in the identified types of heavy-duty 

highway vehicles 

• Use of engines from chassis certifi ed vehicles in certain heavy-duty vehicle 

• Use of Mild hybrids and other means to eliminate fuel consumption when vehicle is 

stopped (in traffic, not parked) and regenerative braking capabilities 

• De te rioration Factors for hybrids 

• Maintenance costs for hybrids 

• Useful Life for hybrids 

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