UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

NATIONAL VEHICLE AND FUEL EMISSIONS LABORATORY

2565 PLYMOUTH ROAD

ANN ARBOR, MICHIGAN 48105-2498

 

MEMORANDUM

SUBJECT: Heavy-Duty Hybrid Onboard Diagnostics

FROM: Amy Kopin

TO: The Docket

DATE: July 19, 2011

On May 10th, 2011 we held a conference call with Odyne Systems, LLC to discuss 

concerns raised by hybrid manufacturers regarding heavy-duty onboard diagnostic (OBD) 

requirements and timing. Hybrid manufacturers, engine manufacturers, and industry trade groups

raised concerns during the comment period for the heavy-duty greenhouse gas notice of proposed 

rulemaking that heavy-duty hybrid applications may not be able to meet the 2013 heavy-duty

OBD regulations that were published in the 2009 OBD Final Rulemaking.

1,2

 Attendees from the 

EPA and Odyne are shown in the table below. The agenda for this meeting is shown on the 

following page of this memo.

Attendee Affiliation 

Cleophas Jackson EPA – Compliance and Innovative Strategies 

Division 

Anthony Neam EPA – Assessment and Standards Division 

Amy Kopin EPA – Assessment and Standards Division 

Joe Dalum Odyne - President and CEO

Dr. Phillip Eidler Odyne – VP Operations

Matt Jarmuz Odyne – Applications Engineer and Sales

 

1 U.S. EPA, NHTSA, and DOT, “Greenhouse Gas Emission Standards and Fuel Efficiency Standards for Mediumand Heavy-Duty Engines and Vehicles,” republished December 29, 2010. Available here: 

http://origin.www.gpo.gov/fdsys/pkg/FR-2010-12-29/html/2010-32726.htm

2 U.S. EPA, “Control of Air Pollution from New Motor Vehicles and New Motor Vehicles Engines; Final Rule 

Regulations Requiring Onboard Diagnostic Systems on 2010 and Later Heavy-Duty Engines Used in Highway 

Applications Over 14,000 Pounds; Revisions to Onboard Diagnostic Requirements for Diesel Highway Heavy-Duty 

Vehicles Under 14,000 Pounds,” published February 24, 2009. Available here: 

http://www.epa.gov/otaq/regs/im/obd/regtech/hd-obd-frm-02-24-09-notice-74-fr-8310.pdf

OFFICE OF

AIR AND RADIATION
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

NATIONAL VEHICLE AND FUEL EMISSIONS LABORATORY

2565 PLYMOUTH ROAD

ANN ARBOR, MICHIGAN 48105-2498

 

EPA-Odyne Heavy-Duty Hybrid OBD Discussion

3pm-4pm EST May 10, 2011

Agenda

EPA’s Questions for Odyene:

1. How does Odyne handle warranty issues today?

2. Does Odyne buy engines or vehicles – What’s Odyne’s role in vehicle assembly

process today?

3. Based on Odyne’s comments, EPA understands that they do not believe they should be 

responsible for vehicle/engine warranty. Does Odynes position in the vehicle creation 

process support this?

As noted in Odyne’s comments, in 2013 OBD is required on heavy duty vehicles. Hybrid 

systems will be considered part of the engine system and be required to comply with the 

comprehensive component portion of the EPA’s OBD regulation assuming they interact 

with the engine. Through the road hybrid system (where there is no interaction with the 

engine system) will not be required to have OBD.

4. How does your hybrid system interact with the engine?

A. Does it shut off the engine?

B. Can it add torque to the crank shaft?

C. Does it supply a load to the engine?

D. Does it have communication with the engine system?

5. Does Odyne believe their hybrid system will be required to have OBD?

6. If so, what has Odyne done to prepare for 2013?

Odyne’s Questions for the EPA:

1. Why would Odyne’s system need OBD based on the operation/interaction with the 

vehicle and engine today?

2. Are there different regulations (OBD, GHG) for PTO based operation different than 

hybrid operation?

OFFICE OF

AIR AND RADIATION
Attachment:

Comprehensive Component Regulations – can be found starting on page 8391 of the final 

heavy-duty OBD rulemaking. Note they are also discussed in other parts of the final rule, 

but this is the main text on ‘comprehensive components’ – the entire rule can be accessed 

here:

http://www.epa.gov/otaq/regs/im/obd/regtech/hd-obd-frm-02-24-09-notice-74-fr8310.pdf

(double click on file to open .pdf file that contains the regs)