**UNITED STATES ENVIRONMENTAL PROTECTION AGENCY** NATIONAL VEHICLE AND FUEL EMISSIONS LABORATORY

2565 PLYMOUTH ROAD ANN ARBOR, MICHIGAN 48105 - 2498

**ME MORA**  **NDUM** SUBJECT: Heavy- Duty Hy brid Onboard Diagnostics FROM: Am y Kopin TO: The Docket DATE: July

19, 2011 On May 1 0 th, 2011 we held a conference call with Ody ne Sy stems, L LC to discuss concerns raised by hy

brid manufacturers re garding heavy- duty onboard diagnostic (OBD) requirements and timing. H yb rid 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 hy brid 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 Ody

ne are shown in the table below. The agenda for this meeting is shown on the follo wing 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 - Presiden t 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 Medium and 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 

### A **genda EPA’s Questions for Odyene:**  1. How does Ody

ne handle warranty issues today ? 2. Does Ody

ne buy engines or vehicles

– What’s Ody ne’s role in vehicle assembly process today ? 3. Based on Ody

ne’s comments, EPA understands that they do not believe they

should be responsible for vehicle/engine warranty . Does Ody nes positio n in the vehicle creation process support this? As noted in Ody

ne’s comments, in 2013 OBD is required on heavy duty vehicles. Hy

brid sy stems will be considered part of the engine sy stem and be required to comply with the comprehensive component portion o f the EPA’s OBD regulation assuming they interact with the engine. Through the road hy brid sy stem (where there is no interaction with the engine sy stem) will not be required to have OBD. 4. How does your hy

brid sy stem interact with the engine? A. Does it sh ut 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 Ody

ne believe their hy

brid sy stem will be required to have OBD? 6. If so, what has Ody

ne done to prepare for 2013? **Odyne’s Questions for the EPA:** 1. Why would Ody

ne’s sy stem 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 hy brid operation? OF FICE 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 entir e rule can be accessed here: http://www.epa.gov/otaq/regs/im/obd/regtech/hd - obd - frm - 02 - 24 - 09 - notice - 74 - fr 8310.pdf (double click on file to open .pdf fil e that contains the regs)