Cross point Kineti cs , LLC 55 1 1 West 79 1h S t Ind ianapolis, IN 46268 Docket 10 No. EPA-HQ-OAR-2014-0827 Docket 

### 10 No
. NHTSA- 2014-0132 Ladies and Gentlemen of the EPA and NHTSA, 

# Crosspoint Kinetics Aug 6, 2015
Thank you for your diligent work in proposing these unified Phase 2 GHG reductions and committing to spurring on the development of advanced technology to meet these requirements

. This long term plan stabilizes these crucial requirements and provides some much needed long-te rm regu latory certainty. As a developer and manufacturer of products for Medium and Heavy Duty commercial vehicles , it is noteworthy that it provides aggressive targets of improved performance at the vehicle leve l into the foreseeable future and yet offers a phased in approach to compliance. Specifically, the subcategories for vocational vehicles and mu ltiple route applications makes regulations more clear and progress more easily identified

. You have asked for specific comments on the proposed test duty cycles and their adequacy. We are reviewing you r proposed cycles against our deployed vehicle data and will in our written comments provide you with our thoughts , specifically on speed and idling assumptions . 

### I applaud you for taking a high level systems approach to measuring emissions and fuel economy. By considering the total vehicle design and application, the maximum impact can be obta ined without the sub-optimization of components' performance such as engines , transmissions and structures

. This approach to standards drives a more integrated approach to reducing G HG and fuel usage, and encourages the use of multiple incremental technologies that result in greater overall improvements than individual systems can provide. However, regarding the vocational vehicles target improvements, the proposed requirement of 16% improvement may fall short of bringing about the necessary technologies to significantly impact this sector. With roughly 30% of the GHG pollutants coming from the Vocational Vehicle and Medium and Heavy-duty truck sector, a greater percentage should be considered to drive innovation even higher

. With regard to the ABT program , it appears that the credits for applying advanced technology for the manufacturers has disappeared. The way the current proposal seems to be written still stops with the chassis OEM , and does not allow for roll up of credits for applying energy saving technologies by delegated final stage manufacturers such as vocational vehicle manufacturers

. We encourage you to take a broader view of how final stage or delegated assembly manufacturers might add additional carbon reduction va lue that cou ld flow back to the OEM

. W ithout a return for the tedious work of bringing a new innovative product or technology to market, vehicle developers and manufacturers are not incentivized to take such risks. The cost of bringing a game changing technology or product to market faces many obstacles in breaking out of the status quo and the established market inertia. The lack of adequate incentives and credits for taking this path makes it less desirable , potentially keeping new technologies from impacting our environment due to lack of sufficient inducements or flexibility in accounting for generating credits. We are concerned that the stringency levels alone may not drive advanced technology, but there are also no credits to encou rage them. Perhaps you will reconsider adding back in the credits for implementing advanced technology and find an equitable means of delegated final assembly OEMs to receive or roll up credits. Your challenge will be to objectively consider new and innovative technologies and methods of applying these advanced approaches that do not fit the status quo. Modifications to meas ure ments and certification methods may be required and flexibility to adapt these processes to accommodate promising and impactful technologies will be crucial. Some of these challenges include organizational empowerment, policy overhaul , working level encouragement and grace for risk taking, and flexible compliance throughout your organizations .We sincerely appreciate the overall body of work that has been poured into this unified proposal. We appreciate that you are active ly seeking stakeholder input and comment. We hope that the end result of this ground breaking policy will have impact for generations to come. Thank you for taking the time to hear our comments. We desire to stay connected and work with you as you shape the final ru le structure. Sincerely, John McNichols Pr oduct Director Crosspoint Kinetics