Crosspoint Kinetics, LLC 

5511 West 791

h St 

Indianapolis, 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 

spurring 

Thank you for your diligent work in proposing these unified Phase 2 GHG reductions and committing to 

on the development of advanced technology to meet these requirements. This long term plan 

stabilizes these crucial requirements and provides some much needed long-term regulatory 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 level into the 

foreseeable future and yet offers a phased in approach to compliance. Specifically, the subcategories for vocational vehicles and multiple 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 your 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 obtained without 

the sub-optimization of components' performance such as engines, transmissions and structures. 

This approach to standards drives a more integrated approach to reducing GHG 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 

manufacturers 

regard to the ABT program, it appears that the credits for applying advanced technology for the 

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 value that could flow back to the OEM. Without a return for the tedious 

manufacturers 

work of bringing a new innovative product or technology to market, vehicle developers and 

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 

encourage 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 measurements 

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 actively 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 rule structure. 

Sincerely, 

John McNichols 

Product Director 

Crosspoint Kinetics