Good afternoon . I am Debbie Gordon, Executive Director of Regulatory Issues and Hybrid Programs for Allison Transmission. Allison Transmission is the world’s largest manufacturer of fully automatic transmissions for medium

- and heavy

- duty commercial vehicles and is a leader in hybrid

- propulsion systems for city buses. Allison transmissions are used in a variety of applicatio ns including refuse, construction, fire, pick

- up and delivery, distribution, bus, motorhomes, defense and energy. Our global headquarters are in Indianapolis, Indiana and I am proud to say that we are celebrating our centennial year.

Over the last six ye ars, Allison has engaged with EPA and NHTSA regarding the two agencies’ efforts to address the greenhouse gas emissions and fuel efficiency of medium and heavy

- duty vehicles. During this time, we have always been afforded the opportunity to directly engage with EPA and NHTSA technical staff and management.

In addition, Allison has supported efforts by EPA and NHTSA to test transmissions and

increase the base of knowl edge that both agencies have with regard to the effect of transmission systems on greenhouse gas emissions and fuel efficiency. O ur overriding concern has been that any regulations that affect transmissions and our customers accurately reflect the capabil ities of fully automatic transmission systems and hybrid systems. We have also emphasized the importance of assessing the relative performance of vehicles and transmission systems with respect to the real world operating conditions of commercial vehicles.

It is a considerable understatement to note that the proposed Phase 2 rule is a complicated rulemaking. We are still in the process of reviewing the rule and its supporting technical analysis. But one thing is abundantly clear: the Greenhouse Gas Emissi on Model (or “GEM”) play s a crucial role in Phase 2 regulations. GEM , literally, determines how you comply

.

Allison fully supports EPA’s ongoing efforts to make GEM more accurate and more representative of real world vehicles . We also support the use of GEM as the primary certification methodology

-- but we have some significant concerns with the quality of GEM

software and EPA t echnical and policy choices regarding GEM

.

First, GEM does not run well. When GEM was delivered, there were missing files and then when we got it to run, there were a number of coding errors identified. Secondly, the model produces unrealistic operation over the duty cycles. T he lockup shift strategy and the neutral loading and automatic neutral functionality are inappropriate. And , finally, there are major deficiencies in the base control algorithms. Some production vehicle con figurations w ould not shift out of first range. Others do not downshift at highway speeds when a load is encountered.

We have also seen the GEM controller release lockup at highway speeds which would never happen.

These examples do not reflect how fully automatic transmissions operate. And flaws in GEM will directly translate into flaws in the final rule. In short, GEM is not ready for “prime time”

as the certification tool.

Allison Transmission Public Comments EPA and NHTSA Public Hearing August 6, 2015 Chicago, ILGiven this situation, we believe that EPA and NHTSA must be mindful of the procedural requirements of th e Clean Air Act and the Administrative Procedure Act. A dequate opportunity for comment must be provided , especially with regard to a central element of the rulemaking

, such as GEM

.

With regard to GEM, the devil really is in the details

. It is impossible to understand and reasonably project the effect of any final rule without understanding precisely how GEM will operate, what it will measure and how it will assess different systems. This is especially true in the vocational vehicle market where there are hundreds of different vehicle types and is amplified where, as here, EPA and NHTSA intend to decrease greenhouse gases and improve fuel efficiency through the deployment of new technology.

When GEM executable files will not run; when other errors are found in GEM, when delays

occur i n making changes to the model

-- the very process of the public comment period is called into question . Without refinement, GEM results could be considered arbitrary

.

To be clear, we intend our comments not as a reflection of the hard work of EPA and NHTSA or their staff. Instead, our criticism is a reflection of the extremely complicated nature of the proposed rule and its heavy reliance on computer modeling

.

We believe that there are several ways EPA can addres s this situation. One avenue would be to

extend the comment period to allow a sufficient time to resolve GEM “bugs” and to allow the public sufficient time to run the model and fully understand its implications. In our view, there

is no downside to this option since there is no legal deadline for a final rule . Another possible avenue would be to reopen the public comment period when GEM is further developed. Other administrative avenues are potentially available, including issuing a Notice of Data Avail ability with an opportunity for comment.

Allison Transmission is looking forward to continuing work with EPA and NHTSA

, but we ask now, at this stage, that the agencies recognize GEM needs further refinement to allow for public

comment and that, overall, the operation of the model must be improved

. W e urge EPA and

NHTSA to seriously consider this matter prior to the announced deadline for the submission of

comments

.

Allison Transmission Public Comments EPA and NHTSA Public Hearing August 6, 2015 Chicago, IL