UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

NATIONAL VEHICLE AND FUEL EMISSIONS LABORATORY

2000 TRAVERWOOD ROAD

ANN ARBOR, MI 48105-2498

 OFFICE OF

AIR AND RADIATION

January 18, 2011

MEMORANDUM

SUBJECT: Meeting with the Motor & Equipment Manufacturers Association (MEMA)

FROM: Angela Cullen

TO: Docket EPA-HQ-OAR-2010-0162

This memorandum documents a teleconference held on Thursday, January 13, 2011 between 

EPA, NHTSA, and MEMA. The individuals who participated in the teleconference include:

EPA: Byron Bunker, Chien Sze, Cle Jackson, and Angela Cullen

NHTSA: Maurice Hicks

MEMA: Leigh Merino and representatives from Bergstrom, Bendix, Delphi, Eaton, 

Essbar Heating Systems, Honeywell, Reemy, Bosch, SRG Global, Webasto, ZF, and 

Alcoa

In the meeting, EPA provided clarifications to the questions posed by MEMA included below:

Clarification Questions / Issue Areas for EPA Call 1/13/11

1. Relative to the regulatory flexibilities, as we understand it, the agencies want to encourage faster 

adoption of advanced technologies and, as such, have proposed including a 1.5 credit for Hybrid 

Powertrains (designs that include energy storage systems); Rankine Cycle Engines (waste heat 

recovery); All-Electric Vehicles; and, Fuel Cell Vehicles. 

Please consider the following questions:

a. Agencies requested comments on the technologies identified and whether 

additional technologies should be added to the list. We interpret that to mean the 
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agency needs a concrete list of advanced technologies and/or advanced 

technology categories. Is a “fixed list” what the agencies envisioned for the 

standards? Or would the agency be open to an approach / system that could add, 

over time, advanced technologies to an active list / living document to include 

technologies (deemed / defined as “advanced”) evolve within those categories 

listed in the NPRM? 

b. Specific question re: Rankine Cycle Engines – On Page 74255 the NPRM 

specifies “Rankine cycle engines” as a proposed advanced credit technology. Is 

“Rankine” interchangeable with “bottoming cycle” in this context?

c. Specific question re: Hybrid Powertrains – On Page 74188 the NPRM specifies 

“the agencies propose to set standards for the chassis manufacturers of vocational 

vehicles.” Can advanced technology credits be generated for hybrid vocational 

vehicles in the case where the hybrid system integrator is not the chassis 

manufacturer? If yes, is the chassis manufacturer required to do the testing or is it 

acceptable for the hybrid system integrator to do the testing for the credits 

calculation?

2. For innovative technologies we understand the agencies included them as those technologies 

“for which the reduction benefits are not captured over the test procedure used to determine 

compliance with the standards” – and are, therefore, “off-cycle.” The agencies continue on to 

say that eligible innovative technology “are newly introduced in one or more vehicle models or 

engines, but that are not yet widely implemented in the heavy-duty fleet.” 

We would like clarification on how the agencies interpret “newly introduced” and “widely 

implemented.”

3. We notice that under the “Definitions” section of the proposed regulatory text (Subpart I --

Definitions and Other Reference Information§ 1036.801 Definitions), there are no proposed 

definitions for either “advanced technologies” or “innovative technologies.” Was that 

intentional? 
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4. Page 74209 (center column) refers to “four separate N2O measurement methods” and that “EPA 

expects that most manufacturers would use photo-acoustic measurement equipment”. What are 

the other acceptable measurement methods?

5. Can the agencies share with us what was the volume mix of diesel and gasoline vehicles used to 

establish the 2010 common baseline for the pickups and vans?

6. In the pickup and vans category, can credits be applied across fuel types within this category? 

For example, can credits on diesel vehicles be applied to compensate for deficiencies on gasoline 

vehicles?

7. Why are improved accessories for HD pickups and vans only considered for diesel engine 

vehicles and not gasoline engine vehicles