**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: By ron Bunker, Chien Sze, Cle Jackson, and Angela Cullen NHTSA: Maurice Hicks MEMA: L eigh Merino and representatives from Bergstrom, Bendix, Delphi, Eaton, Essbar Heating S ys tems, Honey well, Reem y, 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 re gulatory 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 Hy brid Powertrains (designs that include energy storage sy stems); Rankine C ycle Engi nes (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 int erpret that to mean the2 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 / s ys tem 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 Cy cle Engines

– On Page 74255 the NPRM specif ies “Rankine cy cle engines” as a proposed advanced credit technology . I s “Rankine” interchangeable with “bottoming cy cle” in this context? c. Specific question re: Hy brid Powertrains

– On Page 74188 the NPRM specifies “the agencies propose to set sta ndards for the chassis manufacturers of vocational vehicles.” Can advanced technology credits be generated for hy brid vocational vehicles in the case where the h ybrid s ys tem integrator is not the chassis manufacturer? I f yes, is the chassis manufacturer re quired to do the testing or is it acceptable for the h ybrid 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 benefi ts are not captured over the test procedure used to determine compliance with the standards”

– and are, therefore, “off
- cy cle.” The agencies continue on to say that eligible innovative technology “are newly

introduced in one or more vehicle models or engi nes, but that are not y et widely implemented in the heavy
- dut y fleet.” We would like clarification on how the agencies interpret “newl y introduced” and “widel y implemented.” 3. We notice that under the “Definitions” section of the proposed regulator y 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?3

4. Page 74209 (center column) refers to “four separate N 2 O 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 di esel 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 t ypes 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