**UNITED STATES ENVIRONMENTAL PROTECTION AGENCY** NATIONAL VEHICLE AND FUEL EMISSIONS LABORATORY

2565 PLYMOUTH ROAD ANN ARBOR, MICHIGAN 48105 - 2498

**ME MORA**  **NDUM** SUBJECT: Heavy- Duty Hy brid Onboard Diagnostics FROM: Am y Kopin TO: The Docket DATE: July

15 , 2011 On May 11 th, 2011 we held a conference call with the Eaton to discuss concerns raised by Eaton regarding heavy - duty onboar d diagnostic (OBD) requirements and timing. D uring the comment period for the heavy- duty greenhouse gas notice of proposed rulemaking comments were raised that heavy - duty hy brid applications may

not be able to meet the 2013 heavy- duty OBD regulations that were published in the 2009 OBD Final Rulemaking . 1 , 2 Specifically , they have requested a delay

of the application of HD OBD requirements for hy brid applications until 2020. Attendees from the EPA and Eaton are shown in the table below. The agenda is on the following page of this memo. **Attendee Affiliation**  Cleophas Jackson EPA

– Compliance and Innovative Strategies Division Anthony Neam EPA

– Assessment and Standards Division Amy Kopin EPA

– Assessment and Standards Division Ian McKenzie Eato n

1 U.S. EPA, NHTSA, and DOT, “Greenhouse Gas Emission Standards and Fuel Efficiency Standards for Medium and Heavy - Duty Engines and Vehicles,” republished December 29, 2010. Available here: http://origin.www.gpo.gov/fdsys/pkg/FR - 2010 - 12 - 29/html/2010 - 32726.htm 2 U.S. EPA, “Control of Air Pollution from New Motor Vehicles and New Motor Vehicles Engines; Final Rule Regulations Requiring Onboard Diagnostic Systems on 2010 and Later Heavy - Duty Engines Used in Highway Applications Over 14,000 Pounds; Revisi ons to Onboard Diagnostic Requirements for Diesel Highway Heavy - Duty Vehicles Under 14,000 Pounds ,” published February 24, 2009. Available here: http://www.epa.gov/otaq/regs/im/obd/regtech/hd - obd - frm - 02 - 24 - 09 - notice - 74 - fr - 8310.pdf OFFICE OF AIR AND RADIATION**UNITED STATES ENVIRONMENTAL PROTECTION AGENCY** NATIONAL VEHICLE AND FUEL EMISSIONS LABORATORY

2565 PLYMOUTH ROAD ANN ARBOR, MICHIGAN 48105 - 2498 EPA - Eaton Heavy - Duty Hybrid OBD Discussion 2pm - 3pm EST May 11 , 2011 

### Ag **enda** 1. Wh at is y our current OBD J1939 capability for handling faults? a. If y ou don’t have any , how long do y ou estimate it w ill take to make y our current controller’s softw are J1939 capable? 2. Comprehensive Components: a. Wh at is y our understanding of w hat y ou need to do for comprehensive components? b. Wh y do y ou think y our current diagnostics w on’t meet comprehensive components? c. Given that the hy brid sy stem is only covered under comp rehensive components, how long w ill it take for y our company to make y our current diagnostics J1939 compatible for fault storage and reporting? d. Do y ou have the ability to determine an open, shorted to voltage, shorted to ground, an irrational sensor, and a nonfunctioning output component for y our hy brid electronical components? 3. Are there specific requirements or regulations that y ou anticipate having problems w ith and can y ou identify them? 4. EPA Heavy - Duty OBD Rulemaking and Alternative Fuels Timing 5. Next Ste ps OFFICE OF AIR AND RADIATION