**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 1 2 th, 2011 and May 23 rd we held conference call s with BAE to discuss concerns raised by BAE regarding heavy- duty onboard diagnostic (OBD) requirements and timing. We did not get through the entire agenda in the first meeting; therefore, we finished discussing the items on the agenda in the meeting on May 23 rd

. C oncerns were raised during the comment period for the heavy - duty

greenhouse gas notice of proposed rulemaking 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 BAE are shown in the table below. The agenda is on the following page of this memo. **Attendee Affiliation**  **Attended May 12th Meeting Attended May 23rd Meet**  **ing** Cleophas Jackson EPA Yes Yes Anthony Neam EPA Yes Yes Amy Kopin EPA Yes Yes Tom Apalenek BAE Yes Yes James Dupuy BAE Yes No Erin Hissong BAE Yes No Derek Matthews BAE Yes Yes Harry White BAE Yes No Margee Meckstroth BAE No Yes 1 U.S. EPA, NHT SA, 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. EP A, “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; Revisions to Onboard Diag nostic 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 STAT ES ENVIRONMENTAL PROTECTION AGENCY**  NATIONAL VEHICLE AND FUEL EMISSIONS LABORATORY

2565 PLYMOUTH ROAD ANN ARBOR, MICHIGAN 48105 - 2498 EPA - BAE Heavy - Duty Hybrid OBD Discussion 11am - noon EST May 12 , 2011 

### Ag **enda** 1. Wh at is your current OBD J1939 capability for handling faults? a. If you 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. Com prehensive Components: a. Wh at is your 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 system is only covered under comprehensive componen ts, 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 ou tput 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 Step s OFFICE OF AIR AND RADIATION