MEMORANDUM

SUBJECT: Summary of Communications with External Parties Regarding the Final Rule for Medium and 

Heavy Duty Vehicle Fuel Efficiency and GHG Standards.

FROM: Byron Bunker - Assessment and Standards Division US EPA

TO: Docket EPA-HQ-0AR-2010-0162

DATE: August 3, 2011

The table below describes various phone calls and meetings with interested parties related to the 

proposed rule to set GHG emission standards for medium and heavy duty vehicles.

Date Participants Summary

10/28/2010

Mike Joyce – Owner 

Operator Independent 

Driver Association (OOIDA)

Discussed concern that vehicle speed governors weren’t a 

good solution for all drivers especially for individual owner 

operators.

10/28/2010 Pat Quinn – the Accord 

Group

Discussed challenges for heavy-duty hybrid vehicles to 

comply with EPA’s OBD requirements.

11/1/2010 Call w/ NHTSA & OOIDA Separate docket memo by Angela Cullen

11/4/2010

Jed Mandel and Tim 

Blubaugh Engine 

Manufacturers Assocation 

(EMA)

Discussed opportunity for harmonization of GHG standards 

long-term with Europe and the ultimate desirability of that 

outcome for EMA members. EMA emphasized this was a 

priority for their organization.

11/5/2010 Steve McCauly and 

Stephane Couroux

Discussed potential value of harmonized standards and 

new work being done on Low Rolling Resistance tires in 

Canada. Discussed importance of common test procedures 

even if differences in fleet mix mean that different 

standard levels might be more appropriate.

11/29/2010 Don Anair – Union of 

Concerned Scientists (UCS)

Questions about our cost and technology analysis in the 

rule.

12/1/2010 Mike Joyce – OOIDA

How does the rule handle size and weight? Will it 

discourage heavier trucks? Discussed that GEM approach 

does not limit truck capability regarding weight only 

incentivizes weight reduction.

12/16/2010 Jed Mandel and Tim 

Blubaugh (EMA)

EMA raised concerns that 2% measurement allowance for 

in-use testing does not adequately account for 

measurement variability. EMA raised concerns that DFs for 

CO2, N2O and CH4 could be difficult to develop and 

impacted by potential for measurement variation to impact 

estimate accuracy.

1/4/2011 Brad Hicks – Arvin Merritor Agency should consider expanding weight reduction list to 

additional components like brake drums and wheel hubs.

1/5/2011 David Bookbinder 

Discussed virtues and challenges of accurately accounting 

for upstream emissions for Natural Gas versus electricity. 

Discussed that natural gas has better CO2 performance 

when compared to a gasoline or diesel baseline.
1/5/2011 Patrick Charbonneau and 

Tony Cook - Navistar

Discussed technical challenges of reducing CO2 emissions 

from legacy products that will be retired and replaced. 

Discussed potential for hybrid vehicles to grow in the 

market and cost challenges facing wider use of heavy-duty 

hybrids. Discussed how to most accurately estimate 2011 

baseline performance for comparison in 2014. Discussed 

value of innovative credits and potential for new 

technologies like active fifth wheel systems that adjust 

trailer gap at highway speeds. 

1/6/2011

ACEE – Therese Langer, EDF 

– Hilary Sinamon, NRDC –

Luke Tonachel, NESCAUM –

Coralie Cooper, UCS – Don 

Anair, Brendan Bell, ICCT –

Ben Sharp, CATF – David 

Marshall

Margo Oge’s Office and by phone. Discussed need for data 

that VIUS survey used to provide. Need for additional data 

to do the rule better and especially future rules. Group 

discussed the potential for more stringent standards for 

heavy-duty pickups and vans by 2018 especially for 

gasoline engines. Discussed potential for more stringent 

vocational truck standards based on additional 

technologies including transmissions and hybrids. 

Discussed merits of laying out a 2020 path based on full 

suite of NAS identified technologies as a goal for the next 

rule but expressed in this rule. 

1/12/2011

Heavy Duty Fuel Efficiency 

Leadership Group – Pat 

Quinn, Waste Management, 

Randy Mullet- ConWay 

Trucking, Bill Bennet –

Eaton, Brian Mormino –

Cummins

Discussed implications of general vehicle description in 

GEM model when vocational vehicles specifically refuse 

vehicles are so varied. Discussed unique tire needs for 

vocational vehicles specifically high scrub resistance and 

high load ratings. Discussed value of multipliers and other 

aspects of credit generation to encourage market 

introduction of HEV and PHEV medium duty trucks. 

Discussed process for PHEV certification.

1/14/2011 Patrick Charbonneau, Tony 

Cook - Navistar

Discussed alternative engine standard and intent behind 

requirement to use all banked credits prior to utilizing the 

flexibility. Discussed inherent tension in using up banked 

credits when at the same time agencies presumably want 

to encourage introduction of advanced technologies. 

Discussed value of innovative credits to bring new 

technologies to market and relative merits of unrestricted 

credit trading versus more typical trading within standard 

categories.

1/20/2011 David Piech – Navistar

Discussed best method to accurately reflect CO2 

performance for engines at different levels of NOx 

performance.

1/25/2011 Don Nage – GM

Discussed inherent difficulty in meeting requirement to 

report individual 13mode data and RMC data from existing 

test cells. Discussed potential to substitute engineering 

test data for 13 mode results as one possible solution.

1/28/2011 Susan Alt, Jonathon Miller 

and Tony Greszler - Volvo

Margo Oge’s Office and by video. Volvo raised five priority 

issues in the rule. Their number one issue was maintaining 

existing EPA approach to restrict credit averaging across 
vehicle class sizes. Volvo does not make LHD and MHD 

products. Volvo also raised concerns about the process for 

certifying to the alternative engine standard, the alignment 

of model year definitions, and potential competitive issues 

if in markets were small businesses produce a significant 

fraction of the vehicles (specifically refuse trucks).

2/9/2011 Brian Burton – Daimler Discussed Daimler trucks interest in future alignment of US 

and European GHG and FE programs. 

2/10/2011 Don Nage – GM

Discussed relative merits of using engineering data rather 

than 1065 compliant date for reporting engine maps used 

for modeling and not certification. Don emphasized that it 

would require extensive test cell upgrades to make all 

development cells 1065 compliant.

2/14/2011

Drew Kodjak – International 

Council on Clean 

Transportation (ICCT)

Discussed ICCT’s interest in helping other regions move 

forward on GHG and FE programs for HD trucks.

2/15/2011 Tim Blubaugh – EMA

Discussed top issues of concern for EMA and its members 

including broader use of ABT credits, treatment of 

innovative credits, DF determination, OBD for GHG 

controls, consistency of definitions between EPA and 

NTHSA regulations, emissions warranties for tires, handling 

of small business exemptions where small businesses 

compete with large companies, and impediments to 

bringing hybrid vehicles to the market. Discussed need for 

additional work on aerodynamic test procedures.

2/25/2011 Tim Blubaugh – EMA

Discussed issues of concern to EMA and its members 

including concern that N2O standard didn’t reflect full 

range of current product performance, CO2 compliance 

margin didn’t reflect facility to facility variation, need for 

additional methods to certify hybrid drivetrains similar to 

innovative technologies, means to account for wind 

average yaw, and potential to use CdA vs Cd for GEM 

model.

3/2/2011 Tim Blubaugh – EMA

Discussed issues of concern to EMA and its members 

including need for enhanced coastdown test procedure, 

need to account for aerodynamic performance differences 

between sleeper cab and day cab tractors, potential to 

correlate OEM’s own aerodynamic procedures to a 

common reference test procedure, need for means to 

account for wind average yaw, need to define a trailer as a 

test article for coast down procedure.

3/2/2011

Patrick Charbonneau, Tony 

Cook and David Piech –

Navistar

Discussed various aspects of alternative CO2 standard in 

the proposal. Discussed issue of legacy engines and need 

for a compliance path that would work for engines that 

could not be readily updated in the near term but that 

would see a significant update in the coming years. 

Discussed technologies that would be available to legacy 
engines including turbocharging improvements, fuel 

system, reduction in friction, and improved combustion 

optimization. In total these available technologies were 

believed to allow improvements on the order of 2 percent. 

Discussed need to address differing NOx baselines for 

engine out technologies and the potential to use a 

correction factor based on 2009-2011 certification data. 

Discussed potential for innovative technologies and the 

merits of early introduction of Advanced Smartway designs 

to be treated as an advanced technology like hybrids.

3/3/2011

John Wall, Brian Mormino, 

Jackie Yeager and Bob 

Jorgensen – Cummins

Discussed issues of concern to Cummins including their 

feeling that advanced technology credits should not have 

special standing, a concept for addressing the denominator 

effect in child ratings, additional means for hybrid 

certification, and Cummins opinion that gasoline engines 

should have to meet the same stringent standards as diesel 

engines.

3/8/2011 Tim Blubaugh – EMA

Discussed issues of concern to EMA and its members 

including standard trailer testing conditions, how to handle 

anemometer location for coastdown testing, need to 

tighten wind speed allowance for coastdown, and other 

aspects of improving the defined aerodynamic coastdown 

procedure.

3/17/2011 Stephane Couroux –

Environment Canada

Discussed how certification processes in the US and Canada 

might be better aligned or harmonized.

3/17/2011 Tim Blubaugh – EMA

Discussed issues of concern to EMA and its members 

including hybrid test procedures, potential to certify hybrid 

vehicles using innovative procedures, concerns that 

proposed drive cycle not representative of most hybrid 

applications, and means to improve aerodynamic test 

procedures including similar methods as discussed on 3/8.

3/25/2011 Brian Mormino – Cummins

Discussed issues of concern to Cummins including 

treatment of vocational vehicles especially emergency 

vehicles and interest in seeking harmonized standards in 

China.

4/1/2011 Tim Blubaugh - Cummins

Discussed issues of concern to EMA and its members 

including concern that technical need to potentially create 

separate GHG engine families for FTP and SET certified 

engines would inadvertently double the testing burden of 

the existing HD in-use and OBD programs. Also discussed 

EMA’s interest in more definition regarding innovative 

technology test procedures including the possibility of 

using an SAE type II or III fuel economy procedure.

4/1/2011 Barbara Kiss – GM

Discussed issues of concern to GM including concern that 

gasoline loose engines would not have access to other 

potential sources of GHG credits and hence could not be 

sold if technical difficulties made certification below the 
standards not possible. Also discussed the relatively large 

testing burden given the small volume of loose gasoline 

engine sales.

4/1/2011 David Piech – Navistar

Discussed issues of concern to Navistar including 

limitations of legacy engines to improve performance 

beyond improvements in combustion, parasitics and 

turbomachinery. Also discussed challenges of 

appropriately addressing differences in NOx baseline 

performance with many 2011 engines certified to 0.5 g 

NOx and likely to be certified to 0.2 g NOx in 2014.

4/12/2011 Tony Greszler - Volvo

Discussed issues of concern to Volvo including use of MHD 

advanced technology credits to comply with HHD vehicle 

standards, alternative engine standards, and concerns 

regarding “double jeopardy” under a joint EPA/NHTSA 

program.

4/12/2011 Tim Blubaugh – EMA Discussed EMA’s concerns regarding development of DFs 

for CO2.

4/15/2011

Jackie Yeager, Brian 

Mormino, and Bob 

Jorgensen - Cummins

Discussed Cummins’ interest to develop some means to 

adjust CO2 standard for child ratings. 

4/18/2011

Brian Mormino – Cummins, 

Tony Greszler – Volvo, and 

Brian Burton - Daimler

Discussed Cummins, Volvo and Daimlers common concerns 

that alternative engine standards could be “gamed” 

without appropriate accounting of the 2011 baseline and 

concerns that advanced technology credits from MHD 

trucks could undermine HHD tractor reductions leading to 

a competitive concerns for these OEMs.

4/19/2011 Tim Blubaugh – EMA

Discussed issues of concerns to EMA and its members 

including their interest in harmonized standards for the US, 

Canada, and Mexico, their concerns about the 2% in-use 

compliance margin, the N2O standard, and handling of 

early emissions credits by calendar year or model year.

4/20/2011 Tony Greszler and Marc 

Miller – Volvo

Discussed Volvo’s concerns with the advanced technology 

credits and the potential for significant credit flows from 

MHD trucks negatively impacting Volvo in the HHD tractor 

market.

4/25/2011 Tim Blubaugh – EMA

Discussed issues of concern to EMA and its members 

specifically EMA’s recommendation to use CdA rather than 

Cd in the GEM model and the specific recommendation 

that the reference trailer used for coast down testing be 

set at 13 foot 6 inches measured from the ground.

4/27/2011 Jed Mandel – EMA

Discussed issues of concern to EMA and its members 

including EMA’s strong desire that the program works as a 

single national program with a single certification template, 

single certification determination and coordinated single 

action to address any violations of the CAA or EISA.

4/28/2011 Tim Blubaugh – EMA Discussed EMA’s concern regarding dual certification of 

engines to both the FTP and SET standards for CO2.
4/29/2011 Tony Cook and David Piech 

– Navistar

Discussed issues of concern to Navistar including how to 

most appropriately account for difference in NOx baseline 

emissions for the proposed alternative engine standard. 

Also discussed need to group LHD and MHD baseline data 

together given small number of LHD engines and common 

standards for LHD and MHD engines.

4/30/2011 Tim Blubaugh – EMA

Discussed issues of concern to EMA and its members 

including the method for determining the overall height for 

a box trailer used in aerodynamic testing.

5/2/2011 Tony Greszler – Volvo

Discussed issues of concern to Volvo including competition 

concerns for LOCE Class 8 trucks with exempted small 

businesses and credit trading between MHD and HHD 

vehicle.

5/4/2011 Debbie Gordon – Allison

Discussed issues of concern to Allison Transmission 

including how A to B testing for hybrids and powerpack 

testing should be done, how NOx criteria certification 

would be handled, how transmission shift schedules could 

be assured to give a fair A to B comparison.

5/4/2011 Tony Greszler – Volvo

Discussed issues of concern to Volvo including treatment of 

MHD credits, the alternative engine standards, potential 

for double jeopardy, potential for loopholes in baseline and 

child engine ratings, desire for US to work with Europe 

towards a common standard.

5/4/2011 Barbara Kiss & Steve Freneti 

– GM

Discussed issues of concern to GM including the gasoline 

engine standard, and N2O measurement techniques.

5/5/2011

Meeting Dennis Slagle, Tony 

Greszler, and Jonathon 

Miller from Volvo with Gina 

McCarthy, Margo Oge, Lori 

Stewart, Steven Silverman 

and Byron Bunker of EPA

Discussed issues of concern to Volvo including potential for 

“double jeopardy” with dual EPA and NHTSA programs, 

Volvo’s competitive concerns with credit trading of 

advanced technology credits from MHD to HHD trucks 

including Volvo’s recommendation that the agencies 

consider capping those credit transfers, and Volvo’s strong 

interest to ensure the program is robust and enforceable in 

order to maintain a level playing field in the market.

5/6/2011

Brian Mormino – Cummins, 

Tony Greszler – Volvo, and 

Brian Burton - Daimler

Discussed issues of concern to all three companies 

including means to ensure alternative engine baseline level 

is real perhaps by using sales weighting and pooling all 

engines together. Also discussed potential to constrain 

advanced technology credit trading to address concerns 

raised by companies on level playing field.

5/9/2011 Jed Mandel – EMA

Discussed EMA and its members concerns regarding the 

potential for dual EPA and NHTSA programs rather than a 

joint national program. In particular, EMA continued to 

express concerns regarding handling of enforcement 

actions with potential for in EMA’s words “double 

jeopardy”

5/10/2011 Don Anair – UCS, Luke 

Tonachel – NRDC, Therese 

Discussed issues of concern to the groups on the call 

including what actions the agencies would take to ensure 
Langer – ACEEE, Mark 

McCloud – EDF, David 

Marshall – CATF, Fanta 

Kamatake – ICCT, and Matt 

Solomon – NESCAUM

data was available to develop the phase 2 program, what 

the agencies could do to ensure innovative credits were 

real and appropriately accounted for, process for 

certification and interest in finding a more elegant solution 

to child ratings.

5/11/2011 Tim Blubaugh – EMA

Discussed issues of concern to EMA and its members 

including data gathering for phase 2, handling of 

alternative engine baseline, ability to certify FTP and SET 

GHG standards separately, and appropriate hybrid vehicle 

drive cycles.

5/11/2011 Brian Mormino – Cummins

Discussed issues of concern to Cummins including their 

recommendation that gasoline engines meet the same CO2

standard as diesel, that advanced technology credits would 

not be fungible across regulatory classes, that the agencies 

consider other ways to handle child engine ratings.

5/11/2011

Meeting Jed Mandel – EMA, 

Margo Oge – EPA, and Ron 

Medford - NHTSA

Participants discussed EMA’s strong interest in a 

harmonized national program with EPA and NHTSA acting 

effectively as a single agency and not a dual program with 

duplicate certification applications, duplicate approval and 

duplicate enforcement.

5/13/2011

Pat Quinn – Accord Group, 

Chris Hess and Mihia 

Dorobantu – Eaton

Discussed issues of concern to Eaton specifically related to 

determination of A to B test procedures and selection of a 

fair comparison transmission. Eaton believed power and 

vehicle weight would be most important aspects to match.

5/17/2011 Patrick Charbonneau –

Navistar

Discussed issues of concern to Navistar including the 

alternative engine standards and the best performance 

possible for certain legacy engines. Discussed 

appropriateness of accounting for tradeoffs between N2O 

emissions and CO2 in seeking to achieve the lowest total 

GHG emissions.

5/19/2011 Debbie Gordon – Allison 

Transmission

Discussed issues of concern to Allison including ways to 

ensure that A to B testing was done using an appropriate 

reference vehicle for comparison. Discussed need to look 

at equal performance for acceleration, startability, and 

gradeability. Also discussed need to clarify what is meant 

by worst case and how do our current procedures ensure 

best effort when a vehicle cannot follow the driving trace.

5/19/2011 Tim Blubaugh – EMA

Discussed issues of concern to EMA and its members 

including how to handle aerodynamic testing for low and 

midroof tractors where trailer characteristics are quite 

variable (EMA recommendation – test bobtail) and function 

of a vehicle emissions label.

5/20/2011 Tim Blubaugh – EMA

Discussed issues of concern to EMA including DF 

determination, concept of a minimum improvement for 

innovative credits, handling of vocational tractors, 

definition of a Rankine cycle engine, warranty and 

emissions label concerns.
5/23/2011 Steve Frenetti – GM

Discussed issues of concern to GM including how vehicles 

with similar configuration would be tested and accounted 

for in the pickup truck standards.

5/24/2011 Patrick Charbonneau -

Navistar

Discussed issues of concern to Navistar including handling 

of advanced technology credits, interest in accounting for 

N2O / CO2 tradeoff, interest in accounting for mass 

reductions due to smaller engines and concerns about the 

alternative engine standards.

5/24/2011 Cynthia Williams – Ford Discussed issues of concern to Ford including handling of 

emissions warranties for tires and other components.

5/25/2011 Patrick Charbonneau –

Navistar

Discussed issues of concern to Navistar including 

alternative engine standard and treatment of N2O 

emissions.

5/25/2011 Tim Blubaugh – EMA

Discussed issues of concern to EMA and its members 

including determining what products could reasonably 

qualify for early compliance credits without creating a 

windfall.

5/31/2011 Tim Blubaugh – EMA

Discussed issues of concern to EMA and its members 

including how many vehicle tests must be completed prior 

to certification at the start of a model year, handling of all 

components on an emissions label, and treatment of 

emissions warranties for trucks vs engines.

6/2/2011

Brian Mormino, Mike Ruth, 

Bob Jorgensen, Jackie 

Yeager, and John Dixon -

Cummins

Discussed issues of concern to Cummins including 

treatment of advanced technology credits, certification 

process for hybrids, means to measure 13 point steady 

state results over a Ramp Modal Cycle, how to 

demonstrate that early compliance credits do not 

represent a windfall, how to address phantom rating 

concern, and means to certify complete vehicles in Class 4 

and 5.

6/3/1022 Tim Blubaugh – EMA

Discussed issues of concern to EMA and its members 

including treatment of N2O emissions, issues raised on 

OBD standards for hybrids, emission warranties for hybrids, 

and handling of advanced technology credits.

6/6/2011 Fuel Economy Leadership 

Group

Discussed HD proposal in general and few issues of concern 

including vocational tires and ability of fleets to specify the 

right truck for their businesses.

6/6/2011

Don Anair, Michelle 

Robinson (UCS), Vickie 

Patton (EDF), Luke Tonachel 

(NRDC), Drew Kodjak (ICCT)

Discussed common issues of concern for the groups 

including need to move forward soon on phase 2, timeline 

for EPA and NHTSA implementation (maintaining 2014 

compliance year), how soon can trailer standards be set?, 

potential for harmonization with Canada and Mexico.

6/13/2011 Marc Miller, Tony Greszler, 

and Dave Smith – Volvo

Discussed issues of concern to Volvo including handling of 

vocational tractors, must every tire size be tested or can 

test results be interpolated between tire sizes, how does 

PTO load differentiate between accessory load and direct 

PTO shaft load, and need to address health and safety 
concerns with anti-idling technologies.

6/13/2011 Jed Mandel and Tim 

Blubaugh

Discussed issues of concern to EMA and its members 

including EMA’s strong desire that the joint NHTSA/EPA 

program look and act as a single national program for the 

industry. Strong desire to avoid dual certification, dual 

compliance and dual penalty investigations.

6/15/2011 David Kayes – Daimler 

Trucks

Discussed issues of concern to Daimler including the 

potential use of advanced technology credits to offset new 

technology introduction in sleeper cab tractors.

6/15/2011 Tim Blubaugh – EMA

Discussed issues of concern to EMA and its members 

including how early compliance credits would be calculated 

for engines versus vehicles given the current industry 

practices that shift the model years between vehicles and 

engines. Also discussed emissions related components in 

the context of components that could never fail in their 

emissions role (e.g. weight reduction – parts can’t get 

heavier in-use). Finally discussed a number of issues 

related to improvements to coastdown test procedures 

including the appropriate location of a wind speed 

anemometer, acceptable wind speeds during a test, and 

appropriate trailer gap for testing given current industry 

practices.

6/17/2011

Hilary Sinnamon, Jackie 

Roberts – Environmental 

Defense Fund (EDF) 

Discussed issues of concern to EDF including the degree to 

which the rule was likely to lead to increased production of 

specific vehicle components and which sectors of truck 

production were most likely to increase due to the need for 

new parts.

6/17/2011 Tim Blubaugh – EMA

Discussed issues of concern to EMA and its members 

including treatment of mass reducing technologies, means 

to ensure alternative engine standards accomplished real 

reductions, the treatment of advanced technology credits 

and questions about additional testing to inform the 

agencies’ decisions on aerodynamic test procedures.

6/20/2011 Marc Miller – Volvo

Discussed issues of concern to Volvo including concern that 

individual class 5 vehicle platforms would have no 

opportunity for credit trading with cross class restrictions 

and best means to determine aerodynamic performance of 

low and mid roof day cab tractors derived from high roof 

tractors.

6/20/2011 Pat Quinn – the Accord 

Group

Discussed issues of concern to the Heavy Duty Fuel 

Economy Leadership group including the groups interest in 

working with the agencies during development of any 

future heavy-duty regulation.

6/22/2011 Jackie Roberts – EDF

Continued discussion from 6/17 that had been cut short 

due to a fire alarm at EPA. Discussed specific truck 

technology changes.

6/27/2011 Heavy Duty Fuel Economy Discussed issues of concern to the group including hybrid 
Leadership Group –

meeting with EPA at Ariel 

Rios (Margo Oge, Chet 

France in DC, Byron Bunker 

by video)

certification procedures and the value in encouraging 

hybrid technologies, desire for a single harmonized test 

procedure, and in the long term creating a complete 

vehicle certification process and desire to work with the 

agencies in the future on any trailer regulations.

7/5/2011 Glen Kedzie – ATA

Discussed issues of concern to ATA and its members 

including tampering provisions, vehicle emissions labeling 

provisions, treatment of add-ons like roof carriers (again 

tampering), idle shutdown provisions to protect driver 

safety and will the provisions of the rule allow classic 

tractors to continue to be produced.

7/6/2011 Tim Blubaugh – EMA

Discussed issues of concern to EMA and its members 

including means to measure and account for aerodynamic 

improvements that reduce wind average drag, definition of 

date of manufacture, means to account for reductions in 

N2O emissions, and mechanisms to account for vehicle 

speed limiters that incorporate soft top features.

7/6/2011 Mark Cauchi – Environment 

Canada

Discussed issues of interest to Environment Canada 

including the potential for Canadian regulations to align 

with US regulations in the future.

7/12/2011 Tim Blubaugh – EMA

Discussed issues of concern to EMA and its members 

including treatment of medium duty engines primarily 

designed for vocational use but sold into line haul 

applications.

7/16/2011

Brian Mormino, Jackie 

Yeager, and Bob Jorgensen 

– Cummins

Discussed issues of concern to Cummins including 

treatment of complete versus incomplete vehicles for 

criteria and CO2 certification. Cummins position is the CO2 

and criteria certification should be paired. Cummins also 

raised questions regarding how the agencies intended to 

handle certification for engine families where the worst 

case engine selection for NOx was a restricted rating. 

Cummins also raised concerns about the proposals 

language suggesting extension of the heavy-duty pickup 

and van program to large (Class 4+) vehicles