I spent about a 1/2 hour on the phone with a Cummins ser rep discussing towing heavy with the stock 5. 9 and with a 15000-16000# GN trailer. In regards to lugging,any SUSTAINED rpm below the max torque is considered lugging,in the case of my 04 it would be below 1400 rpm. The recommended cruise rpm is 1650 to 1900rpm,torque is what pulls the tr not hp,in order to get the good mpg # keep the rpm down. We also went through a complicated formula to work load and rpm # to figure out mpg at different load and rpm #. Very interesting. I was trying to figure out the economical gain of a US Gear aux box and through the formula determined that the potential yield would be . 5 to 1 mpg. Other topics where discussed, but the point is, call Cummins with your tech questions,the person I had on the phone is an engineer for the CO and was very helpful with the techy questions.