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The Honorable Lisa Jackson Administrator U.S. Environmental Protection Agency 1200 Pennsylvania Ave., N.W. Washington, DC 20460
Jeffrey Zients, Acting Director The Office of Management and Budget 725 17th Street, NW Washington, DC 20503

Dear Administrator Jackson and Acting Director Zients: We are writing to express our support for market development for vehicles that run on natural gas an abundant domestic fuel that can help enhance our air quality and increase our energy security. As your agencies work to finalize the proposed rule for light-duty vehicle fuel economy and greenhouse gas (GHG) emissions standards, we urge you to use this opportunity to level the playing field for all alternative fuel choices that can help us meet these national goals. Congress has recognized the contribution that natural gas can provide as a transportation fuel dating back to the Alternative Motor Fuel Act of 1988 (AMFA) in which Congress wrote a specific compliance metric favoring natural gas and other alternative fuels into the light-duty fuel economy statute. The Conference Report for AMFA could not have been clearer: "[tjhe objective of both the House and Senate bills is to facilitate the development and use of alternative fuels in the United States for purposes of energy security', and the first two legislative findings in the statute itself were "the achievement of long-term energy security for the United States is essential to the health of the national economy, the well-being of our citizens, and the maintenance of national security" and "the displacement of energy derived from imported oil with alternative fuels will help to achieve energy security and improve air quality." Indeed, we agree these objectives are even more critical today.
While we may have differing opinions on light-duty vehicle fuel economy standards and the GHG emission requirements component to this rule, the proposed rulemaking notes that the new requirements are "designed to promote advanced technologies that have the potential to provide 'game changing' GHG emissions reductions in the future." 3 However, as written, the proposed rule creates manufacturing incentives that favor one potential "game changing" technology electric and hybrid vehicles - over other equally compelling alternative fuel choices. We urge you to correct this imbalance. In particular, we ask that you revise the rule to reflect the comparable environmental benefits that natural gas vehicles provide. The President has noted his support for natural gas as a transportation fuel in a number of recent high-profile statements. During his 2012 State of the Union Address, the President stated that "the

House Report 100-929, 134 Cong Rec H 7732, September 16, 1988, p. 7736 2 P.L. 100-494, Section 2 76 Fed. Reg. at 75,012.

PAINTED ON RECYCLED PAPERdevelopment of natural gas will create jobs and power trucks and factories that are cleaner and

cheaper, proving that we don't have to choose between our environment and our economy."4 Speaking in Las Vegas a few days later, he highlighted the potential for natural gas to displace oil and committed the Federal government to do more to incorporate natural gas vehicles into its own vehicle fleet. More recently, while speaking at a North Carolina producer of natural gas trucks, he affirmed the Administration's support for incentives to families, communities and companies that encourage adoption of alternative fuel vehicles. In comments submitted jointly to the Environmental Protection Agency, the American Gas Association (AGA) and America's Natural Gas Alliance (ANGA) point out that, based ontechnology available today, natural gas vehicles achieve GHG emissions benefits far more costeffectively than electric and plug-in hybrid vehicles. This is an important finding in keeping with the stated objectives for the rulemaking. In the proposed rule, your agency recognizes the importance of the economic impact of these regulations, noting that the regulations will "achieve important reductions in GHG emissions and fuel consumption from the light duty vehicle part of the transportation sector, based on technologies that either are commercially available or that the agencies project will be commercially available in the rulemaking timeframe and that can be incorporated at a reasonable cost." Similarly, the comments of the American Clean Skies Foundation (ACSF) urged that the EPA pursue a technology-neutral approach that provides comparable incentives to natural gas and electric vehicles. ACSF also recognized the cost-effectiveness of natural gas vehicles in reducing GHG emissions, as well as the significant energy security benefits of using natural gas as a transportation fuel. The AGA-ANGA comments, as well as those of ACSF, outline specific provisions that, if incorporated into the rule, would provide parity, with regard to the proposed rulemaking, between natural gas and electric/plug-in hybrid vehicles. We understand that proposed rule has been submitted to the Office of Management and Budget for final analysis and we ask that you adopt these suggested changes as you review the EPA's draft rule. The Presidential Memorandum of May 21, 2010 described this current round of regulation as an "opportunity to lead the world in the development of a new generation of clean cars and trucksthrough innovative technologies and manufacturing that will spur economic growth and create highquality domestic jobs, enhance our energy security, and improve our environment." Of the over twelve million natural gas vehicles worldwide today, only about one percent are in use here in the United States. The current rulemaking is an opportunity to help our nation lead the world in natural gas transportation and to more fully benefit from a clean, abundant, and domestic resource. Thank you for your consideration of this request and we look forward to your response.

' President Obama. State of the Union Address (January 26, 2012). Available at

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mber of Congress

ill Shuster Member of Congress

r6m Cole Member of Congress

Frank D. Lucas Member of Congress Jim Matheson Member of Congress

Leonard Boswell Member of Congress

Bill Cassidy Member of Congress artkfor ber of Ccftgress ke Ross ember of Congress