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July25, 2012 

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 PAPER
development 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 on 

technology 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 trucks 

through 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 

www 01 '24 remarks-president-state-unjpjddress
Sullivan 

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