December 8, 2010

Margo T. Oge

Director Office of Transportation and Air Quality

Office of Air and Radiation U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, NW

MC-6401A Washington, DC 20460

Dear Margo:

Thank you for the opportunity to speak last month with you, your staff and your colleagues from the National Highway Traffic Safety Administra tion (NHTSA) regarding the U.S. Environmental Protection Agency’s (EPA’s) and NHTSA ’s joint effort to develop 2017 and later model year (MY) light-duty vehicle greenhouse gas ( GHG) emissions standards and Corporate Average Fuel Economy (CAFE) standards and, in parti cular, the agencies’ Notice of Intent regarding this initiative, as published in the Federal Register on October 13, 2010 (75 FR 62739). In follow up to that telephone discussion, we would like to briefly reiterate our comments regarding three overarching issues raised by the group of Nat ional Association of Clean Air Agencies (NACAA) leaders who participated in the call: 1) th e need for stringent GHG emissions standards, 2) the need for concomitant co-benefit reductions i n criteria pollutant and toxic air pollutant emissions and 3) how states are preparing for elect ric vehicles.

Stringency of GHG Emissions Standards

As EPA and NHTSA take the next step in regulating GHG emissions from light-duty vehicles, this step must help ensure that we are on a pathway for achieving an 80-percent reduction in carbon dioxide emissions by 2050 – a g oal that has been set by many states through legislation or action plans. Meeting this goal wil l require deep reductions in every sector; in the case of light-duty motor vehicles, states and local ities are relying on the greatest emissions reductions feasible. Given the many technological advances that have been made and the great potential for weight reduction reflected in the Lot us study report 1 , it appears clear that the stage is set for a substantial reduction beginning with MY 2 017. Accordingly, we urge EPA to consider the highest end of the range of annual reductions conte mplated in the EPA-NHTSA-California Air Resources Board (CARB) September 2010 Interim Joint Technical Assessment Report , (i.e., 6 percent), but not be bound by the reduction levels in the report and to consider whatever level of stringency can feasibly be achieved.

1 Lotus Engineering, Inc. (March 2010), An Assessment of Mass Reduction Opportunities for a 2017-2020 Model Year Vehicle Program, published by The International Council on Clean Tra nsportation ( http://www.theicct.org/2010/03/lightweight-future ).2

Co-Benefit Reductions in Criteria Pollutant and Tox ic Air Pollutant Emissions

State and local air quality agencies are responsib le for ensuring attainment and maintenance of new nitrogen dioxide and sulfur diox ide National Ambient Air Quality Standards (NAAQS), will imminently face a new ozone NAAQS and are looking toward a new fine particulate matter NAAQS. At the same time, we continue to fac e challenges ameliorating toxic air pollutants. For many areas, meeting these NAAQS and controlling air toxics will require significantly more stringent motor vehicle emissions standards due to the large contribution of motor vehicles to air pollution problems, as evidenced by NATA data as we ll as local monitoring and related studies. Although EPA and NHTSA are focused on reducing moto r vehicle GHG emissions and increasing fuel efficiency in this current effort, a broader v iew of the landscape reveals an urgent need for the two federal agencies to take into account the crite ria pollutant and air toxics co-benefits that are possible and necessary in the timeframe of this rul emaking (2017 to 2025). We urge EPA and NHTSA to broaden their rulemaking effort to take ad vantage of the co-benefit opportunities.

States’ Readiness for Electric Vehicles

EPA and NHTSA should be aware that the 14 states a cross the nation that have adopted CARB’s low-emission vehicle (LEV) standards are wor king hard to be ready for electric and fuel cell vehicles. We anticipate success on this front . Therefore, in addition to desiring that the current regulatory effort achieve a GHG emissions r eduction of at least 6 percent per year for the overall emissions benefit to the nation, these stat es also seek rigorous standards and requirements

that will ensure that electric and electric-drive v ehicles will be part of the fleet mix. Related to this issue, we urge that EPA use a non-zero emission fac tor to account for the emissions of electric

vehicles. We would welcome further discussion of t his issue so we may assist EPA in determining the most appropriate methodology for quantification of the emission factor.

Again, we thank you for talking with us and our co lleagues. We remain keenly interested in this rulemaking and offer our assistance as you mov e ahead.

Sincerely,

Nancy L. Seidman Barry R Wallerstein

Co-Chair Co-Chair

NACAA Mobile Sources and Fuels Committee NACAA Mobi le Sources and Fuels Committee

cc: Ron Medford (U.S. DOT, NHTSA) Tom Cackette (CARB)