From: <james.tamm@dot.gov> 

To: <Chandana_L._Achanta@omb.eop.gov> 

Cc: William Charmley/AA/USEPA/US@EPA 

Date: 05/04/2012 02:01 PM 

Subject: OMB Briefing on CAFE GHG - Presentation 

Hi Chandana, 

 

Attached is the presentation for today’s briefing. As you know, the presentation contains pre-decisional and 

deliberative information. The presentation should not be cited, quoted, or released until the final rule is issued. 

 

Jim 

OMB_Meeting_on_Modeling_Inputs_CAFE_&_GHG_Final.pptx 
CAFE-GHG 2017-2025 Final Ru

NHTSA-EPA Joint Briefing for Inter-AgencyMay 4, 2012

NHTSA and EPA Pre-Decisional Deliberative Materials for Interagency Review – Do Not Cite, Quote, or Rele
Agenda

• Overview of Public Hearing and Written Comments• Schedule• NHTSA-EPA plans for modeling inputs:

▫ Flat versus increasing fuel economy baseline assumptions▫ Technology costs/effectiveness

 battery costs effectiveness for advanced engines and transmissions

mass reduction costs

 Mild hybrid-electric vehicle technology

▫ New vehicle simulation work from NHTSA contractor Argonne Nationa

▫ Vehicle maintenance, repair, and other operating costs▫ Manufacturing learning curve assumptions▫ VMT growth estimations▫ VMT rebound▫ Inclusion of incentives in formal modeling (off-cycle credits, pickup 

credits, EV/PHEV multiplier)

▫ Probabilistic uncertainty analysis▫ Other updates for the FRM

• Next Steps

NHTSA and EPA Pre-Decisional Deliberative Materials for Interagency Review – Do Not Cite, Quote, or Rele
Background for today’s briefing

• NHTSA and EPA have locked down technology and e

inputs and are working on the final rulemaking analyagencies have not finished internal agency discussioregarding potential programmatic changes for the fin

• Today we will provide details regarding a number of 

inputs to the analysis, many of which OMB requesteas an overview of the public comments and issues.

• We have also included the current schedule for the f• While today’s briefing is prior to the formal interage

review, EPA will be placing this material into the pubonce the final rule is completed

NHTSA and EPA Pre-Decisional Deliberative Materials for Interagency Review – Do Not Cite, Quote, or Rele
• Nearly 400 testifiers across the 3 public hearings (De

Philadelphia, San Francisco) in January

• About 290,000 written comments received

▫ ~140 comments submitted by organizations

Overview of Public Hearings & WritteComments

▫ Remainder are comments from individuals, mostly spu

write-in campaigns, virtually all supportive

• Strong support from most auto manufacturers, UAW

consumer groups, citizens, military security organizastate/local governments, auto suppliers.

• See Appendix for summary of key comments by stak

NHTSA and EPA Pre-Decisional Deliberative Materials for Interagency Review – Do Not Cite, Quote, or Rele
Schedule

Milestone DNHTSA/EPA teams perform final rule modeling and analysis, draft responses to comments and the package Now throuFinal EIS Chapters 3-6 review by CEQ, OMB and EPA (cooperating agency) (6 days) June 2(cooperating agency) (6 days) June 2Final EIS Interagency review (3 days) June 2Final EIS issued JuEIS Notice of Availability published in Federal Register JuPackage to Interagency review (30 days) July 13-Signature Aug

NHTSA and EPA Pre-Decisional Deliberative Materials for Interagency Review – Do Not Cite, Quote, or Rele
Flat versus “market-driven” baseline proje

• NPRM

▫ EPA and NHTSA both used a “flat” baseline for primary analysis, i.e., assumed that the re

MY 2017-2025 would meet the MY 2016 standards without voluntary over compliance

▫ NHTSA also included a sensitivity case with a ”market-driven response” (increasing base

approach for all regulatory alternatives), including those technologies with a 1-year payb

• Comments

▫ 5 comments supported “flat” baseline: ACEEE, EDF, ICCT, NRDC, Sierra Club

 “Little or no” basis for increasing baseline without much higher fuel prices EIA gasoline price projections for 2025+ are similar to today’s prices Concern that accounting for an “market driven response” market role would reduce  Concern that accounting for an “market driven response” market role would reduce 

standards

▫ 5 comments on consumer valuation of fuel economy expressed as payback period:

 EDF and Sierra Club commented at least 5 year NADA commented at most 5 year VW commented less than 4 year ICCT commented 3 years 

▫ CBD commented that one of the draft EIS analyses “suggests a much lower fuel efficienc

by market forces than actual experience demonstrates occurs. A University of Michigan s

annual increase of 4.2% in an environment of low regulatory pressures”.

• Plan for final rule

▫ EPA will continue to use a “flat” baseline▫ NHTSA plans to assume a “flat” baseline (manufacturers will not apply more technology 

comply with standards) for the primary analysis and a “market-driven technology applicacase for technologies with a 1-year payback.

NHTSA and EPA Pre-Decisional Deliberative Materials for Interagency Review – Do Not Cite, Quote, or Rele
Lithium-ion Battery Costs for HEV, PH

and EVs: NPRM and Public Comment

NPRM• Agencies used peer-reviewed BatPac Model develop

Argonne National Laboratory

Public Comments

General comments that our battery costs were too lo

•

(Porsche) and too high (Tesla)

• BatPaC model should allow for choice of either air o

cooling of battery (ICCT)

• Beyond these high-level comments, no specific com

the use of the ANL BatPac model, or the modeling inby the agencies in BatPac

NHTSA and EPA Pre-Decisional Deliberative Materials for Interagency Review – Do Not Cite, Quote, or Rele
Battery Costs – FRM 

• Both agencies are using an updated version of t

BatPaC model

▫ Updated model allows choice of air or liquid cool

▫ Updated model allows for parallel modules and p

packs as well as parallel cells

▫ We have included costs for a battery discharge sy

allow for safe discharge of pack’s stored energy broad-side assistant companies, emergency responothers as needed. These discharge system costs wincluded in NPRM.

NHTSA and EPA Pre-Decisional Deliberative Materials for Interagency Review – Do Not Cite, Quote, or Rele
Effectiveness for Advanced Engines a

Transmissions – NPRM 

• Both agencies used the same effectiveness values for advanced 

engines, transmissions, hybrids, etc.

• Effectiveness estimates were derived largely from vehicle simu

from the 2011 Ricardo report and modeling tool

▫ Ricardo is an international engineering firm with >1,600 consultan

staff

▫ Primarily perform work for auto companies and suppliers, but also ▫ 2011 report was a 2-year effort building on 2008 study used for 20▫ 2011 report was peer reviewed at time of NPRM, and recently Rica

published a high-level peer-reviewed technical paper at the 2012 SAutomotive Engineers World Congress summarizing the 2011 stud

• The effectiveness estimates include projections of these techn

the future, such as the engine maps for turbo-charged and cootechnologies

NHTSA and EPA Pre-Decisional Deliberative Materials for Interagency Review – Do Not Cite, Quote, or Rele
Effectiveness for Advanced Engines a

Transmissions – Public Comments

General comments from industry – relates to all technologies• Given the considerable uncertainty about future technology development, cost and 

acceptability, the proposed mid-term evaluation is essential in order to assure that tfeasible fuel economy benefits are obtained in a cost-effective and safety neutral ma

Advanced engines• Uncertainty remains in the viability of high (27 bar) BMEP engines and obstacles are 

Investigation has found effectiveness benefits are lower than agency estimates. (VW

• The simulation modeling used to assess future technology benefits is conservative a

benefits will be larger than projected (ICCT – it should be noted that ICCT funded ~10study)

• Engine maps used in simulation modeling for diesels and cooled EGR gasoline engine

and have been surpassed by other sources, thereby underestimating effectiveness (I

• The agencies diesel effectiveness estimates may be understated (L. Marz, private citi

Advanced transmissions

• No comments on the agencies’ transmission technologies or effectiveness estimates

NHTSA and EPA Pre-Decisional Deliberative Materials for Interagency Review – Do Not Cite, Quote, or Rele
Effectiveness for Advanced Engines a

Transmissions– FRM

• EPA

▫ Final analysis will use the same effectiveness values as 

advanced engines and transmissions

• NHTSA

▫ The primary analysis for final rule will use the same eff

values as NPRM for advanced engines and transmissio

▫ Transmissions with naturally aspirated engines will use 

effectiveness based on Argonne National Laboratory (Amodeling.

▫ A sensitivity case analysis will be conducted using tran

shift optimizer shift schedule effectiveness (lower effe

based on ANL modeling on advanced engines with dua

transmissions.

NHTSA and EPA Pre-Decisional Deliberative Materials for Interagency Review – Do Not Cite, Quote, or Rele
Mass Reduction Costs – NPRM 

• Both agencies used the same mass cost curve 

their respective central analyses

• Each agency performed sensitivity analysis u

mass costs + and 

– 40% compared to the cen

analysis

• Agencies also discussed ongoing efforts looki

the feasible amount of mass reduction and mreduction costs and expressed possibility of uresults in the final rule.

NHTSA and EPA Pre-Decisional Deliberative Materials for Interagency Review – Do Not Cite, Quote, or Rele
Mass Reduction Costs – Public Comm

• ICCT (who partially funded the new FEV mass study) stated that EPA’s mass costs studies (Lotus E

FEV) should be considered in our analyses. They expect costs for the program will be less than extechnology advancements.

• Volkswagen states that mass reduction costs are underestimated

▫ VW stated “The NPRM predicts for large cars and some trucks upwards of 20% mass reduction poten

feels that this may exceed cost effective limits.” VW supports 7-10% mass reduction in the regulatio

▫ “The (exponential) function remains too conservative in its overall estimate of total price increase, i.e

‘shallow’. Volkswagen maintains that above 10%, costs accelerate at a faster rate making reductions less economically practical.“ Significant capital investment to upgrade to lighter material is of concerequipment’s longer useful lives.

• VW stated “Volkswagen has had many successes in applying advanced technologies to our economy 

and complexity decrease, but this process is lengthy and risky. “

• Mass reduction for smaller vehicles

▫ The Aluminum Association believes “advanced small vehicle designs will be developed using aluminu

structural components that will achieve significant weight reduction while preserving vehicle size and 

performance.“

• Some businesses did state that they were working on other mass reduction technologies. 

▫ American Iron and Steel Institute & United Steel Workers – new steels and automotive manufacturin

continue to be developed and will enable significant increases in mass reduction

▫ SABIC – plastic fenders, plastic front end modules, polycarbonate glazing for roof and backlight applic

composite lift-gates

▫ Society of the Plastics Industry, Inc. (SPI) – plastics and composites in glazing, body panels and interio

▫ Bayer Material Science – polycarbonate for headlamps, interior consoles and body panels

• The Alliance stated there are uncertainties with Computer-Aided Engineering crash modeling wit

materials that may possibly be available for mass production in the MY 2017-2025 time-frame .

NHTSA and EPA Pre-Decisional Deliberative Materials for Interagency Review – Do Not Cite, Quote, or Rele
Mass Reduction Costs – FRM

• Both agencies intend to use the identical cost cu

used in the NPRM in their respective central ana

• EPA and NHTSA both have new mass reduction s

which are undergoing peer review. The agencies use the results from these studies in the central for the final rule because the peer review procespotential response to comments is not complete

• We will discuss the results of these studies in the 

rule, and may perform specific sensitivity assessbased on their results.

NHTSA and EPA Pre-Decisional Deliberative Materials for Interagency Review – Do Not Cite, Quote, or Rele
Mild Hybrid Electric Vehicle Technolo

• For the NPRM, both agencies included two types of hybridizati

modeling

▫ 12 volt start-stop systems and strong hybrids based on the P2 conf

• Agencies did not explicitly model mild hybrids, though in the ca

full-size pickup trucks we proposed to provide incentive credits of this technology for 2017

-2021

• For the final rule, we have explicitly included mild-HEVs as one 

available technologies in our models, based on the E-assist miloffered today by General Motors

• Cost estimates based on scaling of similar components from th

Vue mild HEV tear-down costs and battery pack costs from the Model

• Technology effectiveness based on mild HEV system modeled u

Argonne National Laboratory Autonomie model

NHTSA and EPA Pre-Decisional Deliberative Materials for Interagency Review – Do Not Cite, Quote, or Rele
Vehicle Maintenance & Repair Costs 

NPRM 

• Maintenance costs/savings were not included in 

NPRM analysis.

▫ We noted areas where maintenance costs and sav

possible but not quantified and requested comme

• Warranty repair costs were included during the w

period as a component of the indirect cost multinot for the post-warranty period in the NPRM.

• The NPRM stated that there is a great deal of un

surrounding repair costs and that they were not in the modeling. NHTSA requested comment on repair costs might be quantify in the final rule.

NHTSA and EPA Pre-Decisional Deliberative Materials for Interagency Review – Do Not Cite, Quote, or Rele
Vehicle Maintenance & Repair Costs 

Public Comments

• One substantive comment on operating 

maintenance costs, from the National AutomDealers Association (NADA)

▫ Payback analysis should include finance, oppo

and additional maintenance costs.

▫ The final rule should evaluate the potential im

a vehicle’s total cost of ownership.

▫ NADA cited their web site as providing inform

regarding these costs, which also includes rep

NHTSA and EPA Pre-Decisional Deliberative Materials for Interagency Review – Do Not Cite, Quote, or Rele
Vehicle Maintenance & Repair Costs 

• Agencies performed a detailed review of existing owners manuals ma

requirements for a large number of vehicles with and without specific technologies

▫ For example, gasoline vehicles with and without turbochargers; gasoline ve

versions of the same vehicle model, gasoline and hybrid versions of the sammodel. We have used these to estimate changes in maintenance costs (laba number of technologies. 

• In general we were not able to find similar data regarding potential ch

repair costs.

Approach for final rule• Maintenance costs to be included in all aspects of the analysis (BCA, p

▫ Low rolling resistance tires, diesel fuel filters, and many EV costs/savings (n

filter changes, etc.)

• Warranty repair costs during the warranty period will be included, bu

warranty period repair costs will not be included. 

• EPA will discuss repair costs in the RIA but, due to lack of data, will no

▫ Examples with some level of supportive information will be provided for ho

may increase or decrease in the future.

• NHTSA will include sensitivity case analysis of post-warranty period re

using the same repair costs that are used for the in-warranty period 

NHTSA and EPA Pre-Decisional Deliberative Materials for Interagency Review – Do Not Cite, Quote, or Rele
Vehicle Simulation Work from NHTSA Contra

Argonne National Laboratory (ANL)

• DOT contracted with ANL to provide full vehicle simulatio

modeling support. Modeling was not completed in time the NPRM, and NHTSA discussed in the NPRM its intentioANL modeling to validate/update technology effectivenesestimates and synergy factors for the FRM.

• The ANL simulation model is used by OEMs, suppliers, go

agencies, universities, and research organizations

• Simulation results were completed for transmission, 

electrification/hybrid, vehicle technologies (e.g. mass redaero) and most engine technologies.

• Mild hybrid results and transmission results incorporated 

rule effectiveness values.

• Other results may be used for the mid-term analysis

NHTSA and EPA Pre-Decisional Deliberative Materials for Interagency Review – Do Not Cite, Quote, or Rele
Learning Curve Assumptions – NP

• Both agencies applied the same learning curve assum• One learning curve – technologies (i.e., their costs) l

somewhere on that curve, either the steep portion oportion of the curve

• Nearly all technologies considered to be on the flat p

the curve in the 2017-2025 timeframe

• Those on the steep portion in the 2017-2025 timefra

▫ Batteries▫ Lower rolling resistance tires level 2▫ In-home EV/PHEV chargers▫ Alternative refrigerant 

NHTSA and EPA Pre-Decisional Deliberative Materials for Interagency Review – Do Not Cite, Quote, or Rele
Learning Curve Assumptions – Public 

Comments and Final Rule

Public comments• No comments specific to our learning curve c

reduction approach or estimates.

Final rule• Agencies will use same approach for estimat

manufacturing learning-by-doing cost reductwas done in the proposed rule 

NHTSA and EPA Pre-Decisional Deliberative Materials for Interagency Review – Do Not Cite, Quote, or Rele
VMT Projections -- NPRM

• VMT schedules (per vehicle by MY and age) 

developed so that total NPRM VMT was conswith AEO 2011

VMT distribution by age from National Househ

▫

Travel Survey (NHTS) 2001

▫ Vehicle survival rates from Polk NVPP▫ Growth in per-vehicle VMT schedule back-calc

to make total VMT consistent with AEO 2011

NHTSA and EPA Pre-Decisional Deliberative Materials for Interagency Review – Do Not Cite, Quote, or Rele
VMT Projections– Public Commen

• No public comments submitted on this topic.• Updates to NHTS, AEO, and Polk data available between p

and final rule

• AEO 2012 VMT projection is significantly lower than AEO 

projection

NHTSA and EPA Pre-Decisional Deliberative Materials for Interagency Review – Do Not Cite, Quote, or Rele
VMT Projections -- FRM

• Updated to AEO 2012 total VMT estimates

▫ Updated to 2009 NHTS for estimates of averag

by age

▫ Incorporated EIA data on fleet vehicle sales wi

data on household vehicles to develop VMT esfor entire fleet

▫ Updated survival rates to incorporate Polk reg

data for 2007-2010

• Adjusted per-vehicle VMT growth to correspond to 

2012

NHTSA and EPA Pre-Decisional Deliberative Materials for Interagency Review – Do Not Cite, Quote, or Rele
VMT Rebound -- NPRM

• The agencies estimated a 10% VMT rebound effect for the 

analysis

▫ Consistent with 2012-2016 rule and TAR▫ Not derived from a single estimate or particular study, but in

represents a compromise between historical estimates and pfuture estimates

• We sought comment on new data and analysis, including 

▫ Potential that the actual rebound effect could be lower than 

in the literature if drivers respond more to changes in fuel prfuel efficiency, price rises vs. decreases, and price shocks vs. changes 

 There is some evidence of these types of asymmetric consum

responses in the literature

▫ Assumption that rebound effect estimates for conventional v

also apply for vehicles that use grid electricity

NHTSA and EPA Pre-Decisional Deliberative Materials for Interagency Review – Do Not Cite, Quote, or Rele
VMT Rebound – Public Comment

• International Council for Clean Transportation s

we should rely solely on projected estimates thaaccount for future incomes and fuel prices 

▫ These estimates tend to be lower than 10% for th

covered by the rule

• Consumer Federation of America suggested usin

and not including rebound effect in “consumer pocketbook” analysis

• Defour Group suggested using 20% or higher

NHTSA and EPA Pre-Decisional Deliberative Materials for Interagency Review – Do Not Cite, Quote, or Rele
VMT Rebound -- FRM

• We will continue to use 10% in our central an

▫ NRPM rationale is still acceptable; commenter

provide persuasive new evidence

▫ No response to our request for comment on 

data/analysis regarding potential asymmetric consumer responses or the assumption that threbound effect for conventional and electric-pvehicles is the same

• Each agency will also include sensitivity analy

using values on either side of 10%, as in the N

NHTSA and EPA Pre-Decisional Deliberative Materials for Interagency Review – Do Not Cite, Quote, or Rele
Explicit modeling of cost and benefit 

impacts of incentive and credit provi

• For the NPRM, agencies proposed a number of incen

credit provisions

▫ Off-cycle technology credits, including a pre-defined lis▫ Incentive credits for advanced technology full-size pick▫ Multipliers for use of EV/PHEV/Fuel cell vehicles (EPA o

• The agencies estimated the increase in CO2 and fuel

consumption due to the potential use of the EV/PHEvehicle multipliers and the full-size pickup truck incewe were not able to estimate their impact on costs.

• For the final rule, the agencies plan to include estim

both the costs and benefits of these incentives, as wimpacts of several of the off-cycle technology credits

NHTSA and EPA Pre-Decisional Deliberative Materials for Interagency Review – Do Not Cite, Quote, or Rele
Probabilistic uncertainty analysis o

and benefits - NPRM

• Both agencies analyzed the sensitivity of a number of benefits a

variation in the values of certain assumptions and inputs, includfollowing:

▫ NHTSA – discount rates, fuel prices, SCC, rebound effect, consumers

fuel economy benefits, military security, battery costs, mass reductiomarket-driven fuel economy improvements (sometimes referred to over compliance), and the indirect cost markup factor 

▫ EPA – SCC, discount rates, rebound effect, battery costs, mass reduc

indirect cost markup factor, and the cost learning curves

• NHTSA also performed a probabilistic uncertainty analysis exam

simultaneous variation in the major model inputs including techtechnology benefits, fuel prices, the rebound effect, and military costs. 

▫ EPA referenced this analysis in the NPRM as generally reflective of th

present in the EPA assessment

NHTSA and EPA Pre-Decisional Deliberative Materials for Interagency Review – Do Not Cite, Quote, or Rele
Probabilistic uncertainty analysis of c

and benefits– Public comments and F

Public Comment• No comments directly on NHTSA’s probabilistic uncertainty analysis• Bastani, et. al (MIT) submitted probabilistic analysis using stochastic model indicatin

likelihood that standards will be achieved. 

▫ Analysis was not a formal quantitative analysis of the relevant uncertainties abo

costs, more about trying to predict manufacturer behavior in meeting the standuncertainty surrounding various parameters (tech effectiveness, fuel prices, demdeployment of new tech and alt fuels), argues for accounting for uncertainty whfuture fleet. 

Final Rule

• NHTSA – Similar approach to the NPRM. 

Will conduct additional sensitivity analyses: post-warranty repair costs, transmission shif

effectiveness based on Argonne National Laboratory modeling, social cost of non-CO2 GH(CH4 and N2O)Probabilistic uncertainty analysis will be similar to the NPRM.

• EPA – similar approach to that used in the NPRM, we will include a number of sensitivity 

appropriate point to the NHTSA Monte Carlo analysis as generally representative.

NHTSA and EPA Pre-Decisional Deliberative Materials for Interagency Review – Do Not Cite, Quote, or Rele
Other inputs that are changing betwe

NPRM to FRM

• Fuel prices updated to AEO 2012 early release• Analysis of two baselines:

▫ NPRM’s 2008 baseline fleet with CSM projections market sh

mix, and AEO 2011 sales volumes and car/truck split

▫ New 2010 baseline fleet with JD Powers projections of mark

share/model mix, and AEO 2012 sales volumes and car/truc

• Energy security benefits updated based on AEO 2012 ear• Electricity upstream emission factors

▫ NPRM based on national average IPM estimate▫ NHTSA FRM using mix based on NEMS modeling (consistent 

2012 early release). Will include a primary analysis, and sencases in the EIS using upper and lower bound estimates. 

▫ EPA FRM using marginal estimate based on updated IPM mo

• Social cost of carbon – continue to use inter-agency value

monetize CO2 for primary benefits analysis, but for non-Cshow side analysis based on GWP-weighted approach.

NHTSA and EPA Pre-Decisional Deliberative Materials for Interagency Review – Do Not Cite, Quote, or Rele
Appendix

NHTSA and EPA Pre-Decisional Deliberative Materials for Interagency Review – Do Not Cite, Quote, or Rele
Manufacturers

• Broad support for the standards reiterated by OEMs who signed July support letters• Of larger manufacturers, VW & Mercedes argue that passenger car standards are rel

stringent and a slower ramp-up is needed; light truck standards too lenient.

• Several limited-line, intermediate volume manufacturers suggested additional leadti

concepts

• Nearly all OEMs and associations stressed importance of mid-term review due to lon

standards and uncertainty in assumptions

Environmental Groups

Overview of Key Comments, cont

• Most national NGOs support overall scope of the proposal – but many recommendat

benefits not eroded

• Concerned with treatment of trucks relative to cars; midterm should not result in rel

standards; need for backstop standards

• Center for Biological Diversity provided comments that proposed standards do not g

(recommended 60-70 mpg in 2025)

Public

• At hearings, numerous enviro/health/faith/veterans groups and ~300 individuals tes

program. Themes:

▫ Need to address climate change, energy independence, national security▫ Ensure final standards don’t include “loopholes” to weaken benefits▫ Money saved at pump helps consumers’ pocketbooks & can be reinvested in local eco

▫ Standards can spur innovation & create jobs

NHTSA and EPA Pre-Decisional Deliberative Materials for Interagency Review – Do Not Cite, Quote, or Rele
National Automobile Dealers Association (NADA)

• Commented there is no need to set 2025 standards so far in advance -- 

wait to conduct rulemaking in 2014 and set standards for MY2017-2021need not set standards because NHTSA can achieve similar benefits undprogram

• Commented the agencies’ cost projections are significantly underestima• Concern that lower income consumers will not be able to secure a loan 

out of new car market, delaying GHG and oil saving benefits

Overview of Key Comments, cont

• Commented the agencies’ analyses should include operating costs• Commented EPA significantly underestimated cost of HD engine emissio• Encouraged agencies to provide better consumer information on paybac

label)

Consumer Groups• Commented consumers will benefit greatly from standards – consumers 

and decrease the cost of driving; increased consumer vehicle choices wimore fuel efficient and alternative fuel options

• Commented dealers’ concerns are unfounded -- independent analysis a

survey demonstrate strong consumer support across all income levels

NHTSA and EPA Pre-Decisional Deliberative Materials for Interagency Review – Do Not Cite, Quote, or Rele
• State organizations (NACAA and NESCAUM) supported th

and its significant benefits

▫ Concern that the less-stringent standards for trucks could unde

benefits, if fleet shifts from cars to trucks. 

▫ NESCAUM (Northeast states) also believes we should consider 

reduction -- viable to push the fleet to increase EV/PHEVs

Overview of Comments, continue

• UAW expressed strong support -- believes program will le

significant net job creation

• Fuel providers commented that EPA should provide incen

various alternative fuels, such as biofuels and CNG

• Letters of support from 30 U.S. Senators (Feb. 15) and 48 

Representatives (Nov. 15)

NHTSA and EPA Pre-Decisional Deliberative Materials for Interagency Review – Do Not Cite, Quote, or Rele