XlhybndS" 

August 18, 20 15 

Environmental Protection Agency 

Air and Radiation Docket and Information Center (6 1 02T) 

1200 Pennsylvania A venue NW 

Washington, DC 20460 

XL Hybrids, Inc. 

145 Newton Street 

Boston, MA 02135 

RE: EPA/NHTSA Heavy-Duty Greenhouse Gas Emissions and Fuel Efficiency Phase 2 Draft 

Rules (EPA Docket ID No. EPA-HQ-OAR-2014-0827) 

Dear Sir/Madame, 

At XL Hybrids we are very appreciative of the efforts of the federal government team in 

developing the Phase 2 draft rules and agree with the basic principles and structures that have 

been proposed, and as currently proposed, we support the preferred alternative. 

By way of introduction, XL Hybrids is currently a leading fleet electrification company in the 

U.S. with, as of May 20 15, over 12 Million fleet customer miles per year driving our products 

across North America. Our core hybrid electric upfit products for Class 2 to 6 vehicles provide 

roughly 20% fuel and proportional C02 savings. Our success to-date is because of two important 

factors: 

I. XL Hybrids does not significantly alter the major OEM vehicle and powertrain, and so 

major fleets can buy and service major OEM vehicles without any changes 

2. XL Hybrids price point is under $10,000 for a Class 2B hybrid electric full size van, and 

proportionally higher for larger vehi cles which has attractive payback for fleets that have 

considerable lifetime vehicle mileage utili zation. 

In this context, XL Hybrids has both expertise and a stake in these rules as they apply to heavyduty trucks and vans and vocational vehicles, and have the following additional comments and 

recommendations: 

I. We recommend improvements to the hybrid electric battery cost models. 

The learning curve cost models in the RIA Table 2- 100 for mild and strong hybrids do not 

account for the highly specialized manufacturing costs and scaling that is unique to the lithium 

battery market. We suggest that models that take into account industry, market study, and 

national lab modeling for cost and scale specific to the materials and processes used in the 

manufacture of lithium batteries is more appropriate here. Likewise projections should include 

calculations of total MWh purchased by single vehicle manufacturers and well as produced by 

single battery manufacturers as these will both influence scaling. 

2. The projected incremental costs for HD Pickup and Van strong and mild hybrids are too 

low. 
The HD Pickup and Van Strong and Mild Hybrid costs projected in RIA Tables 2-179 and 2-183 

are based on weight seati ngs from LD that do not adequately account for production volume 

differences between the LD and HD sector. By contrast we feel the vocational cost targets are 

reasonable because the weight scaling becomes a more significant factor. 

3. We recommend expanding the trading compliance paths for additional flexibility to allow 

major OEMs to take advantage of the fuel and emissions savings technologies deployed 

by 3rd party upfitters. 

After a complete roadworthy HD vehicle is produced through a multi-manufacturer process, 

many vehicles undergo additional modifications by 3rd party companies that install systems that 

further reduce fuel consumption and emissions some of which are mentioned in the RlA Table 2-

49. Ford Motor Company alone attributes the introduction to the marketplace of more than 

50,000 advanced technology medium/heavy duty vehicle solutions through 3rd party companies 

adding equipment to Ford vehicles that wouldn't necessarily fit the draft rules definition of 

delegated assembly. While the EPA and NHTSA are regulating the primary manufacturers, we 

do not believe the departments are prevented from measuring and assigning credits to 3rd party 

products that produce measureable robust savings that then could participate in an ABT credit 

marketplace. ln XL Hybrids current business model our savings would primarily benefit just end 

fleets when they could also be contributing in Phase 2 regulation goals. The benefits to the public 

would be a more market driven process resulting in faster introduction of advanced savings 

technologies, and the potential for achieving greater reductions. We recognize that structuring, 

validating, and deploying such a credit system would be challenging but we ask that the rules be 

modified to specifically allow for such a possibility so that a program can be developed. 

We are open to discussing our recommendations further at any time. 

Also on Table 2-49 we can offer the following corrections. Our business name is XL Hybrids 

(not XL) and our products are Strong Hybrids from Class 28 to 6 for delivery and service vans 

and trucks, and shuttle busses. 

Sincerely, 

Edward Lovelace 

ChiefTechnology Officer 

e love lace@.x I hybrids.com 

617-718-0329 x iOI