Jensen Reporting 312-236-6936

 ENVIRONMENTAL PROTECTION AGENCY 

 and 

NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION 

 PUBLIC COMMENT SESSION 

 ON PROPOSED FUEL ECONOMY LABELS 

 THE WYNDHAM HOTEL 

 633 NORTH ST. CLAIR STREET 

 CHICAGO, ILLINOIS 

 OCTOBER 14, 2010 
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1 GOVERNMENT PANEL: 

2 MR. RON MEDFORD 

 MS. SARAH DUNHAM 

3 MR. STEVE WOOD 

4 SPEAKER PANELS: 

5 MR. GIEDRIUS AMBROZAITIS 

 MR. LUKE TONACHEL 

6 MR. RON MINSK 

7 MR. DESMOND ROBERTS 

 MR. PETER ZALZAL 

8 MS. ROBIN ECKSTEIN 

9 MR. FRANK SZOLLOSI 

 MR. JACK DARIN 

10 

 MS. DEBBIE BAKKER 

11 MR. EDWARD OSER 

12 MS. LAURA KNEZEVIC 

 MS. LUCINDA HOHMANN 

13 

 MR. SCOTT BECKER 

14 MR. MIKE DUOBA 

 MR. DENNIS R. NELSON 

15 

16 

17 

18 

19 

20 

21

22

23

24
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1 MR. MEDFORD: Good afternoon. Welcome to the 

2 public comment session regarding the Department of 

3 Transportation and the Environmental Protection Agency 

4 proposal for revisions for the fuel economy label 

5 found on all the new vehicles sold in the United 

6 States. I'm Ron Medford, the Deputy Administrator of 

7 the National Highway Traffic Safety Administration. I 

8 would like to thank you for taking your time out of 

9 your busy schedules today to attend and express your 

10 views about this very important topic. 

11 Earlier this year the Department of 

12 Transportation and the Environmental Protection Agency 

13 partnered to revise the widely known fuel economy 

14 label pasted on the window of your new vehicles on the 

15 lots of automobile dealers around the nation. We're 

16 revising the label jointly to not only continue our 

17 collaborative efforts demonstrated between EPA and 

18 NHTSA by our national program of fuel economy and 

19 greenhouse gas standards, but to address the specific 

20 mandate of the two agencies regarding fuel economy 

21 labeling and emissions information on new vehicles at 

22 the point of sale. 

23 The Department of Transportation has 

24 Congressional direction to give people the specific 
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1 informational tools they need to make clear and 

2 informed decisions regarding fuel economy, greenhouse 

3 gas, and smog emissions when making a vehicle purchase 

4 decision. Concurrently, the Environmental Protection 

5 Agency is faced with the challenge of reporting 

6 accurate consumption information associated with both 

7 electric only and a combination of electricity and 

8 gasoline to address the anticipated market entry of 

9 advanced technology vehicles such as plug-in hybrids 

10 and battery electric vehicles. 

11 As directed by the Energy Independence and 

12 Security Act of 2007, the Department of Transportation 

13 in consultation with the Department of Energy and the 

14 Department -- and the Agency of EPA is required to 

15 implement rating scales for fuel economy, greenhouse 

16 gas, and smog-producing emissions across the entire 

17 vehicle fleet. 

18 In addition, the scales need to be given 

19 clear indication of the best and worst performance for 

20 fuel economy and greenhouse gas emissions. As part of 

21 this Act, Congress entrusted the American people armed 

22 with specific information regarding these automobile 

23 components to exercise their independent judgment in 

24 moving toward a secure and energy-independent future. 
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1 As evidenced on the co-proposed labels, in 

2 the form of what we call "slider bars", the Department 

3 of Transportation reached across agency boundaries to 

4 efficiently and clearly incorporate a Congressional 

5 direction as a part of the label revision to the 

6 benefit of the American public and manufacturers 

7 versus taking a separate path requiring a separate 

8 label containing this information. 

9 In addition to myself and our EPA 

10 colleague, I am accompanied today by Steve Wood who's 

11 the assistant chief counsel for the National Highway 

12 Traffic Safety Administration. Also, some important 

13 points to note regarding the proposal we're making. 

14 The commentary period to the proposal ends on 

15 November 22nd. Your testimony today will be 

16 transcribed and entered into both EPA and NHTSA 

17 dockets open for this rulemaking. We also encourage 

18 you to provide any materials which are not considered 

19 confidential business information which may support 

20 your testimony for submission to the docket. 

21 Information for materials for the submission docket, 

22 identification, and agency contacts can be found in 

23 the proposal. 

24 Again, on behalf of the Department of 
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1 Transportation and the National Highway Traffic Safety 

2 Administration, we truly appreciate the effort you 

3 expended to be here today and look forward to hearing 

4 your important views on the proposed revisions of the 

5 fuel economy label. Now, I'd like to introduce my 

6 colleague, Sarah Dunham. 

7 MS. DUNHAM: Thank you very much. Good 

8 afternoon. Welcome to all of you in Chicago as well 

9 as those listening by phone. My name is Sarah Dunham, 

10 I'm the director of EPA's Transportation and Climate 

11 Division, and I'm pleased to be one of the presiding 

12 officers for today's meeting along with my colleague 

13 Ron Medford of DOT'S National Highway Traffic Safety 

14 Administration. 

15 As my colleague mentioned, on August 30th 

16 EPA and NHTSA proposed the most dramatic overhaul of 

17 the fuel economy label since its inception over 30 

18 years ago. There were two main drivers for this 

19 action that I'll mention. One was the new statutory 

20 requirements with the 2007 Energy Law put in place 

21 requiring additional labeling requirements that 

22 included rating vehicles according to fuel economy and 

23 greenhouse gas emissions and smog performing 

24 pollutants. 
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1 Secondly, a new generation of advanced 

2 technology vehicles, including electric vehicles and 

3 plug-in hybrids will soon be widely available, so we 

4 need a label that will help consumers make 

5 straightforward comparisons across all different 

6 vehicle types. 

7 I do want to mention and highlight here at 

8 the beginning that in developing these proposed labels 

9 EPA and NHTSA undertook far-reaching and extensive 

10 research. This included holding more than 30 focus 

11 groups across the nation. We also convened a panel of 

12 innovators nationally known for their expertise in 

13 communicating product and health-related information 

14 to consumers. 

15 As you know, and as Ron mentioned, we put 

16 out two label designs for comments. Both labels 

17 include similar information but the design is 

18 different. Both labels include similar information, 

19 but we did not favor one over the other. Rather, 

20 these two distinctly different designs were intended 

21 to spur discussion and input about what kind of 

22 approach is most useful to consumers, while 

23 enabling EPA and NHTSA to comply with what the law 

24 requires. 
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1 There's clearly a lot to comment on and I'm 

2 sure we'll hear a number of comments throughout the 

3 day from various perspectives, and we're looking 

4 forward to hearing those. In addition to today's 

5 public hearing, we will hold another hearing next 

6 Thursday in Los Angeles and we will accept written 

7 comments, as Ron mentioned, until November 22nd, 2010. 

8 We are aiming to complete the rule in time for the new 

9 label to appear on the windows of most 2012 model year 

10 vehicles. 

11 Now, let me briefly go over how we plan to 

12 hold today's hearing. This afternoon's session is 

13 scheduled to run until about 4:00 p.m., and then we 

14 will reconvene again for an evening session beginning 

15 at 6:00 p.m. this evening. If anyone here wishes to 

16 testify and has not already signed up, please do so at 

17 the reception table outside this room. 

18 Due to the number of people testifying 

19 today, we are asking that each person keep their 

20 testimony to no more than ten minutes. We will be 

21 using panels to speed up the process, and a list of 

22 panel members and their order are available at the 

23 reception table. If we get additional sign-ups today, 

24 we will fill them in as people come in and as time is 
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1 available throughout the afternoon. When the 

2 witnesses on a panel have finished, those of us on the 

3 government panel will have the opportunity to ask 

4 questions. 

5 The hearing will be conducted informally 

6 but formal rules of evidence -- and formal rules of 

7 evidence will not apply. The presiding officers, 

8 however, are authorized to strike statements from the 

9 record which are deemed irrelevant or needlessly 

10 repetitious and to enforce reasonable limits on the 

11 duration of the statement of any witness. 

12 I'm going to end the formal part of this -- 

13 my statements here. I do want to thank you again, 

14 everybody, for joining us here today and throughout 

15 the afternoon and evening. And with that, I would 

16 like to call the first panel of witnesses up so if the 

17 panel, the first three, could please all join us up 

18 here. I'll announce their names, and I am going to 

19 apologize in advance for mispronouncing some people's 

20 names. I should have figured this out ahead of time. 

21 Sorry. 

22 So first panel -- I am going to apologize 

23 right off the bat. Giedrius Ambrozaitis from the Auto 

24 Alliance, please join us, Luke Tonachel from NRDC, as 
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1 well as Ron Minsk from the Electrification Coalition, 

2 please join us up here. 

3 I will ask that each of you will make your 

4 remarks in the order in which I announced your names, 

5 so that would be Giedrius first, Luke, and then Ron 

6 third. 

7 MR. AMBROZAITIS: Good afternoon. Thank you very 

8 much. First off, I thought there was going to be a 

9 projector, so I brought some slides and I gave these 

10 as handouts to follow with my testimony. It has a 

11 couple of points that I'll be following with my 

12 testimony. 

13 My name is Giedrius Ambrozaitis, and I am 

14 here today representing the Alliance of Automobile 

15 Manufacturers. The Alliance is an association of 12 

16 vehicle manufacturers representing 77 percent of all 

17 car and truck manufacturers in the United States, 

18 including BMW Group, Chrysler Group LLC, Ford Motor 

19 Company, General Motors Company, Jaguar Land Rover, 

20 Mazda, Mercedes-Benz USA, Mitsubishi Motors, Porsche, 

21 Toyota, Volkswagen Group of America, and Volvo. My 

22 testimony today will address our initial public 

23 positions in response to the EPA and NHTSA rulemaking 

24 to modify today's fuel economy label. 
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1 Automakers support the general need for new 

2 labels and to address advanced technology vehicles 

3 such as plug-in electric vehicles and battery electric 

4 vehicles. We agree with EPA and NHTSA in that 

5 consumers should have access to clear and accurate 

6 information about their vehicles. Currently our 

7 members provide detailed and comprehensive information 

8 on their vehicles through a full suite of 

9 customer-oriented materials, including interactive Web 

10 sites, innovative new media, and traditional 

11 materials. We have learned over time that most 

12 consumers do Internet research before visiting an auto 

13 dealer. In fact, 70 percent of consumers surveyed by 

14 EPA had a specific type of vehicle in mind when they 

15 started looking for a new vehicle, and the majority of 

16 those, 81 percent, said they ended up purchasing that 

17 type of vehicle. 

18 With regard to the proposed rule, I will 

19 briefly comment on five key issues: The two primary 

20 options for the label design, whether to include 

21 upstream emissions on the label, the need for 

22 additional label lead time, vehicle comparison through 

23 fleet segmentation, and our shared vision of a single 

24 national label. 
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1 First issue, labeling options. The 

2 Alliance supports a more traditional label such as the 

3 proposed Label 2. The responses from the EPA focus 

4 groups point toward this option as a logical evolution 

5 of the current label design. This label provides more 

6 visible data on fuel economy, a metric that consumers 

7 are used to and allows for objective comparisons 

8 within each vehicle class. Some of the major 

9 manufacturers have also conducted their own focus 

10 groups, the results of which have been shared with 

11 EPA, which support the more traditional label. 

12 To the contrary, Label 1 obfuscates the 

13 information consumers most need and rely on in 

14 purchasing decisions. The letter grade format 

15 indirectly focuses attention on a single attribute, 

16 CO2, while ignoring other consumer needs like towing 

17 capacity, safety, comfort, cost, and reliability. 

18 Consumers will confuse the letter grade with overall 

19 vehicle quality or even safety. Moreover, the A, B, C 

20 system is skewed toward electric vehicles while 

21 penalizing worthy advanced technology vehicles in 

22 other categories. 

23 We understand that the letter grade option 

24 was not presented to any of the focus groups whose 
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1 responses formed the basis for this rulemaking but 

2 that EPA is in the process of conducting a Web-based 

3 survey of the proposals. We look forward to reviewing 

4 the results of the Web-based survey and encourage EPA 

5 to make these available well in advance of the comment 

6 deadline. We should note that other recent surveys 

7 including those conducted by Edmunds.com and by Siegel 

8 & Gale indicate that a large majority of consumers 

9 prefer the more traditional label. 

10 Second issue, Upstream Emissions. We agree 

11 with EPA and NHTSA's recommendation that upstream 

12 emissions not be included in the fuel economy label. 

13 This is a confusing concept that will be difficult to 

14 explain in a limited amount of space such as a label. 

15 It involves a complex mix of factors that auto 

16 manufacturers have no way of predicting or 

17 controlling, including the electric energy mix of a 

18 particular geographic region and how much and how 

19 vehicles are driven. This does not mean that 

20 consumers should be unaware of upstream emissions. We 

21 plan to provide constructive input into the design of 

22 the online upstream emissions calculator when we 

23 submit our written comment. 

24 Third issue, Lead Time. The automakers 
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1 require certain significant lead time to implement the 

2 vast changes proposed, which will not even be 

3 finalized until January 2011. Manufacturers cannot 

4 possibly develop the systems to collect and manage the 

5 new information required, redesign the Monroney label, 

6 develop new software to implement the new label 

7 requirements, validate the software and the label 

8 designs, and then work with suppliers to procure 

9 labels in the time frame being considered. The 

10 complexity of color adds another dimension to our lead 

11 time concerns because of the facility changes at 

12 factories and ports and the throughput limitations of 

13 color printers. 

14 A fourth issue, Vehicle Comparisons. 

15 Consumers are very targeted when buying a new vehicle. 

16 They look for vehicles that meet their needs within 

17 specific vehicle segments, like mid-size sedans or 

18 minivans. To make the labels useful, fuel economy 

19 ratings or any type of comparative type of measure, 

20 for that matter, should be based on and shown within 

21 vehicle segments. 

22 And our fifth issue, The Need for a Single 

23 National Label. Over the past few years, automakers 

24 have worked closely with the Administration and the 
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1 California Air Resources Board to bring about a single 

2 national program for fuel economy and greenhouse 

3 gases. For consistency, this single national approach 

4 should carry through to the labeling requirements as 

5 well. However, as this slide demonstrates -- this is 

6 our second slide, which shows a side window of a car 

7 and it has five labels on it, completely covering the 

8 windows. As this slide illustrates, automakers are 

9 required to apply several labels with redundant 

10 information. We encourage EPA and NHTSA to coordinate 

11 their efforts on this rulemaking with FTC and 

12 California. 

13 Thank you for this opportunity to testify. 

14 I'll be happy to take some questions. 

15 MS. DUNHAM: Thank you. Luke Tonachel. 

16 MR. TONACHEL: Good afternoon. Thank you for the 

17 opportunity to testify today on this joint proposed 

18 rule. My name is Luke Tonachel, and I'm a senior 

19 analyst with the Natural Resources Defense Council's 

20 Transportation Program. I represent NRDC and our 

21 1.3 million members and activists in supportive 

22 efforts to improve the fuel economy label for new cars 

23 and light trucks beginning in model year 2012. 

24 NRDC supports changes to the label that 
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1 provide consumers with easy-to-understand information 

2 on the environmental and petroleum consumption impacts 

3 of different vehicle choices. Armed with this 

4 information, car and truck buyers can make informed 

5 buying decisions based on knowing which vehicles are 

6 the best for the environment and save the most money 

7 at the pump while meeting their personal 

8 transportation needs. 

9 NRDC believes that there's five principles 

10 that should be followed to make the label most useful 

11 for consumers and to help pave the way for broader 

12 adoption of clean advanced vehicle technologies. 

13 First, the label should include a prominent and simple 

14 letter grade system. Second, the letter grade system 

15 must be based on a single scale that encompasses the 

16 performance of all light duty vehicles. Third, the 

17 vehicle greenhouse gas emissions should serve as the 

18 primary vehicle performance indicator. Fourth, 

19 operational cost metrics should be included. And, 

20 fifth, the label should include fuel consumption 

21 metrics as well. I'll describe each of these 

22 principles in greater detail. 

23 Number 1, the letter grade system 

24 simplifies comprehension of multiple performance 
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1 factors. Letter grades boil down global warming 

2 pollution and fuel consumption into a single metric 

3 that everyone understands. Experts tell us to keep it 

4 simple. The government agencies commissioned a panel 

5 of impartial consumer experts to help design the 

6 label. Many versions were tested and discarded. 

7 Business experts involved in the launch of successful 

8 products and services like the iPod, Dove soap, and 

9 craigslist.org tell us that consumers act on impulse, 

10 not details. The grading system is what they 

11 overwhelmingly recommended. 

12 The simplicity of the letter grade means 

13 that the pollution and fuel consumption information 

14 can be used early in the buying process. Buyers often 

15 start their new vehicle search by considering a range 

16 of vehicle types and models. By having a metric as 

17 simple as a letter grade, it is easy for buyers to use 

18 this information to quickly compare the performance of 

19 a wide variety of vehicle types early in the buying 

20 process. 

21 The letter grade is also good for 

22 automakers that choose to compete to produce the 

23 cleanest and most efficient vehicles. The grade 

24 clearly differentiates advanced technology vehicles 
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1 with low emissions which enables automakers to better 

2 market these relatively unfamiliar vehicles. 

3 We know that the auto companies are gearing 

4 up to supply more advanced technology vehicles to the 

5 market. According to a recent analysis by auto market 

6 expert Alan Baum, the number of hybrid, plug-in 

7 hybrid, electric, and fuel cell models are forecast to 

8 more than quadruple over the next five years. The 

9 letter grade will clearly show how these clean 

10 technologies rank among other vehicles, which can help 

11 drive consumers to purchase them, ultimately helping 

12 to reduce the risks that automakers take in 

13 introducing them. 

14 Secondly, a single scale allows for 

15 comparison across all vehicle types. The letter grade 

16 system should be based on a single rating scale for 

17 all light duty vehicles so consumers have clear 

18 information about the environmental and energy 

19 performance of the full range of vehicles available to 

20 them. According to a survey of vehicle shoppers by 

21 the EPA and the Department of Transportation, and I'm 

22 quoting, "More than half, or 53.6 percent, compared 

23 two or three vehicles before making their final 

24 decision." And, when it came to the types of vehicle 
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1 seriously considered, more than three-fifths, or 62.8 

2 percent, considered more than one vehicle type with a 

3 third, 32.9 percent considering two vehicle types and 

4 another fifth, 19.7 percent, considering three vehicle 

5 types. 

6 Consumers are likely to consider multiple 

7 vehicle models and types, including both cars and 

8 trucks, because there are several models that meet 

9 their size requirements. However, within the same 

10 size or footprint there's also a wide variety of 

11 efficiency and greenhouse gas emission levels. And 

12 I've shown this in a figure that came with the 

13 testimony that you should have received. Essentially, 

14 buyers are looking for vehicles that hold a certain 

15 number of people and an amount of cargo. I looked at 

16 vehicles of the same footprint and compared their fuel 

17 economy and found that fuel economy can vary 

18 dramatically, and there's some examples also in the 

19 testimony. I found that cars and trucks with the same 

20 footprint can vary by four grades levels or more. 

21 Having the same letter grade system makes it very 

22 clear which vehicles of varying types are most 

23 efficient with the same footprint size. 

24 Number 3, greenhouse gas emissions should 
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1 be the basis of the primary environmental performance 

2 rating. A primary advantage of relying on greenhouse 

3 gas emissions to rate vehicles is that it is 

4 independent of fueling technology and therefore 

5 enables a fair comparison across vehicles operating on 

6 different fuels. 

7 To be consistent across vehicles, the 

8 greenhouse gas labels should include at least the bulk 

9 of emissions that a vehicle's responsible for 

10 emitting. The proposal to label plug-in electric 

11 vehicles with zero grams of CO2/mi is confusing and 

12 the agencies should strongly consider a different 

13 approach. In the proposed rule, the agencies noted 

14 that focus group participants specifically pointed out 

15 that electric vehicles do cause emissions at the power 

16 plant and that those emissions should be represented 

17 on the label. By including the tailpipe emissions for 

18 combustion vehicles and the electricity production 

19 emissions for electric drive, the label would cover at 

20 least 75 percent of the total emissions that the 

21 vehicles of all types contribute to the atmosphere. 

22 Number 4, including the five-year 

23 operational cost eases vehicle comparisons. NRDC 

24 supports the inclusion of the five-year operational 
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1 cost comparison to the average vehicle of the full car 

2 and light truck fleet. Similar to the letter grade, 

3 the colored "spend and save" designations along with 

4 the actual monetary value are easy to understand and 

5 relieve the consumer from the complex task of doing 

6 cost calculations. It also allows consumers to see 

7 how their fuel savings can offset any incremental cost 

8 from purchasing a more advanced, cleaner vehicle like 

9 a hybrid. Because the five-year operational cost is 

10 presented simply, it can also be effective early in 

11 the vehicle purchase process when buyers are 

12 considering the largest varieties of vehicles. 

13 Number 5, fuel consumption should be 

14 emphasized on the label. The label should emphasize 

15 fuel consumption to avoid complications of what the 

16 agencies have called the MPG illusion, especially for 

17 petroleum-powered vehicles. Petroleum consumption 

18 continues to be at the forefront of the public concern 

19 due to its impact on U.S. economic and military 

20 security and should continued to be part of the 

21 vehicle labels. NRDC believes that a shift toward 

22 emphasizing the fuel consumption metric, in gallons 

23 per mile or gallons per 100 mile for petroleum fuels, 

24 for example, would give consumers a clear indication 
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1 of fuel demands when comparing vehicles of different 

2 efficiencies. 

3 In conclusion, a letter grade system that 

4 spans all vehicles on a single scale is an excellent 

5 step forward. It represents a new generation of 

6 labels for a new generation of clean, fuel efficient 

7 vehicles. The grade system design clearly and simply 

8 differentiates the cleanest vehicles across the whole 

9 spectrum of choices, whether consumers start their 

10 new vehicle search across multiple vehicle types or 

11 classes or just focus on a specific class. NRDC looks 

12 forward to expanding on the views expressed today in 

13 our written comments and to continue to engage with 

14 EPA and DOT as the process for finalizing the labels 

15 moves forward. Thank you. 

16 MS. DUNHAM: Thank you. Mr. Minsk. 

17 MR. MINSK: Thank you for the opportunity to 

18 testify today. My name is Ron Minsk. I'm Senior 

19 Vice-President for Policy at Securing America's Future 

20 Energy. 

21 SAFE is a non-ideological organization that 

22 advocates for policies to enhance the nation's energy 

23 and economic security by reducing its dependence on 

24 oil. SAFE employs innovative strategies, enlisting 
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1 the support of prominent business leaders and retired 

2 senior military officers to overcome political 

3 stalemates and policy stagnation. It is led by the 

4 Energy Security Leadership Council, a group of 

5 business executives and retired military leaders, 

6 co-chaired by General P.X. Kelley, 28th Commandant of 

7 the U.S. Marine Corps, and Frederick W. Smith, 

8 chairman, president, and CEO of FedEx Corporation. 

9 SAFE is closely affiliated with the 

10 Electrification Coalition, a nonpartisan, 

11 not-for-profit group of business leaders committed to 

12 promoting policies and actions that facilitate the 

13 deployment of electric vehicles on a mass scale in 

14 order to combat the economic, environmental, and 

15 national security dangers caused by our nation's 

16 dependence on petroleum. 

17 The views that I will express today reflect 

18 SAFE's current thinking. I want to emphasize, 

19 however, that we are both open-minded with respect to 

20 issues concerning the labels and eager to hear other 

21 parties' comments. Our final thoughts, which will be 

22 stated in our written comments, will reflect what we 

23 learn from other parties participating in the process. 

24 First, we have concerns about the letter 
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1 grading system that is used in the Label Design No. 1. 

2 Using a system that compares all vehicles 

3 against each other is inconsistent with the approach 

4 the government has taken in developing fuel economy 

5 standards. While updating fuel economy standards in 

6 recent years, the government adopted a vehicle 

7 attribute approach. That approach recognizes that not 

8 every vehicle can meet every driver's needs and seeks 

9 to promote the use of the most efficient vehicle that 

10 can meet a driver's particular needs. For instance, 

11 if one needs a minivan, it does not penalize the 

12 automaker or the consumer for producing or purchasing 

13 one, but encourages the automaker to make, and enables 

14 the consumer to purchase, the most efficient minivan 

15 possible. This attribute-based system was a response 

16 to concerns that CAFE standards were effectively 

17 pushing drivers into smaller cars that did not meet 

18 their needs. In sharp contrast to that approach, this 

19 letter grade compares every vehicle against every 

20 other vehicle, not just those in their class or with 

21 similar attributes. In doing this, the system 

22 promotes the most efficient vehicle whether or not it 

23 meets the driver's needs. We are concerned that this 

24 approach directly contradicts the approach in current 
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1 fuel economy standards. 

2 That concern that it is inappropriate to 

3 compare every vehicle against each other is compounded 

4 by the use of the letter grade system. The 

5 convenience of a letter grade system is that it's 

6 universally familiar. Its flaw is that it is value 

7 laden. Everyone understands that an A is good and a C 

8 is not. The system effectively tells people that if, 

9 for instance, you need a vehicle that can seat four or 

10 five children safely with a seat belt, for now based 

11 on current existing vehicles on the market, you cannot 

12 aspire for more than a B and you will have few choices 

13 that are better than a B-. We feel that such a system 

14 suggests that the government does not understand 

15 drivers' needs and that it is trying to push people 

16 into smaller cars. It is turning a label that used to 

17 convey only information into one that conveys moral 

18 judgments. 

19 That concern is further compounded by the 

20 fact that the only way to drive a vehicle that earns 

21 an A is to invest in cutting-edge technology, such as 

22 a grid-connected vehicle. While we're intensely 

23 dedicated to the deployment of such technology, we 

24 appreciate that it's new and relatively expensive, at 
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1 least in terms of the upfront costs. Early adopters 

2 should not be the only people able to buy cars with 

3 goods grades. Requiring the use of that technology to 

4 find a car with a good grade undermines system 

5 credibility. We don't want this label to suffer the 

6 same fate of the color-coded threat level system used 

7 by the Department of Homeland Security, which is 

8 universally regarded as irrelevant. 

9 We appreciate that the goal of using the 

10 single letter to convey the vehicle's overall 

11 performance is to simplify the complex. We do not, 

12 however, think that the underlying information is too 

13 complex and do not want it simplified to a single 

14 letter. We lose too much texture in doing so. We 

15 think we can use this as an opportunity to begin 

16 educating people about some of the complexities of the 

17 energy and environmental issues we face, which could 

18 help develop support for sound policies in this arena 

19 in the future. 

20 I'd also like to note that the rule 

21 language stated that a single grade for fuel economy 

22 and greenhouse gas emissions worked because, "vehicles 

23 that are low in CO2 have inherently good fuel 

24 economy," and, "CO2 emissions are the primary 
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1 determinant of fuel economy using EPA test 

2 procedures." That's not true, however, for 

3 grid-connected vehicles. They can, for instance, be 

4 relatively inefficient in their use of electricity yet 

5 powered, for instance, by wind and be entirely 

6 emission free. 

7 With respect to the reporting emissions in 

8 the vehicle label, we strongly support the decision to 

9 report only tailpipe emissions on the label. 

10 EVs have no emissions themselves, and the 

11 labeling program always has focus on the vehicle. 

12 It is nearly impossible to provide a single 

13 meaningful emissions number for each grid-connected 

14 vehicle. Emissions for a single vehicle will vary 

15 from utility to utility, based on the time of day at 

16 which the vehicle is charged and the type of power 

17 that the consumer purchases. They can even be 

18 emission free, not in a decade but even by the end of 

19 this year. They also will improve over time as the 

20 grid becomes cleaner. Remember, grid-connected 

21 vehicles are the only vehicles that will become 

22 cleaner as they become older as the grid improves. 

23 The carmakers cannot control the emissions 

24 attributes of a grid-connected vehicle because they 
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1 are dependent on the factors stated above. Therefore, 

2 it is inappropriate to imply the responsibility for 

3 emissions is attributable to the car when the carmaker 

4 can do nothing about them. 

5 Unlike a regulatory program that's intended 

6 to achieve broad goals and which can rely on averages 

7 across large numbers of vehicles, this labeling 

8 program is intended to inform a particular consumer 

9 about the performance of a particular vehicle, and 

10 that's important to keep in mind. 

11 Finally, we do not attribute upstream 

12 emissions from the use of other appliances to those 

13 appliances. No one attributes upstream emissions from 

14 an air conditioner to Carrier or from plasma 

15 televisions to Sony and Samsung. We don't think that 

16 the treatment of vehicles should depart from the 

17 common treatment afforded other devices that have only 

18 upstream emissions. 

19 The emissions and operating cost 

20 calculations on the Web site. I'm just going to 

21 mention one point here, and that is when you're 

22 calculating the carbon emissions, we believe that it's 

23 critical to use the average mix of generation 

24 resources in each state or region, not to rely on -- 
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1 I'm sorry. But you should rely on the marginal fuel 

2 that is most likely to be used to charge the vehicle. 

3 Such emissions profile of the average mix in a state 

4 may vary significantly from the emissions profile of 

5 the marginal kilowatt hour that's used to charge the 

6 vehicle. And we recommend looking at the work that 

7 was done in Oak Ridge National Lab, for instance, that 

8 has calculated this data in the past. 

9 The five-year operating cost. We believe 

10 that any vehicle label, no matter which design, should 

11 include information of the five-year operating cost or 

12 the difference in the five-year operating cost for the 

13 average vehicle. Consumers are notoriously bad at 

14 calculating payback on investments in energy 

15 efficiency. This information will help consumers 

16 understand that efficiency often pays for itself. 

17 Proving the data over a five-year period makes sense 

18 because it's the average length of time that first 

19 vehicle owners keep their car. 

20 The utility factors which are used to 

21 calculate the fuel consumption and electricity 

22 consumption of plug-in hybrids are also a concern to 

23 us. The utility factor is used to calculate how much 

24 of the energy used by PHEV comes from the grid and how 
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1 much comes from onboard fuel, and it's needed to 

2 accurately reflect how the cars will be used. If the 

3 factors are too low, they will overstate both 

4 emissions and operating costs. It's easy to fall back 

5 on the data and conclude that x percent of all drivers 

6 drive 100 miles a day so x percent of plug-in hybrid 

7 drivers will also drive 100 miles a day. We do not, 

8 however, believe that that is necessarily the correct 

9 approach. 

10 The use of a miles per gallon equivalent is 

11 a metric to compare vehicle efficiency. We believe 

12 that it is not a meaningful metric to use when 

13 comparing vehicles that use alternative fuels to 

14 vehicles that are conventional. 

15 Using MPGE is an attempt to standardize 

16 fuel measurement across different fuels that are 

17 typically measured in different units. It enables 

18 vehicles that consume different types of fuels to be 

19 compared to each other based on the underlying energy 

20 content of the fuel without regard to the efficiency 

21 with which it is converted to the mechanical energy 

22 that moves a vehicle. But virtually no one 

23 understands what that means. And even if they did, it 

24 would not be particularly meaningful. 
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1 Miles per gallon was really developed to 

2 serve as a surrogate for operating costs. That makes 

3 sense when we relied on a single fuel, whose price was 

4 volatile. It allowed us to compare the relative 

5 efficiency of vehicles so that we could quickly 

6 compare their relative operating costs. The use of 

7 miles per gallon also allowed us to report a common 

8 measure of efficiency that isolated the effects of 

9 fuel price volatility. The use of MPGe is different 

10 because we are making comparison across different 

11 fuels measured in different units. 

12 It is possible to compare apples to 

13 oranges. It is important, however, to use the correct 

14 metrics for comparison. 

15 In this case, the correct metrics for 

16 measurement, which should matter to the consumers 

17 most, are cost and emissions. That's what people 

18 really care about. 

19 As an interesting test case, the FTC 

20 governs energy efficiency labels on household 

21 appliances. They have developed a label for water 

22 heaters, for instance, which are available as 

23 electric, natural gas, or liquefied propane gas 

24 appliances. Their labels report energy consumption 
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1 and the units commonly used to measure each respective 

2 fuel, and operating costs. They do not, however, 

3 compare relative efficiencies of different fuels 

4 because they state it was not helpful to consumers. 

5 Lastly, battery performance. The proposed 

6 labels indicate how long it will take to charge a 

7 battery fully discharged in grid-enabled vehicles. 

8 The time that is used to calculate is based upon a 110 

9 volt Level I charger, which will be included with the 

10 purchase of every vehicle. The label should also 

11 include how long it would take to charge the vehicle 

12 with a Level II charger, which many people will 

13 install in their homes and will be the technology in 

14 nearly all public charging taking place, while noting 

15 that the cost of purchase and installation of those 

16 charges is not accounted for in the operating cost of 

17 the vehicle. Early data supports that a very high 

18 percentage of people who buy these vehicles intend to 

19 purchase a charger. And I'll be happy to take any 

20 questions. 

21 MS. DUNHAM: I've got a couple starting with 

22 Mr. Minsk. You referenced the Oak Ridge study on 

23 marginal electricity production. Do you have a site 

24 listed in your comments? 
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1 MR. MINSK: I do not have a site listed here, but 

2 I will both e-mail it to y'all and I will make a -- I 

3 think I could probably submit very quickly just a 

4 short comment to the record electronically. 

5 MS. DUNHAM: That's fine. If you plan to submit 

6 written comments by November 22nd. 

7 MR. MINSK: I'll be glad to. It will be cited in 

8 our written comments. 

9 MS. DUNHAM: That would be great. 

10 MR. MINSK: Maybe even attached. 

11 MS. DUNHAM: I was starting to write down a 

12 question about -- you raised a number of concerns with 

13 the issue of using the MPG equivalent, and so my 

14 original question was: Is there an alternative other 

15 than MPG equivalent which -- and I don't mean to put 

16 this in the context -- we have a statutory requirement 

17 that says we have to put MPG on the label. Is 

18 there -- have you put any thought that there's some 

19 alternative that would satisfy the statutory 

20 requirements? 

21 MR. MINSK: I think it's an interesting legal 

22 question. If it requires you to put miles per gallon 

23 on the label and in fact it does not consume any 

24 gallons, whether or not that applies in that 
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1 particular instance, you know, we can leave that to 

2 the lawyers to figure out. I understand the desire to 

3 be able to want to compare things so easily, but these 

4 aren't necessarily that easy to compare in the way 

5 that kind of seems intuitive. And I think as we begin 

6 to go down the path of alternative fuel vehicles -- 

7 and now we're talking about plug-ins, and we're also 

8 talking about natural gas vehicles and at some point 

9 we may be talking about hydrogen vehicles. 

10 It's easy to kind of default what makes 

11 sense, but we're kind of papering over the 

12 differences. And I think it would be useful to take 

13 the opportunity to try to educate people. These 

14 things are different and do it right from the 

15 beginning instead of essentially kind of building a 

16 facade, which will be the base which we build another 

17 facade and at some point we'll be really confused and 

18 we won't be truly representing the things that do 

19 matter. I mean, emissions matter a lot, and I want 

20 those displayed prominently. The cost matters a lot, 

21 and I want that displayed prominently. I don't think 

22 that the underlying BTUs consumed matters to anyone. 

23 And 99.9 percent of the people couldn't explain what 

24 that meant if they tried. 
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1 MS. DUNHAM: Thank you. 

2 MR. MEDFORD: I just want to continue, Mr. Minsk. 

3 You said you didn't like the letter grade. But the 

4 format on the alternative label, do you like the 

5 format and the presentation there? You went through a 

6 number of changes you'd like to see in terms of 

7 presentation. 

8 MR. MINSK: I think, generally speaking, the 

9 format on Label 2 is a much better format and some 

10 people recommend certainly a small number of, perhaps, 

11 tweaks to it. But I think that overall it's -- you 

12 know, it's a better design. It conveys the 

13 information. And I prefer it to the alternative 3 

14 also because I think it gives people information about 

15 carbon and criteria pollutants as opposed to, I think 

16 it was, just a star system, Label 3. I think it's 

17 good that people hear these numbers around, and 

18 eventually they will begin to start meaning something 

19 just like miles per gallon does. And it's important 

20 to get our ears and our brains accustomed to them over 

21 time. 

22 MR. MEDFORD: This could be for any of you, but 

23 the law requires us to provide, you know, the scales 

24 that we have for both fuel economy and for criteria 
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1 pollutants or smog emission pollutants, a rating for 

2 the entire fleet. And so we sort of have to do that 

3 and provide that. We also have considered at one 

4 point within that scale doing it by the category of 

5 vehicle you're buying, but it really does add sort of 

6 a level of complexity, and we decided not to do that 

7 in this proposal. Do you have a view about that? 

8 MR. MINSK: I thought that on one of them you 

9 actually -- you did. 

10 MR. MEDFORD: Is that 3MM. 

11 MR. MINSK: I thought it was on two you did. You 

12 had a bar, and then it had -- I thought that that was 

13 Label 2, and I think that makes a lot of sense. 

14 MR. MEDFORD: Hang on a second. It shows a 

15 range, but it doesn't break it down by vehicle type. 

16 MR. MINSK: On one of them. On Label 2 it does. 

17 MR. MEDFORD: You think that's not too confusing 

18 or do you have a view about it? You like that? 

19 MR. MINSK: I like that. I think we have to give 

20 people a lot more credit than we are. I mean, people 

21 aren't -- people are capable of understanding more 

22 than the letter A and B and C, and they're capable of 

23 understanding, you know, all vehicles have a subset of 

24 vehicles. If we talk down to people, they'll act like 
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1 we expect them to. If we talk up to them, they'll 

2 rise to the occasion. 

3 MR. TONACHEL: I think it's also a matter of 

4 emphasis, I think as I was pointing out, the letter 

5 grade is helpful because it can be used very quickly 

6 early in the buying process. But that doesn't take 

7 away the need to provide more detail in the label as 

8 well. I think you can cross a number of things that 

9 you provide in a label, which may not be the first 

10 thing that you look at, but that doesn't mean you 

11 shouldn't have them on there. 

12 MR. MEDFORD: You mentioned a time issue and you 

13 mentioned a couple things. One is sort of the print 

14 capability and the other is the color capability. Is 

15 there some additional information that maybe you can 

16 provide in writing, and I'm glad for your comments 

17 that you submitted. But can you elaborate any more on 

18 how much time in the nature of the work that has to be 

19 done to support getting ready with the label on there 

20 and how much of an issue is the color and how much is 

21 it for just establishing a new label format and 

22 printing it? 

23 MR. AMBROZAITIS: Yes, we will submit that in our 

24 written comments. The main issue is that the 
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1 requirements will only be finalized in January 2011 

2 which will leave very little time for hybrids to get 

3 ready for model year 2012. The issue with color is 

4 the printing of color right at the spawn of 

5 production, and we will address all these issues in 

6 our comments. 

7 MR. MEDFORD: Thanks. Thank you. 

8 MR. TONACHEL: I'll ask one other question. The 

9 picture that showed a lot of labels on the vehicle, I 

10 wonder if you could just comment on whether or not 

11 that's an actual vehicle. All those labels were on 

12 one actual vehicle. It looks like this picture in 

13 particular was added to the overall picture. 

14 MR. GIEDRIUS: This is an actual photo of an 

15 actual car on an actual dealer lot. And these are all 

16 the Monroney labels and this is the Stars on Cars 

17 label (indicating). This is the FTC/FFE label 

18 (indicating). And then this is the California 

19 environmental performance label (indicating). 

20 MR. TONACHEL: Just a closer look at this seems 

21 to show that this was somehow added to the label. 

22 Added to the front window. But anyway, I guess the 

23 other point would be that the environmental 

24 performance label that California requires, there's 
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1 also a capability that that could be incorporated into 

2 that Monroney label that's authorized within the state 

3 of California. 

4 MS. DUNHAM: Thank you. 

5 MR. MEDFORD: Thank you. We're ready for Panel 

6 2. Panel 2 is first Mr. Desmond Roberts and second 

7 Peter Zalzal. Welcome. Please be seated. Write your 

8 name on the sign there so everyone can know who you 

9 are. And just when you're ready you can begin your 

10 testimony. 

11 MR. ROBERTS: Good afternoon. My name is Desmond 

12 Roberts. I'm the immediate past chairman of the 

13 National Association of Minority Auto Dealers, known 

14 as NAMAD and a Chevrolet dealer in the Chicagoland 

15 area. Today, I am also testifying on behalf of the 

16 Illinois Automobile Dealers Association, IADA, and the 

17 Chicago Automobile Trade Association, CATA. 

18 NAMAD is a nonprofit organization which 

19 represents ethnic minority automobile dealers in the 

20 United States. IADA is a nonprofit organization 

21 representing franchise new car and truck dealers 

22 throughout the state, and the CATA is the same for 

23 dealers in the greater Chicago area. 

24 Last month the Environmental Protection 
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1 Agency, EPA, and the National Highway Traffic Safety 

2 Administration, NHTSA, issued a proposal to revise the 

3 fuel economy label for light-duty motor vehicles 

4 starting with MY 2012. Let me say upfront that I 

5 realize this proposal in part results from a mandate 

6 set out in the Energy Independence and Security Act of 

7 2007, EISA, which specifies certain changes. 

8 Moreover, I recognize that it was less than four years 

9 ago when EPA revised its fuel economy label for the 

10 model year 2008 and beyond. 

11 Franchised dealers retail all the new 

12 light-duty vehicles covered by the proposed fuel 

13 economy labels. Thus, dealers have an interest in 

14 ensuring that the content, layout, and size of these 

15 labels is appropriate to enable prospective purchasers 

16 interested in fuel economy to have useful, 

17 vehicle-specific information available to them at the 

18 point of sale. In this regard, please note that in 

19 addition to the fuel economy labels which have existed 

20 in one form or another for some 30 years, franchised 

21 dealers also make available to prospective purchasers 

22 an annual fuel economy guide issued by the Department 

23 of Energy, DOE. In fact, we will start making the 

24 model year 2011 version of the guide available this 
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1 week. 

2 Dealers are most concerned about labels 

3 which could one, confuse the buying public; two, make 

4 vehicle purchasing decisions more difficult; or three, 

5 treat certain automakers or fuel types unfairly. The 

6 proposal lays out three labeling alternatives for 

7 consideration. One label design option would impose a 

8 letter grade on a fuel -- vehicle's fuel economy and 

9 greenhouse gas emissions performance relative to the 

10 entire light-duty fleet subject to the fuel economy 

11 labeling mandate. A second option would retain the 

12 current label's focus on miles per gallon, MPG, and 

13 annual fuel costs while updating its overall design 

14 and adding new comparative information on fuel economy 

15 and vehicle emissions. Like the second option, the 

16 third would focus on MPG and annual fuel cost, but 

17 would be formatted differently, especially with 

18 respect to the presentation of comparative 

19 information. It's fair to say that each option offers 

20 advantages and each has shortcomings. While I'm not 

21 going to use my limited time with you today to delve 

22 into the details of the three options, I have some 

23 important general comments I'd like to make. 

24 First, as the proposal correctly notes, the 
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1 overwhelming majority of prospective light-duty 

2 purchasers focus on fuel economy only when fuel prices 

3 are relatively high and only as a relatively minor 

4 criteria when compared to other vehicle attributes. I 

5 believe that this reality will continue to be the case 

6 for model year 2012 and on into the future. 

7 Second, despite the new mandate set out in 

8 section 105 of EISA, even fewer prospective new 

9 vehicle purchasers consider a vehicle's greenhouse gas 

10 or other emissions when shopping. As with fuel 

11 economy, I do not expect emissions performance to play 

12 a significant role in most new vehicle purchase 

13 decisions in moving forward as the overwhelming 

14 majority of customers at least implicitly recognize 

15 that vehicles are highly regulated to meet strict fuel 

16 economy and emissions performance standards. 

17 Third, of the subset of prospective 

18 purchasers who do in fact focus on fuel economy or 

19 emissions performance, most tend to look at 

20 comparative information before coming to a dealership. 

21 With the advent of the Internet, shoppers increasingly 

22 cruise comparative information and make preliminary 

23 purchase criteria decisions in the comfort of their 

24 home or office, arriving at the dealership armed to 
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1 the hilt with a plethora of knowledge regarding the 

2 vehicles to which they've narrowed their search. This 

3 trend also will continue going forward. 

4 The foregoing three market realities drive 

5 my recommendation that EPA and NHTSA focus on using 

6 the label to present vehicle specific facts. City 

7 MPG, highway MPG, combined MPG, and annual fuel cost 

8 based on reasonable assumption are all facts that 

9 should be accurately and appropriately presented for 

10 prospective purchasers to use as they see fit. 

11 Comparative information, such as the in-class 

12 positioning of a vehicle's combined MPG on the 

13 existing label is less helpful due to inherent 

14 limitations. For example, the SUV class arguably is 

15 far too broad for shoppers who have narrowed their 

16 search to a few models of small SUVs. 

17 Comparisons across all makes and models 

18 subject to labeling such as those contained in the 

19 first alternative label design are at best of 

20 virtually no value, and at worst counter-productive. 

21 Why? Simply put, they fail to compare similar or, in 

22 the true sense of the word, comparable products. 

23 Seeking to evaluate and rate vehicles without 

24 attempting to hold constant attributes such as seating 
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1 or hauling capacity renders such ratings meaningless. 

2 What's more, these ratings would confuse consumers 

3 with respect to whether vehicles achieved enhanced 

4 fuel efficiency. As I understand it, the first 

5 alternative would award a better grade to a small 

6 vehicle that underperforms from a fuel economy 

7 perspective than would be to a larger, yet more 

8 capable and optimally efficient vehicle. Notably, EPA 

9 and NHTSA moved away from this approach when adopting 

10 an attribute-based model for their fuel economy 

11 mandates. Certainly, any new fuel economy labeling 

12 scheme should avoid the failed incentives of the past. 

13 With respect to the label format, the 

14 simpler and more clear-cut, the better. In addition 

15 to fuel economy information, the Monroney label must 

16 contain vehicle description, vehicle pricing, and 

17 vehicle safety information, so simplicity will serve 

18 shoppers well. Also, simplicity will allow dealership 

19 salespeople to respond accurately to questions raised 

20 by prospective purchasers regarding a vehicle's 

21 specific fuel economy or emissions performance. 

22 Until now I've made no mention of plug-in 

23 vehicles and how best to describe the fuel economy and 

24 emissions performance. As with information on 
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1 alternative fuel vehicles, the proper calculation and 

2 presentation of standard MPG-equivalent is critical. 

3 The problem is that apparently there is significant 

4 disagreement among vehicle manufacturers and others 

5 that suggest what metric should be used. I commend 

6 the agencies for the efforts to come to grips with 

7 this difficult issue. Again, as you proceed with your 

8 deliberations, I urge you to strive further for 

9 simplicity and consistency and to make sure that no 

10 single technology or fuel type is favored by how 

11 information is calculated or presented. 

12 Lastly, I urge EPA and NHTSA to work with 

13 dealers and their associates on educating the public 

14 on the new labels once promulgated. When it rolled 

15 out its model year 2008 label, EPA worked hard with 

16 dealers and others on outreach, an effort that should 

17 be similarly engaged in leading up to the model year 

18 2012. As with prior versions of the label, it also 

19 will be important to remind the motoring public both 

20 that the fuel economy they can expect to achieve will 

21 depend on many factors including driving conditions, 

22 speed, terrain, and maintenance. And that we should 

23 all continue to take the simple, everyday steps that 

24 will maximize in-use fuel economy and emissions 
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1 performance. 

2 On behalf of NAMAD, IADA, and CATA, I want 

3 to thank you for the opportunity to join you today to 

4 present our case. Thank you. 

5 MR. MEDFORD: Thank you, Mr. Roberts. 

6 Mr. Zalzal. 

7 MR. ZALZAL: Good afternoon. My name is Peter 

8 Zalzal, and on behalf of the Environmental Defense 

9 Fund and our more than 700,000 members nationwide, I 

10 sincerely thank you for the opportunity to testify 

11 today. 

12 EPA and NHTSA have proposed to redesign the 

13 fuel economy label consumers see on the window of 

14 every new motor vehicle. In doing so, the agencies 

15 engaged in a consumer-driven process, empowering 

16 consumers with important new information that will 

17 allow consumers to make straightforward comparisons 

18 across all vehicle types. EDF strongly supports the 

19 agencies' efforts to provide consumers with the 

20 information necessary to make informed purchasing 

21 decisions. 

22 For more than 30 years, the federal 

23 government has required auto labels on new cars and 

24 light trucks that show consumers the estimated miles 
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1 per gallon of that particular vehicle. In 2007, 

2 through the Energy Independence and Security Act, 

3 Congress directed that additional information, 

4 including greenhouse gases and other pollution, be 

5 included on the labels. The proposed new labels 

6 carrying out these statutory mandates will help 

7 consumers to deepen their understanding of the fuel 

8 consumption and environmental impacts of new vehicles. 

9 In providing this information, EPA and 

10 NHTSA engaged consumers to ensure the new fuel economy 

11 label would provide the statutorily-required 

12 information in a way that maximized clarity and 

13 understanding for the consumer. The centerpiece of 

14 this process was a series of focus groups conducted by 

15 EPA and NHTSA across the country. The three phases of 

16 these focus groups explored consumers' use of current 

17 labels, consumers' understanding of and preference for 

18 metrics on advance technology vehicles, and consumer 

19 input on full-label designs. 

20 This process provided policymakers with key 

21 consumer incites allowing the proposed fuel economy 

22 labels to use metrics that consumers wanted to see 

23 while incorporating designs consumers considered 

24 effective. Consumers asked that EPA and NHTSA provide 
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1 labels that create an immediate first impression for 

2 consumers, are easy to read and understand quickly, 

3 clearly identify vehicle technology, utilize color, 

4 chunk information to allow people to deal with more 

5 information, are consistent in content and design 

6 across technologies, allow for comparison across 

7 technologies, and make it easy to identify most fuel 

8 efficient and environmentally friendly vehicles. 

9 Both proposed Labels 1 and 2 respond to 

10 these consumer needs, but there are several additional 

11 benefits associated with proposed Label 1. In 

12 addition to the information on Label 2, proposed 

13 Label 1 includes a letter grade that reflects fuel 

14 efficiency and greenhouse gas emissions and fuel cost 

15 savings over five years based on an average vehicle. 

16 This prominently-displayed letter grade can 

17 benefit consumers by providing information in a clear, 

18 familiar, and informative package. Focus groups 

19 emphasized the need for an easy-to-understand label 

20 format. The letter grade responds to these consumer 

21 concerns by providing a central focus to the label 

22 that gives information on the performance not just of 

23 that vehicle but relative to other vehicles. 

24 Likewise, letter grades for new vehicles, like health 
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1 and safety grades for restaurants, provide consumers 

2 with a central piece of data that is instantly 

3 familiar and meaningful. New York City, for instance, 

4 has recently required all restaurants to prominently 

5 display restaurant letter grades, recognizing the 

6 critical importance of these letter grades in 

7 "helping" consumers make informed choices about where 

8 to eat out. Finally, the label with the letter grade 

9 contains more information because it provides an 

10 easy-to-remember representation of the more detailed 

11 information contained in the rest of the label and the 

12 Web site. The Better Business Bureau in fact recently 

13 shifted to a letter grading system because, "they felt 

14 like their ratings weren't giving enough information." 

15 Label 1 also benefits consumers by 

16 providing important environmental information, 

17 allowing for easy comparisons among vehicles, and 

18 helping consumers understand the economic benefits of 

19 purchasing certain vehicles. Label 1 explains the 

20 money saved at the pump over five years, a key factor 

21 for America's families. Likewise, EPA focus groups 

22 show that consumers did not tend to limit themselves 

23 to one class or type of vehicle when shopping. EPA's 

24 Phase II report noted that, "When asked if it was 
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1 important to be able to compare across different types 

2 of vehicle technologies, virtually every participant 

3 said yes. They indicated that they wanted to use the 

4 information to compare different vehicles across 

5 technologies in their consideration and therefore be 

6 able to make an informed decision." EPA's proposed 

7 Label 1 responds to these concerns and sets fuel 

8 efficiency and environmental performance and fuel 

9 costs in context among all vehicles. 

10 I'd like to thank you again for the 

11 opportunity to testify today. EDF strongly supports 

12 the agencies' efforts and the consumer-driven process 

13 to identify and convey information useful for 

14 consumers purchasing new vehicles. The additional 

15 information and the clear, familiar, and rigorous 

16 presentation will help empower consumers to purchase 

17 new cars that more fully reflect their preferences. 

18 Thank you. 

19 MR. MEDFORD: Thank you. Mrs. Eckstein. 

20 MS. ECKSTEIN: Hi, my name's Robin Eckstein. 

21 Thanks a lot for letting me come on the panel. I 

22 appreciate it. Yes, so I'm an Army veteran. I'm 

23 not -- I don't have a fancy title, unfortunately, and 

24 I'm also one of the volunteer veterans with Operation 
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1 Free, which is a coalition of veterans that have been 

2 doing a lot of outreach and educating people on the 

3 fact that climate change and clean energy are actually 

4 national security issues. 

5 The reason why I'm here today is as a 

6 representative of Operation Free, but also just an 

7 Army vet and consumer. When I was in the Service, I 

8 served for seven years, and I actually deployed to 

9 Iraq in 2003, part of the initial invasion with the 

10 First Armor Division. And while I was there I was 

11 actually a truckdriver, and I drove in a lot of these 

12 fuel convoys that move all around Iraq. And, 

13 unfortunately, you know, I wish I had a fuel efficient 

14 vehicle while I was over there because, unfortunately, 

15 every time you roll outside the gates of Baghdad's 

16 international airport, it's a roll of the dice as far 

17 as what you're going to encounter, whether it's IED, 

18 sniper fire, you know, ambushes. And these forward 

19 operating bases can't function if they don't get their 

20 fuel. So I know they're obviously wishing they had 

21 more fuel efficient vehicles, you know, ways to save 

22 fuel themselves. 

23 And so all of this kind of resonated in my 

24 head. When I came home, I really wanted to be 
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1 involved in making sure that they make some changes to 

2 save American lives and to move towards a cleaner 

3 energy future. And I definitely see, you know. 

4 relabeling on vehicles as definitely a step in the 

5 right direction. I think it's extremely important. 

6 And for me, you know, I like the letter 

7 grade. I'm not going to lie. It's a lot easier. And 

8 as a consumer -- I mean, when I bought a vehicle, it 

9 was a couple years ago now, three or four years ago. 

10 But I did go on the Internet and tried to research a 

11 little bit, so, you know, I feel I'm a fairly fair 

12 representation of the average person. But there's so 

13 much information out there, and it's really hard to 

14 sort through it all. And I think, you know, one of 

15 the points that a lot of people who are against the 

16 label want to say is that, Oh, people can go on the 

17 Internet and look it up. You know, they can find all 

18 this stuff by themselves. But there's so much out 

19 there. It's like impossible to sort through it all. 

20 So to have a simple letter grade on a vehicle I think 

21 is really easy. Some people have said that it's 

22 confusing. I don't know how A, B, C, and D are 

23 confusing. It seems pretty simple to me. 

24 You know, obviously there's people who want 
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1 to say that it's unfair. Well, every student that's 

2 ever gotten a D thinks it's unfair. But, hey, you 

3 know, if you don't want to get a D, then you work 

4 harder. You make your vehicle more fuel efficient and 

5 you can get an A, just like the other people who did. 

6 So, you know, I don't know. I don't see how it can be 

7 confusing or unfair. 

8 Plus, grades are subjective. You know, I 

9 think when you -- you know, if you go somewhere and 

10 you want to purchase something or you know you only 

11 have so much money -- say, you only have $20,000 and 

12 you really want an A vehicle, but you need more car or 

13 you need more cargo room, whatever, and you have to go 

14 to a C. Well, you know, C's still good. It's not 

15 like it's an F. But it will at least get you through, 

16 and later on you strive for the A later. So I guess 

17 it just seems very simple to me. 

18 I guess one of the points is, too, is to 

19 reiterate, is our dependence on oil is really a threat 

20 to our national security. That's one of the reasons 

21 why I'm extremely involved in this. And this is a way 

22 for the American people to actually, you know, put 

23 some effort in. A lot of times people when we've -- 

24 I've gone places and educated people on clean energy 
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1 and climate change and how it affects our national 

2 security. You know, the fact that we're completely 

3 vulnerable here in the United States because we're 

4 dependent our own source of energy, we're funding both 

5 sides of the war. Climate changes will be causing 

6 conflict in the future. All that kind of stuff. I 

7 don't want to have to go through that whole scphiel if 

8 I don't have to. 

9 But basically people ask, Well, what can I 

10 do? Well, hey, this is something they can do. When 

11 they go to a dealership and they buy a new vehicle, 

12 they can say, "Hey, pick the A." That would be great 

13 if I could just say, "Hey, pick the A or pick the B." 

14 Pick the better grade. Sounds easy. 

15 You know, currently we're spending over a 

16 billion dollars a day on fuel for oil from other 

17 countries. That could be money that we could be 

18 putting here in the United States. And if consumers 

19 are given a simple way to judge, you know, what's the 

20 better option, they can be helping getting away from 

21 that one billion. Start getting away from that and 

22 spending the money here in the United States. 

23 And I don't know why the car manufacturers 

24 really are, I mean, against this. It looks like an 
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1 opportunity for you to, you know, do something good 

2 for the environment. Do something for our national 

3 security. Do something good for the troops because, 

4 hey, I'm one of them. I appreciate it. So, you know, 

5 it looks good all around. 

6 I guess on the home front, unfortunately, 

7 you know, just a few years ago and stuff when we had 

8 the oil -- you know, gas prices hike up really high. 

9 I think it's really hard for families to budget. I 

10 know a lot of my friends, you know, started riding 

11 their bikes more often because they just couldn't 

12 afford to be continuing, you know, to drive when the 

13 prices are so high. Well, you know, families need to 

14 really try to budget for those kind of fluxes. And if 

15 they're getting a more full efficient car and they 

16 know they are, you know, it's just going to be easier 

17 for them in the long run. 

18 One of the other things I heard also, too, 

19 was that changing or whatever, that this is a 

20 traditional label. It looks nice and it's 

21 traditional. Well, this is also -- the world's 

22 changing; okay? Where were we 40 years ago? We were 

23 also using a lot less oil than we are now. We also 

24 didn't know as much about global warming and climate 
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1 change. So the world's changing. It's time to get a 

2 new label, guys. Even kids can understand letter 

3 grades. Seems pretty easy. So I don't see why you 

4 would really shy against it. 

5 I am not -- I'm not, you know, a fancy 

6 scientist. I'm not an engineer. But I am a veteran. 

7 I lived through, you know, the effects of fuel and the 

8 shortages. Trust me. You don't want to be short when 

9 you're in Iraq. And I'm also a consumer, and I really 

10 appreciate being able to have such a simplified label, 

11 you know, a letter on there because it makes it 

12 easier. Americans actually can do something about it. 

13 And if the information is available, they are going to 

14 consider it. If you don't put it on there, they're 

15 not going to consider it, you know, because there's 

16 just so much out there. But if it's on there, they 

17 are going to consider it and they're going to feel 

18 better about making a better choice. 

19 And so with that, thanks a lot. I 

20 appreciate it. Hope I didn't talk too fast for you. 

21 MR. MEDFORD: Thank you, Ms. Eckstein, and thank 

22 you for your service to the country. We really 

23 appreciate that very much. So back to the letter 

24 grades just for one question. Some of the people have 
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1 said that have testified that the letter grade could 

2 be misinterpreted. I think the Alliance said this to 

3 mean that it's not about fuel efficiency. It could be 

4 something else about the car. You know, one thing 

5 that NHTSA does is we rate cars for safety, but we 

6 actually have a five star government rating program 

7 that's also on the same label. Do you have any 

8 concerns about not understanding that the letter is 

9 for fuel economy or greenhouse gas emissions? 

10 MS. ECKSTEIN: This is for me? 

11 MR. MEDFORD: Yes. 

12 MS. ECKSTEIN: I think if you look at it -- like, 

13 if you look at this actual label here, it clearly 

14 says, fuel economy and environmental comparison right 

15 above it. I mean, if I just saw a letter on 

16 something, you know, I was like, oh, A or B, I'm not 

17 naturally just going to go buy it. I'm also going to 

18 look above it and look at what the letter grade is 

19 for. You know, maybe it could be for something really 

20 crazy. I think it's very clearly labeled, you know, 

21 right above it about what it's for. So I don't know 

22 why you would be confused unless you were blind and 

23 couldn't read it. 

24 MR. MEDFORD: Thank you. 
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1 MS. DUNHAM: Mr. Roberts, I had a question for 

2 you. You sounded -- well, I think your comments were 

3 pretty clear that you called rankings. Sounds like 

4 sort of -- the number of different rankings that we've 

5 proposed in addition to the letter grades. Is there a 

6 role for those rankings somewhere like on the Web or 

7 someplace else or are you -- do you think people, 

8 consumers can or are already using the Web to do their 

9 own comparison without the rankings? 

10 MR. ROBERTS: Absolutely. Before I respond to 

11 that question, if I may say, on behalf of the 

12 manufacturers and the auto dealers, we're certainly 

13 not against making vehicles more efficient, more fuel 

14 efficient, and providing our contribution to the 

15 environment. The issues that we have of making apples 

16 to orange comparisons on the letter grading, if you 

17 were to grade a particular class of cars, then what 

18 you're doing is penalizing particular cars within a 

19 category as opposed to the individual cars themselves. 

20 I have two dealerships here in the Chicago 

21 land area. I sell a lot of cars. And when consumers 

22 come in and are making decisions, they're making 

23 decisions based on their family needs. Once the 

24 family's needs have been satisfied, then they look to 
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1 the other criteria. They look to environmental, fuel 

2 economy, and stuff like that. And what this -- 

3 particularly what the letter grades imply to me is, 

4 what they're doing is giving smaller, more smaller 

5 vehicles, which are not necessarily more fuel 

6 efficient within their class or category, but by 

7 nature of the fact -- by the virtue of the fact that 

8 they're consuming less fuel, a better grade than a 

9 vehicle that's larger, that could be more fuel 

10 efficient in supplying and satisfying the consumer's 

11 needs. So what we're saying is is the letter grades 

12 don't quite clearly provide the benefit that they are 

13 intended to. And we think that your option 2, even 

14 though we're not endorsing it without further input 

15 from our association, we think your option 2 gives a 

16 better -- more clarity to the consumer, and the 

17 consumer is exactly who we're trying to please. 

18 MS. DUNHAM: This is for Mr. Zalzal. You 

19 mentioned the Better Business Bureau was just shifting 

20 to the letter grades. I was wondering if you were 

21 planning to provide more information on that and what 

22 they're doing. 

23 MR. ZALZAL: We'll certainly provide more 

24 information and I have a cite included in this 
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1 testimony as well. 

2 MS. DUNHAM: Thank you. 

3 MR. ROBERTS: If I may for a moment just address 

4 that issue of the Better Business Bureau. I happen to 

5 be on the Board of Directors of the Better Business 

6 Bureau, and I can attest a little bit to this grading, 

7 the letter grading categories. I can tell you that 

8 there are even with the simplicity of the letter 

9 grading for performance of our business operations, 

10 there is some confusion within that letter grading 

11 because certain criteria in determining the grade for 

12 the particular entity involves the number of 

13 inquiries. And the number of inquiries can adversely 

14 affect that grade. And even though that particular 

15 entity may be a good performing entity based on the 

16 number of inquiries, it could adversely affect their 

17 grade. So even within the Better Business Bureau 

18 there are some issues on the grading system. 

19 MS. ECKSTEIN: I just wanted to ask a question. 

20 You said you got a couple dealerships; right? Now, if 

21 people show up to the dealership to buy a vehicle, 

22 they're going to buy one, most likely. 

23 MR. ROBERTS: We hope. 

24 MS. ECKSTEIN: So whether, you know, you got 
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1 three A's and two B's and one C, you know, they're 

2 going to buy one of them. So I don't understand why 

3 you're against it. I mean, you're going to have a 

4 sale. They need a car so they're coming to you and 

5 they're going to buy one. You're going to have a 

6 sale. Is it just because you got a lot of gas 

7 guzzlers on your lot that, you know you don't -- that 

8 you're afraid of the grade? I guess I don't 

9 understand. 

10 MR. ROBERTS: No. Actually we do have quite an 

11 array of fuel efficient cars on our lot. And we're 

12 certainly not objecting, as I said, to providing 

13 vehicles that provide a better fuel economy. Once 

14 people are directed to a particular or a way from a 

15 particular model based on a misconception of the -- of 

16 how the grade was arrived upon could cause consumers 

17 not to make a decision to purchase a vehicle that is 

18 indeed fuel efficient and that does satisfy their 

19 needs. 

20 MR. MEDFORD: Thank you. We encourage you to 

21 continue to talk after the panel's over and we thank 

22 you for testifying today. Thanks very much. 

23 MS. DUNHAM: Frank Szollosi, hope I got the name 

24 close, from the National Wild Life Federation. And 
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1 from the Sierra Club, Jack Darin. Are you here? 

2 MR. SZOLLOSI: My name is Frank Szollosi. I'm a 

3 climate and energy policy analyst at the National 

4 Wildlife Federation at our Great Lakes office in Ann 

5 Arbor, Michigan. On behalf of the National Wildlife 

6 Federation, our 47 state affiliate organizations and 

7 more than 4 million members and supporters across the 

8 country, we thank you for the opportunity to provide 

9 comments on this proposed rule on new fuel economy 

10 labels and for the new labels themselves, which are 

11 truly a welcome and needed update to labels that have 

12 largely been unchanged for decades. NWF plans to 

13 submit more technical comments before the deadline. 

14 We appreciate this opportunity today in Chicago, the 

15 Midwest, to highlight some key points, particularly as 

16 regards to how the label best supports consumer 

17 decision-making for the next generation of vehicles. 

18 I will be making three points in just under 

19 ten minutes. Our members want information like this. 

20 I'm going to touch on our view that this transition to 

21 clean technology is good business for American car 

22 manufacturers, dealers, and everyone associated with 

23 the industry. And I'm going to close with touching on 

24 some of the features about the labels that we like. 
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1 So, again, our members need and want this 

2 information. Fuel economy labels are a unique and 

3 critical opportunity to provide consumers with 

4 information upfront as they consider one of the most 

5 financially and environmentally significant purchases 

6 that they make. As people -- our members, as people 

7 who care about wildlife habitat, land, and water, we 

8 value acting personally to combat global warming and 

9 reducing our dependence on oil. And, like most 

10 Americans, we value opportunities to put money back 

11 into our household budget by saving money at the gas 

12 pump. And we believe we deserve clear information 

13 that helps make -- that helps take advantage of these 

14 opportunities. 

15 NWF, as an organization, we deeply care 

16 about combating global warming as it's the foremost 

17 threat to wildlife of our time. It's also a profound 

18 threat to the livelihood and security of people and 

19 businesses worldwide. Many of your members here in 

20 the Midwest are hunters and anglers who can see the 

21 changes in game and habitat happening around them and 

22 they actively advocated for policy that cuts global 

23 warming pollution both at the local, regional, and 

24 federal level. 
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1 NWF has a long-standing commitment not just 

2 to wildlife, but to natural resource restoration, 

3 specifically most recently in Louisiana and the Great 

4 Lakes. We were deeply involved in responding to the 

5 tragic spill, the oil spill in the Gulf. More 

6 recently and more locally in the Kalamazoo River in 

7 Michigan. And our members and the tens of thousands 

8 of citizens who respond and are acutely aware of the 

9 price of continued oil dependence. 

10 On greenhouse gas emissions and oil 

11 savings, our members are asking not just what can NWF 

12 do or the government do, but what can they do 

13 personally. 

14 Therefore, clear, prominent greenhouse gas 

15 emissions and fuel economy information helps our 

16 members and consumers make an informed choice between 

17 vehicles that would not only reward automakers who 

18 make investments in fuel efficient and low emissions 

19 technology but also, as I mentioned in the beginning, 

20 would benefit consumers by better aligning their 

21 purchase with their values. 

22 The economy's important. Clearly, NWF has 

23 been a tireless advocate for clean energy and 

24 transportation policy that helps households and 
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1 revitalizes communities, builds jobs, and helps the 

2 economy. Energy costs are also a major part of 

3 household budgets, particularly for lower income 

4 households. But while the relative upfront price of 

5 various vehicles is quite evident, the relative fuel 

6 costs and savings over time are less clear. 

7 Every extra dollar saved on fuel is a 

8 dollar that could be spent on other household 

9 purchases. We want to see those dollars spent 

10 locally. They circulate much more robustly here in 

11 the Midwest than they do overseas where we get the 

12 majority of our oil, or our fuel. Especially here in 

13 the Midwest, many consumers also understand the 

14 intimate connection between new cars and jobs, whether 

15 it's the Ford Chicago assembly, auto manufacturing in 

16 and around Ann Arbor where I work, in Toledo, Ohio, 

17 where I live. We understand the connection between 

18 cars and jobs. 

19 And polling shows that consumers believe 

20 that advanced clean energy technologies means new jobs 

21 and data on willingness to pay to capture those jobs 

22 suggests that they value acting to secure those 

23 benefits to our communities. Without data on relative 

24 fuel costs and savings, it's hard for consumers to 
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1 assess the trade-offs between higher upfront costs and 

2 fuel savings over time. Looking at just costs may 

3 lead consumers into a false choice to which they 

4 short-change their individual and community economic 

5 best interests. 

6 Clearly articulating relative cost savings 

7 help make the value of fuel economy more concrete, and 

8 helps consumers make the core economic trade-offs that 

9 are important to them, whether between fuel and other 

10 purchases or community benefits, or between vehicle 

11 cost and fuel savings, or between vehicles. 

12 My second point is that it's really an 

13 exciting time for the auto industry. The auto 

14 industry is on the verge, I think we all know, on the 

15 verge of major transformation, bringing economic and 

16 environmental and vehicle performance benefits to 

17 consumers. And we believe these new labels should 

18 facilitate that transition. As more and more vehicles 

19 use alternative fuels and alternatives to gasoline, 

20 within a decade and half traditional vehicles that 

21 rely only on gasoline, the internal combustion engine 

22 could make up as little as 25 percent of the new 

23 fleet. 

24 We need labels to work for all types of 
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1 vehicles and for consumers who need to compare them 

2 across several important criteria. 

3 We believe that effective window labels 

4 that addresses the priorities I just mentioned should 

5 have the following features: A simple metric that 

6 provides quick comparison across all vehicles. The 

7 new labels rightly provide more information. However, 

8 a simple summary that gives a consumer a sense of the 

9 overall environmental performance is a critical 

10 element and it's essential that such a summary shows 

11 where the vehicle performs relative to all cars and 

12 light trucks on an absolute scale. But it's also 

13 important to show where it stands relative to similar 

14 vehicles. Such a scale or grading should be 

15 sufficiently prominent to capture consumers' 

16 attention, be clear. Showing comparisons only among 

17 similar vehicles without an absolute scale we believe 

18 would create multiple conflicting elements and could 

19 complicate things. It's potentially misleading to the 

20 public and may detract from the core data on the 

21 label. 

22 Another feature that's important to us is 

23 information regarding tailpipe and upstream emissions. 

24 Most vehicles create pollution from both the tailpipe 
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1 and generating or refining the fuels that they use. 

2 But the proportion of tailpipe and upstream amounts 

3 varies significantly across gasoline, other liquid 

4 fuels, and electric power. While the primary purpose 

5 of this label is to communicate emissions from the 

6 vehicle itself, also providing upstream emissions 

7 information is important to provide consumers with 

8 confidence that they are receiving an accurate picture 

9 of the vehicle's overall environmental impact. 

10 We'd like to see labels feature prominent 

11 information on global warming pollution, as I've 

12 already discussed, and also fuel economy plus a clear 

13 prominent depiction of fuel economy and miles per 

14 gallon we believe is essential. 

15 We also believe these labels need to 

16 feature costs associated with driving the new car or 

17 truck and the cost for savings relative to the average 

18 vehicle. As I mentioned before, relative costs or 

19 savings spur consumer thought regarding overall value 

20 and trade-off opportunities in a way that shows 

21 vehicle -- in a way that shows vehicle and fuel cost 

22 alone do not. New vehicle window labels are one of 

23 the best opportunities to get consumers clear 

24 information about the cost of using versus simply 
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1 purchasing a vehicle. Households deserve clear 

2 information on opportunities to save. 

3 Again, the National Wildlife Federation 

4 thanks the EPA and NHTSA for their efforts to develop 

5 an effective new label. Both the labels that have 

6 been proposed have strengths. Some combination of the 

7 two could ably meet the objectives described today. 

8 And we thank you again for the opportunity to comment 

9 today. 

10 MS. DUNHAM: Thank you. Mr. Darin. 

11 MR. DARIN: Thank you so much for the opportunity 

12 to testify today. My name Jack Darin, D A R I N. I'm 

13 the director of the Sierra Club's Illinois Chapter. 

14 On behalf of the Sierra Club's 1.3 million 

15 members and supporters, we applaud EPA and NHTSA for 

16 proposing the first significant overall vehicle fuel 

17 economy labels in more than 30 years. 

18 Illinois has been seriously looking at 

19 clean car standards for several years. I chaired 

20 Illinois's Clean Car and Energy Efficiency Working 

21 Group in 2007, and at that time we found that 

22 implementing the LEVII/Pavley standards in Illinois 

23 would result in 1 billion gallons of gasoline not 

24 bought at the pump annually in Illinois drivers by 
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1 2020 and 2 billion gallons per year fewer per year by 

2 2030. 

3 Subsequently, after that, the Illinois 

4 General Assembly seriously debated adopting those 

5 standards here in Illinois and again was in the midst 

6 of actively considering that at the time that 

7 President Obama announced new vehicle standards 

8 governing model years 2012 through 2016 to effectively 

9 do that for the entire country. We were using numbers 

10 at that time at $3 a gallon of gas that Illinois 

11 drivers will save, thanks to that action. About $3 

12 billion a year by 2020 and $6 billion a year for 2030, 

13 thanks to that action. And we found tremendous 

14 secondary economic benefits by Illinois drivers having 

15 those dollars to spend or save in their communities as 

16 opposed to spending it at the gas stations. 

17 So this first big step towards breaking our 

18 dependence on oil and reducing U.S. global warming 

19 pollution from our cars and trucks is a tremendous 

20 first step forward. And, as you know, the Sierra Club 

21 is engaged in the administration's process to begin 

22 work on the next round of standards governing years 

23 2017 through 2025. Similarly, we look forward to the 

24 first ever fuel efficiency rules for delivery trucks 
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1 and tractor trailers. 

2 The topic addressed today at this hearing, 

3 fuel economy window labels, is an important component 

4 of a broader plan to break our addiction to oil by 

5 providing helpful, easy-to-use information. Window 

6 labels can help consumers understand the vehicle's 

7 impact on oil use and greenhouse gas emissions and 

8 choose a vehicle that helps reduce our dependence on 

9 oil while meeting their transportation needs. 

10 To be most effective, window labels should 

11 convey a range of helpful information in a simple 

12 format that is easily digestible by consumers. Key 

13 considerations include which metrics to display and 

14 the layout of the label. We support a simple label 

15 that effectively conveys emissions, both greenhouse 

16 gas emissions and traditional criteria emissions, and 

17 that allows consumers to easily compare vehicles and 

18 provides information regarding the economic costs of 

19 operating the vehicle and the savings associated with 

20 efficiency. 

21 Specifically, we urge EPA to incorporate 

22 three elements into the new fuel economy label. 

23 First, we think that the new label should include a 

24 prominent letter grade system that's based on the 
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1 vehicle's greenhouse gas emissions. A letter grade 

2 system, like a school report card, is widely 

3 understood by consumers and would allow consumers to 

4 understand the relative emissions and efficiency of a 

5 vehicle in one quick glance. It would also lead some 

6 consumers to learn more about vehicle emissions. And 

7 such quick information is quite important as EPA's own 

8 label research show that while most consumers use fuel 

9 economy labels to inform them in making decisions, 

10 many only glance very briefly at the current labels. 

11 So, further, a letter grade system could be applied to 

12 all vehicle technologies regardless of the type of 

13 fuel they use. 

14 It's also important that all light duty 

15 vehicles be compared, whether by letter grade or a 

16 different method, by a single scale based on 

17 greenhouse gas emissions so the cars and light trucks 

18 can be compared together. 

19 Second, it's vital that a label for plug-in 

20 hybrid and electric vehicles convey the upstream 

21 emissions from the electricity generation that powers 

22 the car. While electric vehicles do not emit 

23 pollution from a tailpipe, they are certainly 

24 responsible for emissions from the electricity used to 
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1 power them. And when purchasing a plug-in vehicle, 

2 consumers should be made aware of those upstream 

3 emissions. 

4 And third, the new labels should clearly 

5 convey both the economic costs of operating the new 

6 vehicle and the potential savings from fuel 

7 efficiency. While the upfront costs of the new 

8 vehicle are obvious and readily apparent, consumers 

9 are much less likely have to clear understanding of 

10 the operational costs of a new vehicle and the cost 

11 associated with operating a more efficient car. 

12 We support the inclusion of prominent cost 

13 savings and would urge EPA and NHTSA to also include 

14 the operational costs, possibly the expected annual 

15 fuel costs. Additionally providing consumers with the 

16 key information, the fuel used to travel 100 miles, 

17 will help consumers understand costs and fuel 

18 consumption. 

19 In conclusion, Sierra Club applauds EPA and 

20 NHTSA for proposing updated window labels that will 

21 provide consumers with much needed information when 

22 purchasing a new vehicle. We strongly support the 

23 letter grading system as a simple and understandable 

24 way to key consumers into the environmental 
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1 performance. These window labels can also help 

2 consumers make choices that will begin to break our 

3 addiction to oil and help consumers save at the pump. 

4 Again, on behalf of our members and 

5 supporters around the country, we applaud you and 

6 thank you for your hard work. Thank you. 

7 MS. DUNHAM: Thank you. 

8 MR. MEDFORD: Mr. Darin, I just have one 

9 question. At the end, you seemed to indicate we 

10 should include on the label not only the MPG, which is 

11 required, but also the gallons per 100 miles, which is 

12 really a more representative way of measuring fuel 

13 economy. But you said also to include, or your 

14 suggestion perhaps, a cost per 100 miles traveled in 

15 addition to the annual and the five-year cost savings. 

16 MR. DARIN: Right. We feel like that might be a 

17 more direct route to people's thinking about cost. If 

18 we're able to do that simple math for them about how 

19 much those gallons are going to cost as opposed to a 

20 volume. 

21 MR. MEDFORD: That's all. 

22 MS. DUNHAM: I had a question for Mr. Szollosi. 

23 I might want to defer to the written comments later, 

24 but you mentioned in your conclusion that both labels 
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1 had strengths and that some combination of both labels 

2 might be good. Do you have any specifics that you'd 

3 be comfortable sharing now of which elements of each 

4 you think. 

5 MR. SZOLLOSI: Yeah. We like the absolute scale, 

6 comparing the light, the smaller vehicles to the 

7 larger vehicles for greenhouse gas emission reporting, 

8 and so we'd like to see that in either, whichever 

9 direction you go. That's really the major piece for 

10 us. 

11 MS. DUNHAM: Thank you very much. 

12 MR. MEDFORD: I think we're ready for Panel 4, 

13 which is Debbie Bakker from Hyundai and Mr. Edward 

14 Oser from the Center of Neighborhood Technology. 

15 MS. BAKKER: Good afternoon. I'm Deborah Bakker, 

16 senior manager of the Regulation and Certification 

17 Department for Hyundai American Technical Center, and 

18 I'm here today on behalf of the Hyundai Motor Company 

19 and Hyundai Motor America. Hyundai appreciates the 

20 opportunity to testify today on the EPA and NHTSA fuel 

21 economy label proposal. Fuel efficiency and 

22 greenhouse gases are very important topics to our 

23 company, and Hyundai is proud to be the most fuel 

24 efficient major automaker in America. 
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1 Hyundai applauds the agencies' efforts to 

2 think outside the box and consider innovative ways to 

3 provide fuel efficiency and greenhouse gas information 

4 to consumers. The fuel economy label can be a useful, 

5 interactive, and simple tool that the consumer can use 

6 to be make an informed purchase decision, and the 

7 proposed label revisions do an excellent job of 

8 exploring a number of options on how to achieve that. 

9 I would like to address six main points 

10 regarding the proposed label revisions and will be 

11 submitting additional comments in greater detail in 

12 our written submission. 

13 First, Hyundai supports the use of a letter 

14 grade on the label, as was proposed in Label Option 1. 

15 A letter grade is a simple and intuitive method of 

16 highlighting fuel efficiency performance. A 

17 methodology well-known by all, and it allows consumers 

18 to easily compare fuel efficiency and greenhouse gas 

19 performance across models and vehicle types. To 

20 address concerns that the grade could be misconstrued 

21 as an overall vehicle rating, we believe this can be 

22 easily addressed by adding a bold header entitled, 

23 Fuel efficiency, into the grade itself. 

24 Second, while we support the use of a 
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1 letter grade, we believe the agencies' proposed grade 

2 distribution should be modified to make it more 

3 informative to consumers. Under the proposed 

4 distribution, more than 80 percent of models on the 

5 road today would receive a variation of a B grade or a 

6 C+. Increasing differentiation between grades can be 

7 improved by providing electric, plug-in, and fuel cell 

8 vehicles with the grade of A+. As these technologies 

9 become more prevalent in the market, the methodology 

10 can be modified to further discriminate the fuel 

11 efficiency performance of these vehicles. 

12 Alternatively, these technologies can be 

13 removed from the grading system and given their own 

14 unique label identifier. The Korean government, which 

15 has instituted a numerical fuel economy label grading 

16 system of one to five, opted to remove advanced 

17 technologies from their grading scale. Again, 

18 removing advanced technology vehicles or providing 

19 these vehicles or these technologies with an A+ rating 

20 initially would allow for a wider distribution of 

21 grades. 

22 As another alternative, Hyundai could also 

23 support the use of a 0-to-100 scale, the numerical 

24 form of a letter grade. As this metric would also 
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1 allow for finer differentiation between models but 

2 would still provide a simple way to grade vehicle fuel 

3 efficiency. Without a change in the distribution 

4 methodology, Hyundai cannot support the grading 

5 proposal. 

6 Third, we support the use of an absolute 

7 scale, as was proposed, where all vehicles are rated 

8 as one fleet as opposed to a class segment grading 

9 system. We believe that an absolute scale provides 

10 the most level playing field for vehicle types and is 

11 the easiest to understand by consumers. With the 

12 grading system in the Korean market, the label grade 

13 was initially segmented by vehicle class and was found 

14 to be confusing to consumers who struggled to 

15 understand why a smaller, more fuel efficient car 

16 received a lower grade than a much larger and less 

17 efficient vehicle. The Korean government later 

18 converted their grading system to an absolute scale. 

19 For these reasons, Hyundai supports an absolute scale. 

20 Fourth, regarding the label format, Hyundai 

21 appreciates the esthetics and layout of Label 1 and 

22 the innovative thinking this label demonstrates. 

23 Unfortunately, there are several drawbacks with the 

24 label. For instance, the logistics involved with 
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1 printing variable data is a concern. Printer 

2 tolerances are such that it is very difficult to print 

3 variable text in the small boxes found in the lower 

4 portion of Label 1. Additionally, potential for color 

5 fading and difficulties with batch printing of 

6 variable data that are in color are issues. We will 

7 submit Hyundai's proposal for a black and white label 

8 which provides additional space for variable data. 

9 Fifth, we recommend that EPA and NHTSA move 

10 forward in this rulemaking with a method to assess the 

11 fuel efficiency of fuel cell vehicles. Hyundai 

12 intends to introduce this technology on a small scale 

13 in the not-too-distant future; this technology has 

14 been in development for many years and is well 

15 understood at this point so that a methodology can be 

16 developed now in anticipation of those vehicles. We 

17 prefer that the label methodology be ready when these 

18 vehicles are introduced. 

19 Finally, we ask for a minimum of 90 days 

20 lead time to adopt any changes rather than the 30 days 

21 proposed. Additional time beyond 90 days may be 

22 necessary depending on the design and color of the 

23 finalized label. Depending on the timing of the final 

24 rule, the agencies may also want to reconsider 
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1 application of the label to model year 2012 vehicles 

2 and instead require the label starting on a specific 

3 date. 

4 To summarize, Hyundai supports a letter 

5 grade or numerical rating such as 0-to-100 on an 

6 absolute scale, believes that the distribution of 

7 grades should be adjusted to provide more grade 

8 differentiation for consumers, supports a black and 

9 white label with a minimum of three months lead time 

10 for implementation and asks that fuel cell vehicle 

11 labeling be addressed in this rulemaking. 

12 Thank you. 

13 MR. MEDFORD: Thank you very much. Next is 

14 Mr. Oser. 

15 MR. OSER: Good afternoon. My name is Edward 

16 Oser, and I'm here representing Center for 

17 Neighborhood Technology, a 32-year-old think-and-do 

18 tank based here in Chicago. CNT combines rigorous 

19 research with on-the-ground results in four major 

20 areas of urban sustainability: Climate, energy, 

21 natural resources, and transportation and community 

22 development. Also, through constituent organizations, 

23 CNT coordinates comprehensive energy efficiency 

24 retrofits for multifamily low-income housing and runs 
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1 I-GO, a non-profit, car-sharing, low-emission, and 

2 citywide. 

3 On behalf of CNT, I am grateful to both the 

4 Environmental Protection Agency and the National 

5 Highway Traffic Safety Administration for the 

6 opportunity to comment on this proposed ruling. 

7 CNT stands firmly in support of a new 

8 grade-based vehicle labeling system, and does so for 

9 three primary reasons. 

10 First, labels provide consumers with 

11 valuable, easy-to-understand information on the true 

12 costs that go along with not just buying a vehicle, 

13 but with operating it as well. The simple truth 

14 behind the idea of labeling is that when people have 

15 better information, they make better decisions. 

16 Transportation costs are the second highest 

17 expenditures for American families next to housing, 

18 but people don't generally recognize this because the 

19 costs are disaggregated into a tank of gas here, a car 

20 payment there, and a repair or city sticker in 

21 between. The recession has stripped many Americans of 

22 their livelihoods, eroded savings, and plunged many 

23 further into debt. Americans now need every chance 

24 they can get to save. Labels that reward greater fuel 
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1 economy offer one of those chances. 

2 Second, CNT supports this effort from an 

3 environmental standpoint. According to the EPA, 

4 carbon emissions from passenger vehicles account for 

5 about 17 percent of America's contribution to climate 

6 change. In combination with renewed interest in 

7 public transit and available choices of efficient 

8 vehicles, the labels could help consumers lead the way 

9 in carving that percentage down. 

10 These new labels could, at the point of 

11 purchase, create a vital connection for the consumer 

12 between their choice of vehicle and the far broader 

13 implications that choice has for the environment and 

14 future generations. As more and more of these labeled 

15 vehicles become part of the American fleet, the result 

16 would likely be a slowing of America's carbon 

17 emissions. 

18 Finally, we support labels that are truly 

19 meaningful. That means labels that grade all vehicles 

20 -- cars, trucks, SUVs, and minivans -- on the same 

21 scale. The hard truth is that it doesn't matter to 

22 the atmosphere and the oceans whether carbon comes 

23 from the tailpipe of a hatchback or a Hummer. Grading 

24 cars and trucks on the same scale is not comparing 
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1 apples and oranges. It's comparing pollution and 

2 pollution. 

3 But if the end result of the grading 

4 produced a simplistic message that all large vehicles 

5 are bad and are equally bad, that would be inaccurate 

6 and would miss the purpose of the labeling. Some 

7 people want to own a truck, an SUV, or a minivan 

8 because they need more space or hauling capability. 

9 But according to EPA/DOT survey data, many trucks, 

10 minivans, and SUVs are available now that are actually 

11 more efficient than many cars. And the same data 

12 shows efficiency within vehicle categories varying 

13 dramatically. 

14 The labels can solve this dilemma 

15 elegantly. The labels should compare emissions and 

16 mileage on a single scale, regardless of vehicle type, 

17 and they should grade accordingly. But they can also 

18 provide a diverse array of metrics in addition to the 

19 letter grade. While walking around the car lot, 

20 consumers can use the additional information on the 

21 labels to compare mileage, emissions, and projected 

22 savings to find the best vehicle to suit their needs. 

23 And that includes the best truck, the best SUV, or the 

24 best minivan. Being able to make those comparisons 
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1 without getting a false impression of the vehicle's 

2 effects on the environment is the best, fairest 

3 balance the labels can hope to achieve. 

4 CNT recognizes the serious amount of 

5 thought and work that has gone into the creation of 

6 the draft labels and applauds the people at EPA and 

7 NHTSA who formulated those ideas and did that work. 

8 The results are impressive and CNT celebrates them. 

9 But meaningful labels also have meaningful cutoff 

10 points that properly identify the most and least 

11 fuel-efficient vehicles. Rating distribution should 

12 not be too heavily weighted to the center. There 

13 should be thicker tails on the ratings distribution, 

14 more A's and D's, if not F's, and fewer B's and B-. 

15 Reworking the distribution scale would come closer to 

16 the truth that not all vehicles are above average. 

17 That, for the environment and for everyday 

18 affordability, some vehicles are indeed failing. 

19 Nevertheless, CNT is enthusiastic about the 

20 prospect for a clearer, more robust, more modern 

21 labeling system that accurately and fairly identifies 

22 the affordability and environmental impact of the 

23 vehicles bought and sold in America. A labeling 

24 system that uses meaningful, strict cutoffs between 
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1 grades and grades all vehicles on a single scale has 

2 the potential to be a significant contributor in the 

3 efforts to stop climate change and to make 

4 transportation more affordable for everyday Americans. 

5 Thank you again for the opportunity to 

6 testify here today. 

7 MR. MEDFORD: Thank you very much. Ms. Bakker, 

8 I'm interested in some of your comments about the way 

9 the current label, the letter grade label, is 

10 proposed. You were saying that you think the advanced 

11 technology in electrics should be just removed and 

12 that's the way it's done in Korea. And then would you 

13 suggest changing the distribution system even if you 

14 take those out the way it's currently done? 

15 MS. BAKKER: We'd like to see the curve 

16 flattened. You're talking about keep the bell curve 

17 and just spread it out a little bit more? 

18 MR. MEDFORD: I think you suggested taking out 

19 those electric vehicles and that type out of the 

20 distribution system and just give them an A+; is that 

21 right? 

22 MS. BAKKER: Right. An A+ or special identifier. 

23 MR. MEDFORD: And that's how it's done in Korea? 

24 MS. BAKKER: Right. They have a unique 
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1 identifier. 

2 MR. MEDFORD: And then beyond that you want to 

3 change the distribution. 

4 MS. BAKKER: Right. We would want to flatten it. 

5 A bell curve where all the ratings are compressed. We 

6 want to see it much flatter so you get a fairer 

7 estimation across the scale. And if you move the A -- 

8 I'm sorry, the A and the A+ and the A- vehicles out, 

9 you get two additional grades. But, alternatively, if 

10 you go to a zero to 100 you get many more bandwidths 

11 and can spread it out that way. 

12 MS. DUNHAM: Actually, I was just going to ask, 

13 for both of you. I think both of you were suggesting 

14 something similar of having some kind of a different 

15 distribution if there were specific ways to do that. 

16 I mean, as -- I think what we've proposed right now is 

17 these increments of CO2 emissions. 

18 MR. MEDFORD: On either side of the -- 

19 MS. DUNHAM: On either side. I'm just trying to 

20 see if there's -- and, obviously, if you have further 

21 ideas that you want to submit written comments, too. 

22 MS. BAKKER: Well, we'll have a proposal in our 

23 written comments. 

24 MR. MEDFORD: You also said that in Korea, you 
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1 said that it would be okay to use a letter grade or 1 

2 to 5 numerical system or zero-to-100 scale. Is there 

3 one that you prefer? 

4 MS. BAKKER: So I think the zero to 100 is very 

5 preferable because you can get very fine distinctions 

6 between vehicles and there's ten categories that you 

7 can try to increase to get to. So people intuitively 

8 know that an A is 90 to 100 and 80 is 90 is a B. So 

9 if you're on the cusp, it gives an incentive to 

10 improve performance. So we like the letter grade, but 

11 we're worried about the distribution. That's one way 

12 to fix it. It's just a numerical version of the same 

13 thing. 

14 MR. MEDFORD: And then you also said -- I missed 

15 the time for the introduction of the fuel cell vehicle 

16 that you said there should be a special label 

17 provided. 

18 MS. BAKKER: We intend to use some fuel cell 

19 vehicles on a small scale in 2012. 

20 MR. MEDFORD: As a part of your regular retail 

21 sales or demonstration program? 

22 MS. BAKKER: Perhaps beyond a demonstration 

23 program. 

24 MR. MEDFORD: That's really all I have. 
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1 MS. DUNHAM: Just a quick follow-up. If you can 

2 possibly provide either some references or more 

3 information on Korea's labeling program. 

4 MS. BAKKER: It's probably in Korea. 

5 MR. MEDFORD: Thank you very much. 

6 MS. DUNHAM: The next panel, let me just see if 

7 folks are here. Is Laura Knezevic here? Great. If 

8 you can come forward. And Lucinda Hohmann, are you 

9 here as well? Great. If you can both come up here 

10 and take a seat. 

11 MS. KNEZEVIC: Good afternoon. My name is Laura 

12 Knezevic, and I'm the director of the Illinois Student 

13 Environmental Coalition. Our organization represents 

14 thousands of students from over 40 college and 

15 university campuses across the state. Our members 

16 come from diverse backgrounds, but all share the same 

17 concern for our environment and the challenges global 

18 warming will present to our generation. 

19 I am here on behalf of our members, to 

20 share their concerns about the impact of vehicle 

21 emissions on our environment and atmosphere. The 

22 implications of global warming are well understood and 

23 the emissions from our cars and SUVs are a major 

24 contributor to this problem. Any tool that the EPA 
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1 can give to consumers to make more informed choices 

2 regarding the environmental impact of a purchase is 

3 strongly supported by our coalition. 

4 Many products tout themselves as having 

5 environmentally beneficial features, but few have the 

6 accurate measures to back up those claims. This 

7 proposed regulation would give credibility to the fuel 

8 economy listed on new cars. We strongly support the 

9 use of the most accurate methods of measuring the fuel 

10 economy of a vehicle in order to give consumers the 

11 best information possible when purchasing a new car. 

12 We also support the newly designed label that would be 

13 displayed on each car, as it gives a clear and 

14 accurate description of the fuel economy that one 

15 should expect from each vehicle in realistic driving 

16 conditions. In addition, we urge you to include the 

17 large SUVs that had previously been exempt from this 

18 rule. 

19 An update to this regulation is long 

20 overdue and would present no further burden on car 

21 manufacturers than the current requirements. 

22 Consumers should have the most accurate information 

23 available to them when purchasing an item that has 

24 such large environmental impacts. We hope you take 
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1 our concern into consideration and we thank you for 

2 your time. 

3 MS. DUNHAM: Thank you. 

4 MS. HOHMANN: My name is Lucinda Hohmann. I work 

5 in the Midwest office here in Chicago with the Union 

6 of Concerned Scientists, or UCS. With over a quarter 

7 of a million supporters nationwide, UCS is a leading 

8 nonprofit partnership of scientists and citizens 

9 working for healthier air, cleaner transportation, and 

10 a safer world. We applaud the EPA and NHTSA for their 

11 good work to date on this rulemaking and for the 

12 opportunity to give comments today here in Chicago. 

13 I would like to summarize a few key 

14 principles, thoughts, and reactions raised by the 

15 proposed fuel economy labels in this rule. 

16 Firstly, we are very supportive of an 

17 overall letter grade metric as something that is 

18 relatively simple and understandable to the average 

19 consumer. We believe it makes sense to include a 

20 letter grade in your final label design. 

21 We are also strongly supportive of the 

22 decision to use a single fleet-wide scale as an 

23 accurate reflection of the relative efficiency and 

24 environmental performance of each vehicle model. We 
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1 would not support a so-called class-based system as 

2 the primary metric for measuring vehicles. A 

3 class-based system would create confusion among many 

4 consumers. For example, they would see a cleaner more 

5 efficient vehicle getting a lower grade than a dirtier 

6 less efficient vehicle. So it would be confusing and 

7 it wouldn't be clear for consumers. 

8 We believe the final design should be 

9 relatively simple, easy on the eye, and to the extent 

10 possible uncluttered. Additionally, we strongly 

11 support the decision to use color as part of the 

12 design as a purely black and white label is less 

13 likely to be eye-catching. 

14 We certainly support the inclusion of the 

15 criteria pollutant emissions comparison information in 

16 some form. However, the term smog is surprisingly 

17 absent in the draft labels. Consumers may not quickly 

18 comprehend what is meant by the phrase "other air 

19 pollutants," and so we would recommend to incorporate 

20 the word smog in that portion of the label. 

21 We very strongly urge the agencies to build 

22 upon the good work that you've done to date by 

23 adjusting your overall calculations to include 

24 relevant upstream emissions for vehicles. Consumers 
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1 want accuracy. And with the expected and desired 

2 increase in manufacturing and sales of cleaner, 

3 advanced technology vehicles, tailpipe emissions alone 

4 would not necessarily achieve an accurate reflection 

5 of overall environmental performance. So, again, 

6 including the calculation of upstream emissions. 

7 Finally, we fully support the inclusion of 

8 the dollar amount of savings or additional amounts 

9 that would be spent, as the case may be, in fuel 

10 costs. This is a helpful piece of information for 

11 consumers. 

12 Updating the design of the fuel economy 

13 label is an important component of getting cleaner, 

14 more efficient vehicles on our roads and highways, and 

15 we support the agencies' efforts to update and improve 

16 upon the old label design. My colleague in California 

17 will be offering more detailed testimony at the 

18 hearing in LA next week. But, once again, I 

19 definitely thank you for your good work so far and for 

20 the opportunity to be here today. 

21 MS. DUNHAM: Thank you. 

22 MR. MEDFORD: I had one question for Ms. Hohmann, 

23 or maybe a couple questions. You said relative 

24 upstream emissions. Is that just for electric 
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1 vehicles or for all vehicles? Do you care about -- 

2 MS. HOHMANN: For all vehicles. 

3 MR. MEDFORD: No matter what fuel type? 

4 MS. DUNHAM: Exactly. 

5 MR. MEDFORD: And you said that the final label 

6 should be easy on the eye. Do you think any of these 

7 two that we co-proposed are easy on the eye? 

8 MS. HOHMANN: I do. Especially the first one. I 

9 think, again, the letter grade is real important. I 

10 think it's very clear and understandable to consumers, 

11 and I think the layout is very clear. 

12 MR. MEDFORD: What do you think about what the 

13 Hyundai representative said about going to a one to 

14 five scale or zero to 100 scale? Do you think that's 

15 a good or bad idea? 

16 MS. HOHMANN: I thought it was very interesting. 

17 I hadn't heard that before. But I do think the letter 

18 grade is still clear. I understand the concern, but 

19 from a consumer's point of view because there is so 

20 much information that the clearest label would be the 

21 letter grade metric. 

22 MS. DUNHAM: I just actually want to ask 

23 Ms. Knezevic your opinions or thoughts on putting a 

24 letter grade on the vehicles. 
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1 MS. KNEZEVIC: We also think that a letter grade 

2 would be the clearest way to convey to consumers the 

3 fuel efficiency of the car. 

4 MS. DUNHAM: Thank you very much. 

5 MR. MEDFORD: I think that's it for this noon 

6 time session. I think we're going to reconvene back 

7 at 6:00; right? Or is there -- 

8 MS. DUNHAM: Unless if anyone else has signed up 

9 or would wish to talk. 

10 MR. MEDFORD: If not, we'd like to thank you, 

11 everyone, for coming to the hearing today and we very 

12 much value your input and we'll be reconvening at 6:00 

13 p.m. Thank you. 

14 (WHEREUPON, a break was had.) 

15 MS. DUNHAM: Welcome. Good evening. We are 

16 going to reconvene our evening session here for the 

17 panel. I'm just going to go through a quick reminder 

18 of some of the rules that we talked about earlier 

19 today and before I call up our panel. 

20 If there is just -- also, if anyone here 

21 does want to testify who hasn't signed up, please sign 

22 up at the table outside. We are going to ask, like we 

23 did this afternoon, that each person keep their 

24 testimony to no more than ten minutes. And when the 
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1 witnesses on the panel are finished, those on the 

2 governmental panel here will have the opportunity to 

3 ask questions. 

4 We are going to conduct this hearing 

5 informally and formal rules of evidence will not 

6 apply. As the presiding officers, we are authorized 

7 to strike statements from the record that are deemed 

8 irrelevant or needlessly repetitious and to enforce 

9 reasonable limits on the duration of the statement of 

10 any witnesses. So those are just the formal part of 

11 this. 

12 So let me just with that call up the panel. 

13 Scott Becker, please join us at the panel, and Mike 

14 Duoba. Let me just confirm that Dennis Nelson has not 

15 joined us this evening. 

16 If you all will please just take a second 

17 and put your names on the little pieces of paper. One 

18 more reminder. If you can remember to speak slowly 

19 and clearly so we can keep a record of what you say. 

20 Mr. Becker, whenever you're ready. 

21 MR. BECKER: Thank you very much, and good 

22 evening. Before I start, once again, thank you for 

23 your patience. I just arrived from the airport and I 

24 do apologize for being late. 
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1 My name is Scott Becker, and I am the 

2 senior vice president for administration and finance 

3 with Nissan North America, Inc., based in Franklin, 

4 Tennessee. My responsibilities include ensuring that 

5 Nissan is positioned in the U.S. market to sell cars 

6 Americans want to buy and to make sure we do so in a 

7 way that promotes safety and a clean environment. 

8 As public policy around fuel economy took 

9 center stage, Nissan embraced those efforts, announced 

10 the Nissan Green Program and supported the Energy Act 

11 of 2007. At Nissan, we are investing in 

12 hypertechnology and continuing to improve our 

13 traditional vehicle fleet. Indeed, we've already 

14 improved the fuel economy of our passenger car fleet 

15 by well over 10 percent since 2005 and will continue 

16 to leverage advances in traditional technologies and 

17 safe weight reduction strategies to make further 

18 gains. 

19 As we do so, we will continue to bring to 

20 market hyperelectric vehicles and full battery 

21 electric vehicles. EVs are important, but we 

22 recognize that they are only a portion of the total 

23 vehicle population. Government can mandate more 

24 efficient fleets and automakers can build more 
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1 efficient vehicles, but the ultimate test will be 

2 public acceptance of those vehicles. 

3 The public must be well-informed of the 

4 benefits of these new technologies. The label 

5 proposal is a significant step toward providing 

6 consumers with the information they need. We fully 

7 support this effort. Our research indicates that 

8 consumers want specific information that allows them 

9 to make comparisons between the vehicles they are 

10 considering. They also want information that is 

11 tailored to their individual likely use of those 

12 vehicles. 

13 A label that merely compares vehicles 

14 across classes and provides less specific information 

15 will be less useful in influencing consumer behavior. 

16 The labels should, therefore, be geared toward the 

17 specific vehicle type. It is important to continue 

18 providing highway and city fuel economy for 

19 traditional vehicles that will continue to be used in 

20 traditional ways. Since electric vehicles will be 

21 driven mostly in the city, the city fuel economy 

22 should be emphasized for those vehicles. 

23 Miles per gallon or miles per gallon 

24 equivalent should continue to be the main 
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1 informational focal point, followed by annual fuel 

2 cost and driving range. The labels should continue to 

3 provide consumers primarily with the information they 

4 have traditionally relied upon and secondarily provide 

5 new information that promotes their understanding of 

6 new technologies. 

7 The information that is provided about new 

8 technologies and particularly the electric portion of 

9 new power trains, will be critical to developing 

10 consumer acceptance of those technologies. Financial 

11 support for technology development and 

12 commercialization is just one aspect of what is 

13 necessary to make revolutionary reductions in tailpipe 

14 greenhouse gas emissions. 

15 No matter how much we invest in the 

16 technology, American consumers must endorse the 

17 benefit of electric power trains and must themselves 

18 be willing to embrace a new form of transportation. 

19 Government sponsored information is critical to 

20 influencing public perception. American consumers 

21 rely on the government to provide them with 

22 information that is accurate and is responsive to 

23 their concerns. When it comes to vehicles, those 

24 concerns fall into a few clearly defined areas. 
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1 Vehicles must be reliable and safe, they must be fuel 

2 efficient to keep operating costs down, and 

3 increasingly they must be environmentally friendly. 

4 At Nissan, we've seen remarkable interest 

5 in the 100 percent electric Nissan Leaf. Within ten 

6 months of unveiling the Nissan Leaf 230,000 people 

7 raised their hands looking for more information and 

8 20,000 have placed a deposit. We should, however, 

9 resist the temptation to draw larger conclusions from 

10 this early consumer reaction. While there is interest 

11 from across the United States, Nissan Leaf 

12 hand-raisers and reservationists are environmentally 

13 concerned early adopters. They are the same people 

14 that purchased the first hybrids. A large percentage 

15 come from states that have been traditionally more 

16 environmentally conscious. The challenge is to 

17 nationalize this interest to make electric-based 

18 vehicles a permanent feature of the U.S. fleet. 

19 We are not introducing the Nissan Leaf as a 

20 response to regulation. We're introducing it to 

21 create a new long-term solution. The first round of 

22 rulemaking covering an initial set of model years has 

23 expanded the public dialogue from a focus just on fuel 

24 economy to one focused on both fuel economy and CO2 
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1 emissions. The next round of rulemaking is moving the 

2 focus away from stringency levels and program 

3 structure toward a focus on ensuring that advanced 

4 technology vehicles get a strong and sustainable 

5 foothold in the United States vehicle market. 

6 The information provided to consumers on 

7 the label through government Web sites and by ratings 

8 organizations is going to define the extent to which 

9 consumers are willing to give electric-driven vehicles 

10 a try. 

11 The agencies' technical report reflects the 

12 difficulties facing alternative technology vehicles. 

13 The table set forth in the report show the different 

14 technology pathways forward suggests that for 

15 consumers, advanced gasoline vehicles combined with 

16 weight reduction will impose lower initial costs and, 

17 depending on the technology, lower lifetime operating 

18 costs than advanced technology vehicles. This is not 

19 surprising, as it merely confirms that new 

20 technologies are more expensive until the economy of 

21 scale for these technologies can be achieved. It does 

22 highlight, however, the need for regulatory support 

23 for new technologies. 

24 Our experience so far with the Nissan Leaf 
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1 demonstrates that our initial EV consumers have a high 

2 level of environmental awareness. They understand 

3 that traditional vehicles run on fuel, resulting in 

4 greenhouse gas emissions from the tailpipe. They 

5 understand that sustainable change is incremental. 

6 They can make a difference by being early adopters and 

7 purchasing a vehicle with no tailpipe emissions. 

8 Interestingly, although we did not initially plan to 

9 display a zero emission vehicle label on the consumer 

10 (unintelligible), it had been displayed on some of the 

11 prototypes. 

12 We have been inundated with consumers 

13 requests to add this label. We understand the concern 

14 about upstream emissions from energy-generating 

15 facilities that power our electrical grids. Nissan 

16 Motor Company and Nissan North America have long 

17 advocated for the current development of renewable 

18 fuels to support the development of battery-powered 

19 vehicles. Notwithstanding the slow pace of developing 

20 cleaner energy sources, as a carmaker we are doing our 

21 part by bringing electric vehicles to market. 

22 Discouraging the proliferation of electric 

23 vehicles by devaluing their contribution to a cleaner 

24 environment does nothing to solve the upstream 
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1 emissions issue. On the contrary, using every 

2 available government resource to encourage the 

3 widespread acceptance of battery-powered vehicles will 

4 create a fleet that will in turn drive a need and a 

5 public demand for low emissions electricity to support 

6 it. Discouraging the growth of that electric fleet by 

7 diminishing the way in which the environmental 

8 benefits are presented to the public will serve only 

9 to reduce the market for electric-powered vehicles and 

10 to delay further serious advancements in low emissions 

11 electricity. 

12 Nissan's global commitment to alternative 

13 technology vehicles and to the improvement of 

14 traditional power trains will not waiver, nor will our 

15 continued commitment to work toward the growth of 

16 infrastructure to support electric vehicles and a 

17 marketplace prepared to accept them. 

18 With an eye towards the long-term 

19 environmental benefits of zero emissions vehicles 

20 combined with lower emissions electricity, government 

21 programs should embrace and encourage automakers in 

22 advancements in battery development and the widespread 

23 commercialization of electric vehicles. While the 

24 environmental impact of traditional power sources is 
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1 an issue that we must all work to help resolve, 

2 devaluing electric vehicles in the eyes of consumers 

3 does nothing to further this end. 

4 Nissan will supply the agencies with more 

5 specific comments on many of the detailed aspects of 

6 the label proposal. In general, we strongly encourage 

7 the agencies to maintain their support of 

8 battery-powered vehicles and we look forward to 

9 working with you for creating a market for alternative 

10 technology vehicles. 

11 Once again, thank you very much for the 

12 opportunity to meet with you today. 

13 MS. DUNHAM: Thank you. Mr. Duoba. 

14 MR. DUOBA: My name's Mike Duoba. I'm 

15 representing myself I guess because originally I was 

16 not going to testify because I'm not representing the 

17 national group I work for or the agency that funds my 

18 research. I've been working in electric and 

19 alternative fuel technology for actually 22 years and 

20 have dedicated my entire career to getting these 

21 technologies, you know, ready for mass market. So I 

22 feel like, you know, sitting here talking about this 

23 stuff is kind of like it's first and goal. We only 

24 have a few plays left to call. And it's very 
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1 important that we make the most intelligent play as 

2 possible because we're right at the goal line here. 

3 And I do appreciate the big task of putting ten pounds 

4 of stuff in a five-pound bag which is essentially some 

5 of the challenges involved with taking legacy mile per 

6 gallon and labeled statutory requirements and taking 

7 this new fangled car and trying to cram it into that 

8 construct. 

9 But I have some very important observations 

10 and recommendations that many of them I'm sure match 

11 all the other experts that I've talked to every day 

12 regarding these issues in this pretty much very 

13 specific field. The recommendations are based upon 

14 many years of test procedure development for hybrids 

15 and plug-in hybrids and electric vehicles. I tested 

16 my first plug-in hybrid in 1994. I was the chair of 

17 the society of automobile engineers task force and 

18 development procedures of the J1711. I'm also the 

19 co-chair and co-developer of the new procedures that 

20 are still under development for electric vehicles. So 

21 with that little introduction, that's where I come 

22 from. 

23 The conventional label discussion that 

24 we've had so far, we've had some good discussion. I 
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1 think we understood the need -- or I understood the 

2 need that we would need a better resolution to score 

3 these vehicles as a letter grade, that the issue we're 

4 having between putting this type of vehicle in a 

5 specific class and all of the vehicles together. We 

6 need more resolution, so I would support the proposal 

7 that Hyundai mentioned earlier where you have this 

8 zero to 100 scale. It looks like a grade that you 

9 would have on a test, just like a letter grade, and 

10 you're within a specific class of vehicles and you can 

11 still decide which one is better than the other. 

12 There will be no incentive for a better, higher 

13 performing SUV if they all get a score of or D- or D+ 

14 or whatever. 

15 What we haven't talked too much about is 

16 the battery electric vehicles and plug-in hybrid 

17 vehicles. First thing I want to mention is that the 

18 second label that has the PHE bar that shows the range 

19 and associated consumption metrics is a very good 

20 tool. I think that there's the two labels, and one 

21 has that and one doesn't. If you want to educate the 

22 consumers, even the ones who are never thinking about 

23 an advanced vehicle, they can look over the label and 

24 say, Now I get what these cars are all about. For 30 
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1 miles they have this operational mode. So I think 

2 that's really important to keep that -- so no matter 

3 what design you go with, whether the letter grade is 

4 predominantly displayed or not, keep that. That's a 

5 very important tool I think. I don't think there's 

6 enough room in the first label to do that. 

7 So, anyway, let's move on to MPGE. So if 

8 there's one thing that we have to maybe retool and 

9 rethink is MPGE. We got to change this metric 

10 somehow. It kind of undermines the very reason why 

11 we're writing the label to inform consumers. Gasoline 

12 and electricity cannot be converted back and forth, 

13 like converting miles into kilometers. That's just 

14 not how physics works. You know, I understand you're 

15 trying to adhere to statutory language. You have to 

16 have MPG on there. But in fact, you're providing 

17 misleading information. 

18 So let's take a step back. Why are we 

19 posting MPG in the first place? The fundamental 

20 reason is that we're trying to show how much petroleum 

21 we're going to use. This is, you know, why CAFE was 

22 put in place and the other things that we're trying to 

23 display and reduce the amount of consumption of 

24 petroleum. Certainly it's a goal of the Department of 
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1 Energy to reduce the import of petroleum. That's the 

2 number one thing that DOE is interested in. So 

3 nothing's really changed except that we want to add 

4 CO2 as an additional piece of information. But if we 

5 want to, if we want to -- if you're using MPGE, we're 

6 giving the wrong message on what a gallon of gas is 

7 anymore. In a way, we're arbitrarily telling -- the 

8 EPA is arbitrarily telling the consumer that the 

9 electric vehicle is two to three times more preferred 

10 than gasoline because the efficiency you will get. 

11 You know, a 98 mile per gallon car is about as 

12 efficient getting energy from its energy source to its 

13 wheels as a 30-something mile per gallon car. So by 

14 giving it a 98 per gallon equivalent answer for an 

15 electric car, you're already saying this is how much I 

16 favor electricity over gasoline. Whereas, a 98 mile 

17 per gallon equivalent battery electric vehicle isn't 

18 consuming any petroleum. The grid only has less than 

19 1 percent of petroleum going into its mix. This is 

20 the domestic fuel, and none of its imported. So it's 

21 really important to make these distinctions. If a 

22 consumer comes to the mind set of, I'm only interested 

23 in finding what the petroleum usage of this vehicle 

24 is, petroleum usage is obscured in the current label, 
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1 especially for plug-in hybrids and especially for 

2 Clemens (inaudible) plug-in hybrid, which I'm mixing 

3 and I'm not mixing it up enough and it's murky brown 

4 stuff which is called MPGE, and I don't have any idea 

5 where that energy came from. 

6 Let's talk about CO2 emissions for a 

7 second. I fully understand that in coming up with a 

8 single number for CO2 upstream is kind of difficult. 

9 It depends on where you live. It depends on all these 

10 other things. But there's some people at Argonne 

11 National Laboratory that have been doing life cycle 

12 analysis for decades and, you know, they had a lot of 

13 input on renewable fuels, you know, that was recently 

14 put in place. And, you know, there's some assumptions 

15 you have to make going into that over a single answer 

16 or we need to go over the range of answers. 

17 But either way, the drive cycle which is 

18 where we base what our fuel economy is is an 

19 assumption of a range speed and acceleration rates 

20 we're going to encounter. The urban drive schedule is 

21 an assumption. It's an a assumption. And based on 

22 the assumption, you'll score a certain number. And 

23 even the five cycle fuel economy label that we're 

24 talking about includes a certain assumption that 
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1 you'll be driving in cold weather or hot weather or, 

2 as you know, people in Arizona -- I'm still 

3 speculating on a five cycle label. But somehow, you 

4 know -- which includes a lot of heater usage. I'm not 

5 going to use the heater hardly at all, maybe a month 

6 or so in the winter. 

7 So other aggregate values exist on the 

8 label and the cost -- like I said, there was 

9 procedure. So we shouldn't be too timid about coming 

10 up with a number that has some certain assumptions, 

11 but at least be able to gauge whether or not a certain 

12 vehicle technology is in the same ballpark as another 

13 one. So I don't think -- I know there's statutory 

14 requirements or some precedence maybe that you're 

15 using tailpipe only emissions. You know, I don't 

16 think the people that wrote the original rules thought 

17 it was a good idea to have EPA obligated to provide 

18 misleading information to say that there's no CO2 

19 impact on an electric car. Some people might not go 

20 to the Web site and fully understand what that means. 

21 Okay. One point on the slider bars that I 

22 thought is important to point out. The slider bars 

23 are a good idea to, you know, to show relative, you 

24 know, consumption or whatever. But the point is 
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1 you're reinforcing the MPG illusion if you're using 

2 MPG on the slider bar. You have these very 

3 high-consuming vehicles all bunched on one slide and 

4 all the low consuming vehicles all spread out on the 

5 other slide. If you want to acclimate consumers to 

6 understand what the consumption rate of a car is, 

7 whether a certain number is high or low, that's a 

8 perfect opportunity to put it on a slider bar. So my 

9 recommendation is the slider bar should be consumption 

10 only. 

11 People are starting to know what a 40 MPG 

12 car is, it's a pretty high mileage car. We, you know, 

13 heard the hybrid numbers are in The 40s and 50s and so 

14 forth. So we don't need to train people on what a 

15 high MPG number is. What we need to train them on is 

16 what a consumption number is. Maybe we need more 

17 slider bars or maybe a slider bar for each criteria or 

18 whatever. 

19 But I guess, you know, to conclude the 

20 comments I have, we all understand that the MPG metric 

21 was something used because it correlated with, you 

22 know, fuel costs and it correlated with, you know, 

23 upstream emissions, you know, just total life cycle 

24 emissions and so forth. The problem is that we have 
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1 advanced technology vehicles, but it's a 

2 two-dimensional vehicle and we have to address -- we 

3 have to address the impact of these vehicles 

4 separately. There's petroleum usage and there's the 

5 CO2 emissions, and they're two separate things. You 

6 might encounter a consumer that doesn't have any 

7 concern over CO2 emissions. He's, you know, read 

8 certain articles and believes and says that, I'm just 

9 interested in petroleum and apple pie and you 

10 producing petroleum. There might be somebody who's, 

11 you know, very avid about the CO2 emissions at all 

12 costs. They need to be able to make the correct 

13 purchasing decision and an obscure mixture of these 

14 metrics, you know, is something we got to avoid. So 

15 especially, like I say, for a plug-in hybrid. Do not 

16 be afraid to break those out and worry about the total 

17 numbers and so forth. 

18 So, again, if you're going to report a mile 

19 per gallon we shouldn't be afraid that there might be 

20 a really high number. Like, for example, a plug-in 

21 hybrid in blended mode would have this strangely high 

22 amount per gallon, but that's okay because that's the 

23 miles per gallon of petroleum that we're consuming. 

24 You have to show that on a slider bar, perhaps, that 
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1 gives you consumption because then zero consumption is 

2 a number that I can wrap my brain around. Infinity 

3 miles per gallon is something that we never had to 

4 worry about before, but I guess we do now because we 

5 have advanced vehicle technology that is displacing 

6 petroleum, which may not mean high efficiency. 

7 So anyway, I think that's the end of my 

8 comments. And I guess I would point out that if 

9 there's any questions or anything along this process, 

10 you can call me any time and we'll be able to talk 

11 about this at any time. 

12 MS. DUNHAM: Thank you. 

13 MR. MEDFORD: So, Mike, if you don't use miles 

14 per gallon equivalent, what do you use? 

15 MR. DUOBA: Well, if it's an electric vehicle -- 

16 MR. MEDFORD: Yeah. 

17 MR. DUOBA: You can show its electric consumption 

18 or you can show -- if kilowatt hours per mile or 

19 whatever is not a metric that people might be familiar 

20 with, what is the impact of electricity usage? It's 

21 CO2 emissions upstream and it's cost. 

22 MR. MEDFORD: But, you know, consumers are so 

23 interested in and aware of making these comparisons 

24 across classes. You know, if you just provide the 
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1 consumption in electrical terms, they're not going to 

2 understand what that means. 

3 MR. DUOBA: Right. There's an idea I have. I'm 

4 kind of calling it a mile per gallon index, and that 

5 is that you have to limit yourself to a specific 

6 question. You know, the mile per gallon would answer 

7 all these questions, but now if you have a specific 

8 question that says what is my -- you know, what is my 

9 petroleum usage, then your answer is that it's zero or 

10 infinity or whatever, and that's your answer. And 

11 consumption is zero. But when I'm asked the question 

12 of what's my fuel cost or energy cost, you might be 

13 able to say it's the same as a conventional vehicle 

14 that got 130 miles per gallon. If you want to say 

15 what's my greenhouse gas index in mile per gallon, you 

16 can say it's as much as a nonplug-in car, a 

17 conventional car, that got, you know, 75 miles per 

18 gallon. They're an equal comparison. So that's one 

19 idea that I've been throwing around. 

20 In each of these criteria bins, you can 

21 say, Oh, the impact is the same as the car, 

22 conventional car that we're used to. It's equal to 

23 the performance of that car that we're used to. 

24 But when you report an electric vehicle in 
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1 miles per gallon, you know, it's something that early 

2 on I think everybody has played around with. I 

3 reported results back in the mid '90s in this fashion 

4 and I think everybody who's done testing on these cars 

5 has realized that, you know, it's kind of like not 

6 giving us an answer that's not helping us. It's kind 

7 of obscuring things a little bit. 

8 So if it's an electric car and it has a 

9 consumption rate of electricity, then that's the 

10 answer. And I know that you have to come up with some 

11 MPG on the label, but maybe you can say it cost as 

12 much as a car that got 150 miles per gallon or 

13 something. 

14 MR. MEDFORD: So you suggest actually additional 

15 slider bars beyond the bars that are there, basically 

16 the ones that are required by the statute. You think 

17 more wouldn't confuse consumers? It would help them? 

18 MR. DUOBA: Well, I think for plug-in hybrid you 

19 have more information to give. You have to give it in 

20 depleting mode and sustaining mode. And I guess the 

21 real question is do you want slider bars for those 

22 separate modes or do you want one that's a utility 

23 factor aggregate version. I don't have an opinion 

24 either way on how to do that. But if what is shown 
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1 now where there's miles per gallon and there's a miles 

2 per gallon equivalent for a plug-in hybrid, I have no 

3 idea how much of that miles per gallon came from 

4 electricity and how much came from fuel, it's not 

5 sending the wrong message. It's just not sending any 

6 message. There's no message there at all. And 

7 someone's going to take that and say, this car has a 

8 higher number than that car. But from what? You 

9 know, the fact that a gallon of gasoline has 33.7 

10 kilowatt hours of heat energy in it, and 33.7 kilowatt 

11 hours of electricity can provide that much heat, 

12 doesn't mean that they're all equal. That just means 

13 they can provide that much heat. They can heat this 

14 room, but they can't drive the car that way. 

15 MR. MEDFORD: Okay. And you also suggested that 

16 we go to a zero-to-100 scale, not the letter grade 

17 because -- 

18 MR. DUOBA: I agree that more resolution is 

19 better. I noticed that everybody's got a different 

20 opinion within a class or not within a class. Well, 

21 in the information that's provided, we can do both, 

22 and that's what you need. And I think the slider bar 

23 with that whole section of SUVs or whatever is a good 

24 idea. Again, it's consumption-based and not 
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1 miles-per-gallon-based. It will help out. If you 

2 have a higher resolution, that would be fine. I don't 

3 know whether or not a letter grade is going to hit 

4 home with more consumers than a number that's like at 

5 95 verses an 85 or something like that. 

6 MR. MEDFORD: Mr. Becker, you didn't express a 

7 view about, almost everyone has, about the letter 

8 grade, and I wondered if Nissan had developed a 

9 position yet or you're waiting for your written 

10 comments? 

11 MR. BECKER: Our view is that -- our preference. 

12 Our preference is Label No. 2. And you'll see in our 

13 written comments for us. Our view is based on what 

14 we've seen from our customers and research that miles 

15 per gallon or miles per gallon equivalent is really a 

16 key informational point that consumers look to as a 

17 basis of comparison followed by the annual fuel cost 

18 and then after that by the driving range. Our view is 

19 that Label No. 2 better conveys this information to 

20 consumers, and our research shows that we believe 

21 consumers find that information more helpful. 

22 MR. MEDFORD: You also said that you thought that 

23 for electric vehicles because of the way they're used, 

24 there should be a different kind of emphasize for 
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1 city -- I think you used the word emphasis for city 

2 versus city/highway which is used traditionally. 

3 MR. BECKER: Correct. 

4 MR. MEDFORD: How would you do that? When you 

5 say special emphasis, what did you have in mind? 

6 MR. BECKER: We think the label should emphasize 

7 the city number. 

8 MR. MEDFORD: Bigger? Bolder? 

9 MR. BECKER: Yes. 

10 MR. MEDFORD: Okay. 

11 MS. DUNHAM: Just to follow-up, your reference to 

12 the research that you've done with your consumers, is 

13 that the consumers specifically who purchased or done 

14 a deposit on the Leaf or more broadly. 

15 MR. BECKER: We've done some research with our 

16 Leaf customers, or those that have expressed interest 

17 in the Leaf. 

18 MS. DUNHAM: And you tested with them these 

19 specific labels or more in terms of concept of what 

20 information they're looking for? 

21 MR. BECKER: Yes, we have. And the conclusion we 

22 have from that consumer research is that Label No. 2 

23 is more consumer friendly. 

24 MR. MEDFORD: Listen, is there anyone else in the 
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1 audience that wants to testify that has hadn't had a 

2 say today? Okay. Listen, we'd like to thank -- many 

3 of you have been here all day or all afternoon and 

4 evening. So, first of all, thanks to Scott and 

5 thanks, Mike, for testifying today. We appreciate 

6 that this evening. And we thank everyone that 

7 participated today, and I think we're finished. Thank 

8 you. 

9 (A short break was had.) 

10 MR. MEDFORD: Could you introduce yourself, 

11 Mr. Nelson. 

12 MR. NELSON: It's in the remarks. 

13 My remarks in favor of Option 1 for the 

14 improved newer and more improved fuel economy labeling 

15 for new automobiles and light trucks. My name is 

16 Dennis R. Nelson, and I reside at 19 East Ohio Street, 

17 No. 1204, Chicago, Illinois, 60611-2707. 

18 Being an energy researcher, my remarks are 

19 part of my continuing personal celebration of being an 

20 effective energy environmental activist for more than 

21 40 years now starting with the time around the first 

22 Earth Day. I am the president of the Chicago-based 

23 Nuclear Energy Information Service, NEIS, Illinois's 

24 environmental/safer energy no nukes group, which 
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1 supports better transportation vehicle fuel economy 

2 labeling as an important part of a 

3 carbon-free/nuclear-free energy pathway. 

4 Again, I support Option 1 for the improved 

5 newer fuel economy labeling for new cars and light 

6 trucks because the present design for fuel economy 

7 labels is over 30 years old. We should be updating 

8 them now. These proposed newer labels will give us 

9 better information to protect the environment and our 

10 wallets or purses. There are two newer label designs 

11 and both offer us, No. 1, fuel efficiency compared to 

12 other vehicles; No. 2, global warming pollution and 

13 other tailpipe emissions relative to other vehicles; 

14 No. 3, fuel cost savings for the vehicle; No. 4, a 

15 Web site link, which can give personalized estimates; 

16 No. 5, the ability to receive additional information 

17 over the phone. 

18 However, I support Option 1 because it also 

19 gives a letter grade which reflects both the fuel 

20 efficiency and greenhouse gas emissions over a 

21 five-year period based upon an average vehicle as well 

22 as fuel cost savings. These letter grades will make 

23 purchasing a new auto or light truck much easier. 

24 Number 1, the letter grade offers a 
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1 simpler, easy-to-understand format. It also provides 

2 a central focus that gives information on performance 

3 of that vehicle as compared to others. 

4 Number 2, a letter grade for a new vehicle 

5 provides us with a single bit of data which is 

6 instantly familiar and meaningful. Kind of like a 

7 health and safety guide for a restaurant. 

8 Number 3, a label with the letter grade 

9 contains additional information and provides an easier 

10 to remember representation of the more detailed 

11 information contained in the remainder of label and 

12 the Web site. Thank you. 

13 MR. MEDFORD: Thank you. 

14 MS. DUNHAM: Thank you very much. 

15 MR. MEDFORD: Now I think we're all done. 

16 (Which were all the proceedings 

17 had in the above-entitled cause.) 

18

19

20

21

22

23

24
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1 STATE OF ILLINOIS ) 

 ) SS 

2 COUNTY OF COOK ) 

3 

4 Kelly A. Siska, being first duly sworn, on 

5 oath says that she is a Certified Shorthand Reporter, 

6 Registered Professional Reporter, and Certified 

7 LiveNote Reporter doing business in the City of 

8 Chicago, County of Cook and the State of Illinois; 

9 That she reported in shorthand the 

10 proceedings had at the foregoing meeting; 

11 And that the foregoing is a true and correct 

12 transcript of her shorthand notes so taken as 

13 aforesaid and contains all the proceedings had at the 

14 said meeting. 

15 

16 

 ____________________________ 

17 KELLY A. SISKA, CSR, RPR, CLR 

18 

19 

20 C.S.R. No. 084-002761 

21 SUBSCRIBED AND SWORN TO 

before me this___day of 

22 ___________ A.D., 2009. 

23 

_______________________ 

24 NOTARY PUBLIC 
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ability 119:16

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average 21:1 28:23

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averages 28:6

avid 111:11

avoid 21:15 44:12

111:14

award 44:5

aware 64:8 73:2

112:23

awareness 101:2

A's 61:1 84:14

A.D 121:22

B

B 12:19 25:12,13

36:22 52:22 54:13

57:16 77:5 84:14

87:8

back 30:4 56:23

63:10 89:6 94:6

106:12,18 114:3

backgrounds 88:16

bad 29:13 83:5,5

93:15

bag 104:4

Baghdad's 51:15

Bakker 2:10 75:13

75:15,15 85:7,15

85:22,24 86:4,22

87:4,18,22 88:4

balance 84:3

ballpark 109:12

bandwidths 86:10

bar 36:12 105:18

110:2,8,9,17

111:24 115:22

bars 5:2 109:21,22

110:17 114:15,15

114:21

base 34:16 108:18

based 14:20 16:5

16:15 18:16 25:10

27:15 30:19 32:8

43:8 48:15 58:23

60:15 61:15 71:24

72:16 80:18 96:3

104:13 108:21

116:13 119:21

bases 51:19

basically 54:9

114:15

basis 13:1 20:1

116:17

bat 9:23

batch 79:5

battery 4:10 11:3

32:5,7 96:20

102:22 105:16

107:17

battery-powered

101:18 102:3

103:8

Baum 18:6

Becker 2:13 95:13

95:20,21 96:1

116:6,11 117:3,6

117:9,15,21

beginning 7:8 8:14

15:23 34:15 64:19

behalf 5:24 39:15

46:2,8 58:11 62:5

69:14 74:4 75:18

81:3 88:19

behavior 97:15

believe 28:22 29:9

30:8,11 42:5

63:12 65:19 66:17

67:3,17 68:14,15

76:21 77:1 78:9

90:19 91:8 116:20

believes 16:9 21:21

80:6 111:8

bell 85:16 86:5

belt 25:10

beneficial 89:5

benefit 5:6 48:17

59:12 64:20 98:17

benefits 48:11

49:15,18 65:23

66:10,16 70:14

97:4 102:8,19

best 4:19 16:6

43:19 44:23 62:16

66:5 68:23 83:22

83:23,23,24 84:2

89:11

better 18:1 25:13

35:9,12 44:5,14

49:12 54:14,20

56:18,18 59:8,16

59:19 60:4,5,17

61:13 64:20 81:15

81:15 105:2,11,12

115:19 116:19

119:1,9

beyond 40:10

79:21 86:2 87:22

114:15

big 70:17 104:3

Bigger 117:8

bikes 55:11

billion 54:16,21

69:23 70:1,12,12

bins 113:20

bit 52:11 60:6

85:17 114:7 120:5

black 79:7 80:8

91:12

blended 111:21

blind 57:22

BMW 10:18

Board 15:1 60:5

boil 17:1

bold 76:22

Bolder 117:8

bought 52:8 69:24

84:23

boundaries 5:3

box 76:2

boxes 79:3

brain 112:2

brains 35:20

break 36:15 71:4

74:2 94:14 111:16

118:9

breaking 70:17

briefly 8:11 11:19

72:10

bring 15:1 96:19

bringing 66:15

101:21

broad 28:6 43:15

broader 16:11 71:4

82:12

broadly 117:14

brought 10:9

brown 108:3

BTUs 34:22
Jensen Reporting 312-236-6936

Page 3

budget 55:9,14

63:11

budgets 65:3

build 34:16 91:21

96:24

building 34:15

builds 65:1

bulk 20:8

bunched 110:3

burden 89:20

Bureau 49:12

59:19 60:4,6,17

business 5:19 17:7

23:1,5,11 49:12

59:19 60:4,5,9,17

62:21 121:7

businesses 63:19

busy 3:9

buy 26:2 32:18

54:11 57:17 60:21

60:22 61:2,5 96:6

buyers 16:4 17:14

17:17 19:14 21:11

buying 14:15 16:5

17:14,19 36:5

37:6 41:3 81:12

B's 61:1 84:14

C

C 12:19 25:7 36:22

52:22 53:14 61:1

77:6

CAFE 24:16

106:21

calculate 29:21,23

32:8

calculated 29:8

45:11

calculating 28:22

29:14

calculation 45:1

92:6

calculations 21:6

28:20 91:23

calculator 13:22

California 15:1,12

38:18,24 39:3

92:16

call 5:2 9:16 94:19

95:12 103:24

112:10

called 21:16 58:3

108:4

calling 113:4

campuses 88:15

capability 37:14,14

39:1 83:8

capable 36:21,22

44:8

capacity 12:17 44:1

capture 65:21

67:15

car 10:17 15:6 16:4

21:1 26:4 28:3

29:19 38:15 39:21

53:12 54:23 55:15

57:4 61:4 62:21

68:16 69:19,20

72:22 73:11 78:15

81:19 83:19 89:11

89:13,20 94:3

96:14 104:7

107:11,13,15

109:19 110:6,12

110:12 113:16,17

113:21,22,23

114:8,12 115:7,8

115:14

carbon 28:22 35:15

82:4,16,22

carbon-free/nucl...

119:3

card 72:2

care 31:18 63:7,15

93:1

career 103:20

cargo 19:15 53:13

carmaker 28:3

101:20

carmakers 27:23

Carrier 28:14

carry 15:4

carrying 47:6

cars 15:22 19:7,19

24:17 25:16 26:2

30:2 38:16 46:23

50:17 57:5 58:17

58:18,19,21 61:11

65:14,18 67:11

70:19 72:17 82:20

82:24 83:11 88:23

89:8 96:5 105:24

114:4 119:5

carving 82:9

car-sharing 81:1

case 31:15,19 42:5

46:4 92:9

CATA 39:17,22

46:2

categories 12:22

60:7 83:12 87:6

category 36:4

58:19 59:6

cause 20:15 61:16

120:17

caused 23:15

causing 54:5

celebrates 84:8

celebration 118:19

cell 18:7 77:7 79:11

80:10 87:15,18

center 75:14,17

80:16 84:12 96:9

centerpiece 47:13

central 48:21 49:2

120:2

CEO 23:8

certain 14:1 19:14

40:7 41:5 49:19

60:11 108:22,24

109:10,11 110:7

111:8

certainly 35:10

44:11 58:12 59:23

61:12 72:23 91:14

106:24

Certification 75:16

Certified 121:5,6

chair 104:16

chaired 69:19

chairman 23:8

39:12

challenge 4:5 99:16

challenges 88:17

104:5

chance 81:23

chances 82:1

change 51:3 54:1

56:1 78:3 82:6

85:3 86:3 101:5

106:9

changed 107:3

changes 14:2,11

15:24 35:6 40:7

52:1 54:5 63:21

79:20

changing 55:19,22

56:1 85:13

Chapter 69:13

charge 29:2,5 32:6

32:11

charged 27:16

charger 32:9,12,19

charges 32:16

charging 32:14

Chevrolet 39:14

Chicago 1:10 6:8

39:17,23 58:20

62:14 65:15 80:18

90:5,12 118:17

121:8

Chicagoland 39:14

Chicago-based

118:22

chief 5:11

children 25:10

choice 56:18 64:16

66:3 82:12,13

choices 16:3 22:9

25:12 49:7 74:2

82:7 89:1

choose 17:22 71:8

Chrysler 10:18

chunk 48:4

circulate 65:10

cite 59:24

cited 33:7

citizens 64:8 90:8

city 43:6 49:3 81:20

97:18,21,21 117:1

117:1,7 121:7

citywide 81:2

city/highway 117:2

claims 89:6

CLAIR 1:9

clarity 47:12 59:16

class 12:8 22:11

24:20 43:14 49:23

58:17 59:6 78:8

78:13 105:5,10

115:20,20

classes 22:11 97:14

112:24

class-based 91:1,3

clean 16:12 18:9

22:6 51:3 53:24

62:21 64:23 65:20

69:19,20 96:7

cleaner 21:8 27:20

27:22 52:2 90:9

91:4 92:2,13

101:20,23

cleanest 17:23 22:8

clear 4:1,19 11:5

18:17 19:22 21:24

48:17 50:15 58:3

63:12 64:14 65:6

67:16 68:12,23

69:1 73:9 89:13

91:7 93:10,11,18

clearer 84:20

clearest 93:20 94:2

clearly 5:4 8:1

17:24 18:9 22:7

48:3 57:13,20

59:12 64:22 66:6

73:4 95:19 98:24

clear-cut 44:14

Clemens 108:2

climate 6:10 51:3

54:1,5 55:24 62:3

80:20 82:5 85:3

close 61:24 62:23

closely 14:24 23:9

closer 38:20 84:15

CLR 121:17

Club 62:1 70:20

73:19

Club's 69:13,14

CNT 80:18,23 81:3
Jensen Reporting 312-236-6936

Page 4

81:7 82:2 84:4,8

84:19

coalition 10:1

23:10 51:1 88:13

89:3

cold 109:1

collaborative 3:17

colleague 5:10 6:6

6:12,15 92:16

collect 14:4

college 88:14

color 14:10,13

37:14,20 38:3,4

48:3 79:4,6,22

91:11

colored 21:3

color-coded 26:6

combat 23:14 63:8

combating 63:16

combination 4:7

69:6 75:1 82:6

combined 43:7,12

100:15 102:20

combines 80:18

combustion 20:18

66:21

come 8:24 45:6

50:21 58:22 84:15

88:8,9,16 99:15

104:21 114:10

comes 29:24 30:1

82:22 98:23

107:22

comfort 12:17

42:23

comfortable 75:3

coming 42:20 61:4

94:11 108:7 109:9

Commandant 23:6

commend 45:5

comment 1:5 3:2

8:1 11:19 13:5,23

33:4 38:10 69:8

81:6

commentary 5:14

comments 7:16 8:2

8:7 22:13 23:21

23:22 32:24 33:6

33:8 37:16,24

38:6 41:23 58:2

62:9,13 74:23

76:11 85:8 86:21

86:23 90:12 103:5

110:20 112:8

116:10,13

commercialization

98:12 102:23

commissioned 17:4

commitment 64:1

102:12,15

committed 23:11

common 28:17

31:7

commonly 32:1

communicate 68:5

communicating

7:13

communities 65:1

65:23 70:15

community 66:4,10

80:21

companies 18:3

company 10:19,19

75:18,23 101:16

comparable 43:22

comparative 14:19

41:14,18 42:20,22

43:11

compare 17:18

25:3 30:11 31:4,6

31:12 32:3 34:3,4

43:21 50:1,4 67:1

71:17 76:18 83:15

83:21

compared 18:22

19:16 30:19 42:4

72:15,18 119:11

120:3

compares 24:2,19

97:13

comparing 22:1

30:13 75:6 82:24

83:1

comparison 11:22

18:15 20:5 21:1

31:10,14 48:6

57:14 58:9 67:6

91:15 113:18

116:17

comparisons 7:5

12:7 14:14 20:23

43:17 46:17 49:17

58:16 67:16 83:24

97:9 112:23

compete 17:22

complete 8:8

completely 15:7

54:2

complex 13:15 21:5

26:11,13

complexities 26:16

complexity 14:10

36:6

complicate 67:19

complications

21:15

comply 7:23

component 71:3

92:13

components 4:23

compounded 25:3

25:19

comprehend 91:18

comprehension

16:24

comprehensive

11:7 80:23

compressed 86:5

concept 13:13

117:19

concern 21:18 25:2

25:19 29:22 79:1

88:17 90:1 93:18

101:13 111:7

concerned 24:23

41:2 90:6 99:13

concerning 23:20

concerns 14:11

23:24 24:16 33:12

48:21 50:7 57:8

76:20 88:20 98:23

98:24

conclude 30:5

110:19

conclusion 22:3

73:19 74:24

117:21

conclusions 99:9

concrete 66:7

Concurrently 4:4

conditioner 28:14

conditions 45:21

89:16

conduct 95:4

conducted 9:5 12:9

13:7 47:14

conducting 13:2

confidence 68:8

confidential 5:19

confirm 95:14

confirms 100:19

conflict 54:6

conflicting 67:18

confuse 12:18 41:3

44:2 114:17

confused 34:17

57:22

confusing 13:13

20:11 36:17 52:22

52:23 53:7 78:14

91:6

confusion 60:10

91:3

Congress 4:21 47:3

Congressional 3:24

5:4

connection 65:14

65:17 82:11

conscious 99:16

consider 19:6

20:12 42:9 56:14

56:15,17 63:4

76:2

consideration 41:7

50:5 90:1

considerations

71:13

considered 5:18

14:9 19:1,2 36:3

47:23

considering 17:15

19:3,4 21:12 70:6

97:10

consistency 15:3

45:9

consistent 20:7

48:5

constant 43:24

constituent 80:22

construct 104:8

constructive 13:21

consultation 4:13

consume 30:18

33:23

consumed 34:22

consumer 12:16

17:5 21:5 24:12

24:14 27:17 28:8

47:13,18,21 48:10

48:20 51:7 52:8

56:9 59:16,17

62:16 67:8 68:19

76:5 82:11 90:19

97:15 98:10 99:10

101:9 107:8,22

111:6 117:22,23

consumers 7:4,14

7:22 11:5,12,13

12:6,13,18 13:8

13:20 14:15 16:1

16:11 17:9 18:11

18:17 19:6 21:6

21:24 22:9 29:13

29:15 31:16 32:4

44:2 46:13,16,17

46:19,24 47:7,10

47:16,17,22,23,24

48:2,17 49:1,7,15

49:18,22 50:14,16

54:18 58:8,21

61:16 63:3 64:16

64:20 65:13,19,24

66:3,8,17 67:1,15

68:7,23 71:6,12

71:17 72:3,3,6,8

73:2,8,15,17,21

73:24 74:2,3 76:4

76:17 77:3 78:11

78:14 80:8 81:10

82:8 83:20 89:1
Jensen Reporting 312-236-6936

Page 5

89:10,22 91:4,7

91:17,24 92:11

93:10 94:2 97:6,8

98:3,16,20 100:6

100:9,15 101:1,12

103:2 105:22

106:11 110:5

112:22 114:17

116:4,16,20,21

117:12,13

consumer's 59:10

93:19

consumer-driven

46:15 50:12

consuming 59:8

107:18 110:4

111:23

consumption 4:6

16:2,20 17:2,13

21:13,15,17,22

29:21,22 31:24

47:8 73:18 105:19

106:23 109:24

110:6,9,16 112:1

112:1,17 113:1,11

114:9

consumption-bas...

115:24

contacts 5:22

contain 44:16

contained 43:18

49:11 120:11

containing 5:8

contains 49:9 120:9

121:13

content 30:20

40:14 48:5

context 33:16 50:9

continue 3:16

22:13 35:2 42:5

43:3 45:23 61:21

96:15,19 97:17,19

97:24 98:2

continued 21:20

64:9 102:15

continues 21:18

continuing 55:12

96:12 118:19

contradicts 24:24

contrary 12:12

102:1

contrast 24:18

contribute 20:21

contribution 58:14

82:5 101:23

contributor 85:2

88:24

control 27:23

controlling 13:17

convened 7:11

convenience 25:5

conventional 30:14

104:23 113:13,17

113:22

converted 30:21

78:18 106:12

converting 106:13

convey 25:17 26:10

50:13 71:11 72:20

73:5 94:2

conveys 25:17

35:12 71:15

116:19

convoys 51:12

Cook 121:2,8

coordinate 15:10

coordinates 80:23

core 66:8 67:20

Corporation 23:8

Corps 23:7

correct 30:8 31:13

31:15 111:12

117:3 121:11

correctly 41:24

correlated 110:21

110:22

cost 12:17 16:19

20:23 21:1,6,7,9

28:19 29:9,11,12

31:17 32:15,16

34:20 41:16 43:7

48:14 66:6,11

68:17,21,24 73:10

73:12 74:14,15,17

74:19 98:2 109:8

112:21 113:12,12

114:11 116:17

119:14,22

costs 26:1 30:4 31:2

31:6 32:2 41:13

50:9 65:2,6,24

66:1,2 68:16,18

71:18 73:5,7,10

73:14,15,17 81:12

81:16,19 92:10

99:2 100:16,18

110:22 111:12

Council 23:4

Council's 15:19

counsel 5:11

counter-producti...

43:20

countries 54:17

country 47:15

56:22 62:8 70:9

74:5

County 121:2,8

couple 10:11 32:21

37:13 52:9 60:20

92:23

cover 20:19

covered 40:12

covering 15:7

99:22

co-chair 104:19

co-chaired 23:6

co-developer

104:19

co-proposed 5:1

93:7

CO2 12:16 26:23

26:24 86:17 99:24

107:4 108:6,8

109:18 111:5,7,11

112:21

CO2/mi 20:11

craigslist.org 17:9

cram 104:7

crazy 57:20

create 48:1 67:18

67:24 82:11 91:3

99:21 102:4

creating 103:9

creation 84:5

credibility 26:5

89:7

credit 36:20

criteria 35:15,24

42:4,23 59:1

60:11 67:2 71:16

91:15 110:17

113:20

critical 28:23 45:2

49:6 63:3 67:9

98:9,19

cross 37:8

cruise 42:22

CSR 121:17

current 12:5 23:18

24:24 25:11 41:12

47:16 72:10 85:9

89:21 101:17

107:24

currently 11:6

54:15 85:14

curve 85:15,16

86:5

cusp 87:9

customers 42:14

116:14 117:16

customer-oriented

11:9

cutoff 84:9

cutoffs 84:24

cuts 63:22

cutting-edge 25:21

cycle 108:11,17,23

109:3 110:23

C's 53:14

C.S.R 121:20

D

D 52:22 53:2,3

69:12 105:13,13

dangers 23:15

Darin 2:9 62:1

69:10,11,12 74:8

74:16

data 12:6 29:8,17

30:5 32:17 49:2

65:21,23 67:20

79:1,6,8 83:9,11

120:5

date 80:3 90:11

91:22

day 8:3 27:15 30:6

30:7 54:16 104:11

118:3,22 121:21

days 79:19,20,21

deadline 13:6

62:13

deal 48:4

dealer 11:13 38:15

39:14

dealers 3:15 39:13

39:16,19,21,23

40:11,13,21 41:2

45:13,16 58:12

62:22

dealership 42:20

42:24 44:18 54:11

60:21

dealerships 58:20

60:20

debated 70:4

Debbie 2:10 75:13

Deborah 75:15

debt 81:23

decade 27:18 66:20

decades 62:12

108:12

decide 105:11

decided 36:6

decision 4:4 18:24

27:8 50:6 61:17

76:6 90:22 91:11

111:13

decisions 4:2 12:14

16:5 41:4 42:13

42:23 46:21 58:22

58:23 72:9 81:15

decision-making

62:17

dedicated 25:23

103:20

deemed 9:9 95:7

deepen 47:7

deeply 63:15 64:4

default 34:10

Defense 15:19 46:8
Jensen Reporting 312-236-6936

Page 6

defer 74:23

define 100:8

defined 98:24

definitely 52:3,4

92:19

delay 102:10

deliberations 45:8

delivery 70:24

delve 41:21

demand 102:5

demands 22:1

demonstrated 3:17

demonstrates 15:5

78:22 101:1

demonstration

87:21,22

Dennis 2:14 95:14

118:16

depart 28:16

Department 3:2,11

3:23 4:12,13,14

5:2,24 18:21 26:7

40:22 75:17

106:24

depend 45:21

dependence 22:23

23:16 53:19 63:9

64:9 70:18 71:8

dependent 28:1

54:4

depending 79:22

79:23 100:17

depends 108:9,9

depiction 68:13

depleting 114:20

deployed 51:8

deployment 23:13

25:23

deposit 99:8 117:14

Deputy 3:6

describe 16:21

44:23

described 69:7

description 44:16

89:14

deserve 63:12 69:1

design 7:17 11:20

12:5 13:21 17:5

22:7 24:1 29:10

35:12 41:7,13

43:19 48:5 79:22

90:20 91:8,12

92:12,16 106:3

119:6

designations 21:3

designed 89:12

designs 7:16,20

14:8 47:19,23

119:10

desire 34:2

desired 92:1

Desmond 2:7 39:6

39:11

despite 42:7

detail 16:22 37:7

76:11

detailed 11:7 49:10

92:17 103:5

120:10

details 17:10 41:22

determinant 27:1

determining 60:11

detract 67:20

devaluing 101:23

103:2

develop 14:4,6

26:18 69:4

developed 31:1,21

79:16 116:8

developing 7:8

24:4 98:9 101:19

development 79:14

80:22 98:11

101:17,18 102:22

104:14,18,20

devices 28:17

dialogue 99:23

dice 51:16

difference 29:12

101:6

differences 34:12

different 7:5,18,20

16:3 20:6,12 22:1

30:16,17,18 31:9

31:10,11 32:3

34:14 50:1,4 58:4

72:16 86:14

100:13 115:19

116:24

differentiates

17:24 22:8

differentiation

77:6 78:1 80:8

differently 41:17

difficult 13:13 41:4

45:7 79:2 108:8

difficulties 79:5

100:12

digestible 71:12

dilemma 83:14

dimension 14:10

diminishing 102:7

direct 74:17

directed 4:11 47:3

61:14

direction 3:24 5:5

52:5 75:9

directly 24:24

director 6:10 69:13

88:12

Directors 60:5

dirtier 91:5

disaggregated

81:19

disagreement 45:4

discarded 17:6

discharged 32:7

Discouraging

101:22 102:6

discriminate 77:10

discussed 68:12

discussion 7:21

104:23,24

displacing 112:5

display 49:5 71:13

101:9 106:23

displayed 34:20,21

89:13 101:10

106:4

distinctions 87:5

107:21

distinctly 7:20

distribution 77:2,4

77:20 78:3 80:6

84:11,13,15 85:13

85:20 86:3,15

87:11

diverse 83:18 88:16

Division 6:11 51:10

docket 5:20,21

dockets 5:17

DOE 40:23 107:2

doing 21:5 24:21

26:14 36:4 46:14

51:2 58:18 59:4

59:22 101:20

108:11 121:7

dollar 65:7,8 92:8

dollars 54:16 65:9

70:15

domestic 107:20

DOT 22:14

DOT'S 6:13

Dove 17:8

draft 84:6 91:17

dramatic 6:16

dramatically 19:18

83:13

draw 99:9

drawbacks 78:23

drive 18:11 20:19

25:20 30:6,7 43:4

55:12 102:4

108:17,20 115:14

driven 13:19 97:21

drivers 6:18 24:17

25:15 30:5,7

69:24 70:11,14

driver's 24:8,10,23

driving 45:21

68:16 89:15 98:2

109:1 116:18

drove 51:11

due 8:18 21:19

43:13

duly 121:4

Dunham 2:2 6:6,7

6:9 15:15 22:16

32:21 33:5,9,11

35:1 39:4 58:1

59:18 60:2 61:23

69:10 74:7,22

75:11 86:12,19

88:1,6 90:3 92:21

93:4,22 94:4,8,15

103:13 112:12

117:11,18 120:14

Duoba 2:14 95:14

103:13,14,14

112:15,17 113:3

114:18 115:18

duration 9:11 95:9

duty 16:16 18:17

72:14

D's 84:14

E

eager 23:20

earlier 3:11 94:18

105:7

early 17:14,19

21:10 26:1 32:17

37:6 99:10,13

101:6 114:1

earns 25:20

ears 35:20

Earth 118:22

eases 20:23

easier 52:7 55:16

56:12 119:23

120:9

easiest 78:11

easily 34:3 71:12

71:17 76:18,22

East 118:16

easy 17:17 21:4

30:4 34:4,10 48:2

48:7 49:17 52:21

54:14 56:3 91:9

93:6,7

easy-to-remember

49:10

easy-to-understa...

16:1 48:19 81:11

120:1

easy-to-use 71:5

eat 49:8

Eckstein 2:8 50:19

50:20,20 56:21

57:10,12 60:19,24
Jensen Reporting 312-236-6936

Page 7

economic 21:19

22:23 23:14 49:18

66:4,8,15 70:14

71:18 73:5

economy 1:6 3:4,13

3:18,20 4:2,15,20

6:5,17,22 10:24

12:6 13:12 14:18

15:2,22 19:17,17

24:4,5 25:1 26:21

26:24 27:1 35:24

40:3,9,13,16,19

40:22 41:8,10,14

42:2,11,16,18

44:6,10,11,15,21

44:23 45:20,24

46:13 47:10,21

57:9,14 59:2

61:13 62:9 63:2

64:15 65:2 66:7

68:12,13 69:17

71:3,22 72:9

74:13 75:21 76:4

77:15 82:1 89:8

89:10,14 90:15

92:12 96:8,14

97:18,21 99:24,24

100:20 108:18,23

118:14 119:1,5,6

economy's 64:22

EDF 46:18 50:11

Edmunds.com

13:7

educate 34:13

105:21

educated 53:24

educating 26:16

45:13 51:2

Edward 2:11 75:13

80:15

effective 21:10

47:24 67:3 69:5

71:10 118:20

effectively 24:16

25:8 70:8 71:15

effects 31:8 56:7

84:2

efficiencies 22:2

32:3

efficiency 19:11

29:15,16 30:11,20

31:5,8,20 44:4

48:14 50:8 57:3

69:20 70:24 71:20

72:4 73:7 75:21

76:3,16,18,23

77:11 78:3 79:11

80:23 83:12 90:23

94:3 107:10 112:6

119:11,20

efficient 17:23

19:23 22:6 24:9

24:14,22 44:8

48:8 51:13,21

53:4 55:15 58:13

58:14 59:6,10

61:11,18 64:18

73:11 75:24 78:15

78:17 82:7 83:11

91:5,6 92:14

96:24 97:1 99:2

107:12

efficiently 5:4

effort 6:2 45:16

53:23 82:2 97:7

efforts 3:17 15:11

15:22 45:6 46:19

50:12 69:4 76:1

85:3 92:15 96:9

EISA 40:7 42:8

either 75:8 86:18

86:19 88:2 108:17

114:24

elaborate 37:17

electric 4:7,10 7:2

11:3,3 12:20

13:17 18:7 20:10

20:15,19 23:13

31:23 68:4 72:20

72:22 77:7 85:19

92:24 96:21 97:20

98:8,17 99:5

101:21,22 102:6

102:16,23 103:2

103:18 104:15,20

105:16 107:9,15

107:17 109:19

112:15,17 113:24

114:8 116:23

electrical 101:15

113:1

electricity 4:7

20:18 27:4 29:21

32:23 72:21,24

102:5,11,20

106:12 107:16

112:20 114:9

115:4,11

electrics 85:11

electric-based

99:17

electric-driven

100:9

electric-powered

102:9

Electrification 10:1

23:10

electronically 33:4

elegantly 83:15

element 67:10

elements 67:18

71:22 75:3

embrace 98:18

102:21

embraced 96:9

emission 19:11

27:6,18 36:1 75:7

101:9

emissions 3:21 4:3

4:16,20 6:23

11:21 13:10,12,20

13:22 16:17 18:1

19:24 20:3,9,15

20:16,17,19,20

26:22,24 27:7,9

27:10,13,14,23

28:3,12,13,18,19

28:22 29:3,4 30:4

31:17 34:19 41:9

41:15 42:10,11,16

42:19 44:21,24

45:24 48:14 57:9

64:10,15,18 67:23

68:5,6 71:7,15,16

71:16 72:1,4,6,17

72:21,24 73:3

82:4,17 83:15,21

86:17 88:21,23

91:15,24 92:3,6

92:24 98:14 100:1

101:4,7,14 102:1

102:5,10,19,20

108:6 109:15

110:23,24 111:5,7

111:11 112:21

119:13,20

emit 72:22

emitting 20:10

emphasis 37:4

117:1,5

emphasize 21:14

23:18 116:24

117:6

emphasized 21:14

48:19 97:22

emphasizing 21:22

employs 22:24

empower 50:16

empowering 46:15

enable 40:15

enables 18:1 20:5

24:13 30:17

enabling 7:23

encompasses 16:15

encounter 51:17

108:20 111:6

encourage 5:17

13:4 15:10 61:20

102:2,21 103:6

encourages 24:13

ended 11:16

endorse 98:16

endorsing 59:14

ends 5:14

energy 4:11,13

6:20 13:17 18:18

22:20,22 23:4

26:17 29:14,24

30:19,21 31:20,24

40:6,23 47:2 51:3

52:3 53:24 54:4

62:3 64:23 65:2

65:20 69:20 80:20

80:23 96:10

101:20 107:1,12

107:12 108:5

113:12 115:10

118:18,20,23,24

119:3

energy-generating

101:14

energy-independ...

4:24

enforce 9:10 95:8

engage 22:13

engaged 45:17

46:15 47:10 70:21

engine 66:21

engineer 56:6

engineers 104:17

enhance 22:22

enhanced 44:3

enlisting 22:24

ensure 47:10

ensuring 40:14

96:4 100:3

entered 5:16

enthusiastic 84:19

entire 4:16 36:2

41:10 70:9 103:20

entirely 27:5

entitled 76:22

entity 60:12,15,15

entrusted 4:21

entry 4:8

environment 16:6

55:2 58:15 82:13

84:2,17 88:17,21

96:7 101:24 119:9

environmental 1:1

3:3,12 4:4 16:2

18:18 20:1 23:14

26:17 38:19,23

39:24 46:8 47:8

49:16 50:8 57:14

59:1 66:16 67:9

68:9 73:24 81:4

82:3 84:22 88:13

89:2,24 90:24

92:5 101:2 102:7
Jensen Reporting 312-236-6936

Page 8

102:19,24 118:20

environmentally

48:8 63:5 89:5

99:3,12,16

environmental/s...

118:24

EPA 3:17 4:14 5:9

5:16 6:16 7:9,23

10:23 11:4,14

12:3,11 13:2,4,11

15:10 18:21 22:14

27:1 40:1,9 43:5

44:8 45:12,15

46:12 47:9,15,24

49:21 69:4,15

71:21 73:13,19

75:20 79:9 82:3

84:6 88:24 90:10

107:8 109:17

EPA's 6:10 49:23

50:6 72:7

EPA/DOT 83:9

equal 113:18,22

115:12

equally 83:5

equivalent 30:10

33:13,15 97:24

107:14,17 112:14

115:2 116:15

eroded 81:22

especially 21:16

41:17 65:12 93:8

108:1,1 111:15

essential 67:10

68:14

essentially 19:13

34:15 104:4

establishing 37:21

esthetics 78:21

estimated 46:24

estimates 119:15

estimation 86:7

ethnic 39:19

EV 101:1

evaluate 43:23

evening 8:14,15

9:15 94:15,16

95:15,22 118:4,6

eventually 35:18

everybody 9:14

114:2,4

everybody's 115:19

everyday 45:23

84:17 85:4

evidence 9:6,7 95:5

evidenced 5:1

evident 65:5

evolution 12:4

EVs 27:10 96:21

exactly 59:17 93:4

example 21:24

43:14 91:4 111:20

examples 19:18

excellent 22:4 76:7

exciting 66:13

executives 23:5

exempt 89:17

exercise 4:23

exist 109:7

existed 40:19

existing 25:11

43:13

expanded 99:23

expanding 22:12

expect 37:1 42:11

45:20 89:15

expected 73:14

92:1

expended 6:3

expenditures 81:17

expensive 25:24

100:20

experience 100:24

expert 18:6

expertise 7:12

experts 17:3,5,7

104:11

explain 13:14

34:23

explains 49:19

explored 47:16

exploring 76:8

express 3:9 23:17

116:6

expressed 22:12

117:16

extensive 7:9

extent 91:9 100:8

extra 65:7

extremely 52:5

53:21

eye 91:9 93:6,7

102:18

eyes 103:2

eye-catching 91:13

e-mail 33:2

F

F 53:15

facade 34:16,17

face 26:17

faced 4:5

facilitate 23:12

66:18

facilities 101:15

facility 14:11

facing 100:12

fact 11:13 25:20

33:23 40:23 42:18

49:12 51:3 54:2

59:7,7 106:16

115:9

factor 29:23 49:20

114:23

factories 14:12

factors 13:15 17:1

28:1 29:20 30:3

45:21

facts 43:6,8

fading 79:5

fail 43:21

failed 44:12

failing 84:18

fair 20:5 41:19

52:11

fairer 86:6

fairest 84:2

fairly 52:11 84:21

fall 30:4 98:24

false 66:3 84:1

familiar 25:6 48:18

49:3 50:15 112:19

120:6

families 49:21 55:9

55:13 81:17

family 58:23

family's 58:24

fancy 50:23 56:5

fangled 104:7

far 43:15 51:16

82:12 92:19

100:24 104:24

far-reaching 7:9

fashion 114:3

fast 56:20

fate 26:6

favor 7:19 107:16

118:13

favored 45:10

feature 67:22 68:10

68:16 99:18

features 62:24 67:5

89:5

federal 46:22 63:24

Federation 61:24

62:4,6 69:3

FedEx 23:8

feel 25:13 52:11

56:17 74:16

103:22

felt 49:13

fewer 42:8 70:1

84:14

field 78:10 104:13

fifth 14:22 16:20

19:4 79:9

figure 19:12 34:2

figured 9:20

fill 8:24

final 18:23 23:21

79:23 90:20 91:8

93:5

finalized 14:3 38:1

79:23

finalizing 22:14

Finally 28:11 49:8

79:19 82:18 92:7

finance 96:2

Financial 98:10

financially 63:5

find 26:4 52:17

83:22 116:21

finding 107:23

fine 33:5 87:5

116:2

finer 78:1

finished 9:2 95:1

118:7

fire 51:18

firmly 81:7

first 9:16,17,22

10:5,8 12:1 16:13

23:24 29:18 37:9

39:6 41:24 43:19

44:4 48:1 51:10

69:16 70:17,20,24

71:23 76:13 81:10

93:8 99:14,21

103:23 104:16

105:17 106:6,19

118:4,21 121:4

Firstly 90:16

fit 43:10

five 11:19 15:7 16:9

18:8 25:10 48:15

49:20 57:6 77:16

93:14 108:23

109:3

five-pound 104:4

five-year 20:22,24

21:9 29:9,11,12

29:17 74:15

119:21

fix 87:12

flatten 86:4

flattened 85:16

flatter 86:6

flaw 25:6

fleet 4:17 11:23

21:2 36:2 41:10

66:23 78:8 82:15

96:13,14 99:18

102:4,6

fleets 96:24

fleet-wide 90:22

fluxes 55:14

focal 98:1

focus 7:10 12:3,9

12:24 20:14 22:11

27:11 41:12,16
Jensen Reporting 312-236-6936

Page 9

42:2,18 43:5

47:14,16 48:18,21

49:21 99:23 100:2

100:3 120:2

focused 99:24

focuses 12:15

folks 88:7

follow 10:10

followed 16:10

98:1 116:17

following 10:11

67:5

follow-up 88:1

117:11

foothold 100:5

footprint 19:10,16

19:20,23

force 104:17

Ford 10:18 65:15

forecast 18:7

forefront 21:18

foregoing 43:4

121:10,11

foremost 63:16

form 5:2 40:20

77:24 91:16 98:18

formal 9:6,6,12

95:5,10

format 12:14 35:4

35:5,9,9 37:21

44:13 48:20 71:12

78:20 120:1

formatted 41:17

formed 13:1

formulated 84:7

forth 100:13

106:12 110:14,24

111:17

forward 6:3 8:4

13:3 22:5,12,15

42:13 43:3 51:18

70:20,23 79:10

88:8 100:14 103:8

found 3:5 5:22

19:17,19 69:21

70:13 78:13 79:3

four 19:20 25:9

40:8 52:9 80:19

fourth 14:14 16:18

78:20

frame 14:9

franchise 39:21

franchised 40:11

40:20

Frank 2:9 61:23

62:2

Franklin 96:3

Frederick 23:7

free 27:6,18 51:1,6

friendly 48:8 99:3

117:23

friends 55:10

front 38:22 55:6

FTC 15:11 31:19

FTC/FFE 38:17

fuel 1:6 3:4,13,18

3:20 4:2,15,20 6:5

6:17,22 10:24

12:6 13:12 14:18

15:2,22 16:20

17:2,13 18:7

19:16,17 21:7,13

21:15,22 22:1,6

24:4,5 25:1 26:21

26:23 27:1 29:1

29:21 30:1,16,20

31:3,9 32:2 34:6

35:24 40:3,9,12

40:16,19,22 41:5

41:8,8,10,13,14

41:16 42:2,2,10

42:15,18 43:7

44:4,6,10,11,15

44:21,23 45:1,10

45:20,24 46:13

47:7,10,21 48:7

48:13,14 50:7,8

51:12,13,20,21,22

53:4 54:16 56:7

57:3,9,14 58:13

59:1,5,8,9 61:11

61:13,18 62:9

63:2 64:15,18

65:5,7,12,24 66:2

66:7,9,11 68:12

68:13,21 69:16

70:24 71:3,22

72:8,13 73:6,15

73:16,17 74:12

75:20,21,23 76:3

76:4,16,18,23

77:7,10,15 78:2

78:15 79:11,11

80:10 81:24 87:15

87:18 89:7,9,14

90:15 92:9,12

93:3 94:3 96:8,14

97:18,21 98:1

99:1,23,24 101:3

103:19 107:20

108:18,23 110:22

113:12 115:4

116:17 118:14

119:1,5,6,11,14

119:19,22

fueling 20:4

fuels 20:6 21:23

30:13,16,18 31:11

32:3 66:19 68:1,4

101:18 108:13

fuel-efficient 84:11

full 11:8 18:19 21:1

55:15 96:20

fully 32:7 50:17

92:7 97:6 108:7

109:20

full-label 47:19

function 51:19

Fund 46:9

fundamental

106:19

funding 54:4

funds 103:17

further 25:19 45:8

59:14 72:11 77:10

81:23 86:20 89:20

96:17 102:10

103:3

future 4:24 22:19

26:19 42:6 52:3

54:6 79:13 82:14

F's 84:14

G

gains 96:18

Gale 13:8

gallon 30:10 31:1,7

33:22 35:19 41:12

47:1 68:14 70:10

97:23,23 104:6

107:6,11,13,14,17

111:19,22,23

112:3,14 113:4,6

113:14,15,18

114:1,12 115:1,2

115:3,9 116:15,15

gallons 21:22,23

33:24 69:23 70:1

74:11,19

game 63:21

gas 3:19 4:3,16,20

6:23 16:17 19:11

19:24 20:3,8

26:22 31:23,23

34:8 41:9 42:9

48:14 55:8 57:9

61:6 63:11 64:10

64:14 70:10,16

71:7,16 72:1,17

75:7 76:3,18

81:19 98:14 101:4

107:6 113:15

119:20

gases 15:3 47:4

75:22

gasoline 4:8 66:19

66:21 68:3 69:23

100:15 106:11

107:10,16 115:9

gates 51:15

gauge 109:11

geared 97:16

gearing 18:3

general 10:19 11:1

23:6 41:23 70:4

103:6

generally 35:8

81:18

generating 68:1

generation 7:1 22:5

22:6 28:23 62:17

72:21 88:18

generations 82:14

geographic 13:18

getting 37:19 54:20

54:21 55:15 84:1

91:5 92:13 103:20

107:12

Giedrius 2:5 9:23

10:5,13 38:14

give 3:24 21:24

36:19 85:20 89:1

89:7,10 90:12

100:9 114:19,19

119:8,15

given 4:18 54:19

77:13

gives 35:14 48:22

59:15 67:8 87:9

89:13 112:1

119:19 120:2

giving 49:14 59:4

107:6,14 114:6

glad 33:7 37:16

glance 72:5,10

global 17:1 55:24

63:8,16,22 68:11

70:18 88:17,22

102:12 119:12

go 8:11 34:6 52:10

52:16 53:9,13

54:7,11 57:17

75:9 81:12 86:10

94:17 106:3

108:16 109:19

115:16

goal 26:9 103:23

104:2 106:24

goals 28:6

going 9:12,18,22

10:8 28:20 41:21

43:3 51:17 52:7

55:16 56:13,15,17

56:17 57:17,17

60:22 61:2,3,5,5

62:20,23 74:19

86:12 93:13 94:6

94:16,17,22 95:4

100:8 103:16

106:21 107:19
Jensen Reporting 312-236-6936

Page 10

108:15,20 109:5

111:18 113:1

115:7 116:3

good 3:1 6:7 10:7

15:16 17:21 25:7

26:4,23 35:17

39:11 46:7 53:14

55:1,3,5 60:15

62:21 75:2,15

80:15 88:11 90:11

91:22 92:19 93:15

94:15 95:21

104:24 105:19

109:17,23 115:23

goods 26:3

gotten 53:2

governing 70:8,22

government 2:1

9:3 17:4 24:4,6

25:14 46:23 57:6

64:12 77:14 78:17

96:23 98:19,21

100:7 102:2,20

governmental 95:2

governs 31:20

grade 12:14,18,23

16:14,14,23 17:12

17:17,21,23 18:9

18:15 19:21 21:2

22:3,7 24:19 25:4

25:5 26:4,21 35:3

37:5 41:8 44:5

48:13,16,20 49:8

52:7,20 54:14

57:1,18 58:17

59:8 60:11,14,17

61:8,16 71:24

72:1,11,15 76:14

76:15,20,23 77:1

77:1,5,8,24 78:2

78:12,16 80:5,7

82:19 83:17,19

85:9 87:1,10

90:17,20 91:5

93:9,18,21,24

94:1 105:3,8,9

106:3 115:16

116:3,8 119:19,24

120:4,8

grades 17:1 19:20

26:3 48:24 49:1,5

49:6 53:8 56:3,24

58:5 59:3,11,20

77:6,21 80:7 85:1

85:1 86:9 119:22

grade-based 81:8

grading 17:10 24:1

49:13 58:16 60:6

60:7,9,10,18

67:14 73:23 77:13

77:15,17 78:4,8

78:12,18 82:23

83:3

grams 20:11

grateful 81:3

great 33:9 54:12

62:4 64:3 88:7,9

greater 16:22

39:23 76:11 81:24

Green 96:10

greenhouse 3:19

4:2,15,20 6:23

15:2 16:17 19:11

19:24 20:2,8

26:22 41:9 42:9

47:4 48:14 57:9

64:10,14 71:7,15

72:1,17 75:7,22

76:3,18 98:14

101:4 113:15

119:20

grid 27:20,22 29:24

107:18

grids 101:15

grid-connected

25:22 27:3,13,20

27:24

grid-enabled 32:7

grips 45:6

group 10:18,18,21

20:14 23:4,11

69:21 103:17

118:24

groups 7:11 12:4

12:10,24 47:14,16

48:18 49:21

growth 102:6,15

guess 38:22 53:16

53:18 55:6 61:8

103:15 110:19

112:4,8 114:20

guide 40:22,24

120:7

Gulf 64:5

guys 56:2

guzzlers 61:7

H

habitat 63:7,21

half 18:22 66:20

handouts 10:10

hands 99:7

hand-raisers 99:12

Hang 36:14

happen 60:4

happening 63:21

happy 15:14 32:19

hard 45:15 52:13

55:9 65:24 74:6

82:21

harder 53:4

hatchback 82:23

hauling 44:1 83:8

head 51:24

header 76:22

health 48:24 120:7

healthier 90:9

health-related 7:13

hear 8:2 23:20

35:17

heard 55:18 93:17

110:13

hearing 6:3 8:4,5,5

8:12 9:5 71:2

92:18 94:11 95:4

heat 115:10,11,13

115:13

heater 109:4,5

heaters 31:22

heavily 84:12

help 7:4 16:11 17:5

18:10 26:18 29:15

47:6 50:16 66:7

71:6 73:17 74:1,3

82:8 103:1 114:17

116:1

helpful 32:4 37:5

43:13 71:5,11

92:10 116:21

helping 18:11 49:7

49:18 54:20 114:6

helps 63:13,13

64:15,24 65:1

66:8 71:8

hey 53:2 54:10,12

54:13 55:4

Hi 50:20

high 32:17 42:3

55:8,13 101:1

110:7,12,15

111:20,21 112:6

higher 66:1 105:12

115:8 116:2

highest 81:16

highlight 7:7 62:15

100:22

highlighting 76:16

highly 42:15

highway 1:3 3:7

5:11 6:1,13 40:1

43:7 81:5 97:18

highways 92:14

high-consuming

110:3

hike 55:8

hilt 43:1

hit 116:3

Hohmann 2:12

88:8 90:4,4 92:22

93:2,8,16

hold 8:5,12 19:14

43:24

holding 7:10

home 42:24 51:24

55:6 116:4

Homeland 26:7

homes 32:13

hope 56:20 60:23

61:23 84:3 89:24

hot 109:1

HOTEL 1:8

hour 29:5

hours 112:18

115:10,11

household 31:20

63:11 65:3,8

households 64:24

65:4 69:1

housing 80:24

81:17

Hummer 82:23

hunters 63:20

hybrid 18:6,7 21:9

30:6 72:20 104:16

105:16 108:2

110:13 111:15,21

114:18 115:2

hybrids 4:9 7:3

29:22 38:2 99:14

104:14,15 108:1

hydrogen 34:9

hyperelectric 96:20

hypertechnology

96:12

Hyundai 75:13,17

75:18,19,19,23

76:1,13 77:22

78:4,19,20 79:11

80:4 93:13 105:7

Hyundai's 79:7

I

IADA 39:16,20

46:2

idea 81:14 93:15

108:4 109:17,23

113:3,19 115:3,24

ideas 84:7 86:21

identification 5:22

identifier 77:14

85:22 86:1

identifies 84:21

identify 48:3,7

50:13 84:10

IED 51:17

ignoring 12:16

II 32:12 49:24

Illinois 1:10 39:16

69:13,18,22,24

70:3,5,10,14
Jensen Reporting 312-236-6936

Page 11

88:12 118:17

121:1,8

Illinois's 69:20

118:23

illusion 21:16

110:1

illustrates 15:8

immediate 39:12

48:1

impact 21:19 68:9

71:7 84:22 88:20

89:2 102:24

109:19 111:3

112:20 113:21

impacts 16:2 47:8

89:24

impartial 17:5

implement 4:15

14:1,6

implementation

80:10

implementing

69:22

implications 82:13

88:22

implicitly 42:14

imply 28:2 59:3

import 107:1

importance 49:6

important 3:10

5:12 6:4 28:10

31:13 35:19 41:23

45:19 46:16 49:16

50:1 52:5 64:22

66:9 67:2,13,22

68:7 71:3 72:7,14

75:22 92:13 93:9

96:21 97:17 104:1

104:9 106:2,5

107:21 109:22

119:2

imported 107:20

impose 41:7 100:16

impossible 27:12

52:19

impression 48:1

84:1

impressive 84:8

improve 15:22

27:19 87:10 92:15

96:12

improved 77:7

96:14 118:14,14

119:4

improvement

102:13

improves 27:22

impulse 17:9

inaccurate 83:5

inappropriate 25:2

28:2

inaudible 108:2

incentive 87:9

105:12

incentives 44:12

inception 6:17

incites 47:21

include 7:17,18

11:20 16:13,20

20:8 29:11 32:11

71:13,23 73:13

74:10,13 89:16

90:19 91:23 96:4

included 6:22 7:10

13:12 16:19 32:9

47:5 59:24

includes 48:13

83:23 108:24

109:4

including 7:2 10:18

11:9 13:7,17 19:7

20:17,22 45:21

47:4 92:6

inclusion 20:24

73:12 91:14 92:7

income 65:3

inconsistent 24:3

incorporate 5:4

71:21 91:19

incorporated 39:1

incorporating

47:23

increase 87:7 92:2

Increasing 77:6

increasingly 42:21

99:3

incremental 21:7

101:5

increments 86:17

Independence 4:11

40:6 47:2

independent 4:23

20:4

index 113:4,15

indicate 13:8 32:6

74:9

indicated 50:3

indicates 97:7

indicating 38:17,18

38:19

indication 4:19

21:24

indicator 16:18

indirectly 12:15

individual 58:19

66:4 97:11

industry 62:23

66:13,14

inefficient 27:4

infinity 112:2

113:10

influencing 97:15

98:20

inform 28:8 72:9

106:11

informally 9:5 95:5

information 3:21

4:6,22 5:8,19,21

7:13,17,18 11:6,7

12:13 14:5 15:10

16:1,4 17:13,18

18:18 25:17 26:12

29:11,15 35:13,14

37:15 40:17 41:14

41:19 42:20,22

43:11 44:15,17,24

45:11 46:16,20

47:3,9,12 48:4,5

48:12,17,22 49:9

49:11,14,16 50:4

50:13,15 52:13

56:13 59:21,24

62:19 63:2,4,12

64:15 67:7,23

68:7,11,24 69:2

71:5,11,18 72:7

73:16,21 76:3

81:11,15 83:20

88:3 89:11,22

91:15 92:10 93:20

97:6,8,10,14 98:3

98:5,7,19,22 99:7

100:6 106:17

107:4 109:18

114:19 115:21

116:19,21 117:20

118:23 119:9,16

120:2,9,11

informational 4:1

98:1 116:16

informative 48:18

77:3

informed 4:2 16:4

46:20 49:7 50:6

64:16 76:6 89:1

infrastructure

102:16

inherent 43:13

inherently 26:23

initial 10:22 51:9

99:22 100:16

101:1

initially 77:20

78:13 101:8

innovative 11:10

22:24 76:2 78:22

innovators 7:12

input 7:21 13:21

47:19 59:14 94:12

108:13

inquiries 60:13,13

60:16

install 32:13

installation 32:15

instance 24:10 25:9

27:3,5 29:7 31:22

34:1 49:3 78:24

instantly 49:2

120:6

instituted 77:15

intelligent 104:1

intend 32:18 87:18

intended 7:20 28:5

28:8 59:13

intends 79:12

intensely 25:22

interactive 11:9

76:5

interest 40:13 82:6

99:4,10,17 117:16

interested 40:16

85:8 107:2,22

111:9 112:23

interesting 31:19

33:21 93:16

Interestingly 101:8

interests 66:5

internal 66:21

international 51:16

Internet 11:12

42:21 52:10,17

intimate 65:14

introduce 6:5

79:12 118:10

introduced 79:18

introducing 18:13

99:19,20

introduction 87:15

104:21

intuitive 34:5 76:15

intuitively 87:7

inundated 101:12

invasion 51:9

invest 25:21 98:15

investing 96:11

investments 29:14

64:18

involved 17:7 52:1

53:21 64:4 78:24

104:5

involves 13:15

60:12

in-class 43:11

in-use 45:24

iPod 17:8

Iraq 51:9,12 56:9

irrelevant 9:9 26:8

95:8

isolated 31:8

issue 12:1 13:10,24
Jensen Reporting 312-236-6936

Page 12

14:14,22 33:13

37:12,20,24 38:3

45:7 60:4 102:1

103:1 105:3

issued 40:2,22

issues 11:19 23:20

26:17 38:5 51:4

58:15 60:18 79:6

104:12

item 89:23

I-GO 81:1

J

Jack 2:9 62:1 69:12

Jaguar 10:19

January 14:3 38:1

job 76:7

jobs 65:1,14,18,20

65:21

join 9:17,24 10:2

46:3 95:13

joined 95:15

joining 9:14

joint 15:17

jointly 3:16

judge 54:19

judgment 4:23

judgments 25:18

J1711 104:18

K

Kalamazoo 64:6

keep 8:19 17:3

28:10 29:19 85:16

94:23 95:19 99:2

106:2,4

Kelley 23:6

Kelly 121:4,17

key 11:19 47:20

49:20 62:15 71:12

73:16,24 90:13

116:16

kids 56:2

kilometers 106:13

kilowatt 29:5

112:18 115:10,10

kind 7:21 34:5,10

34:11,15 51:23

54:6 55:14 86:14

103:23 106:10

108:8 113:4 114:5

114:6 116:24

120:6

Knezevic 2:12 88:7

88:11,12 93:23

94:1

know 7:15 18:3

34:1 35:12,23

36:23 39:8 51:13

51:18,20,21 52:3

52:6,11,14,17,22

52:24 53:3,6,6,8,9

53:10,14,22 54:2

54:15,19,23 55:1

55:4,7,8,10,10,12

55:13,16,16,24

56:5,7,11,15 57:4

57:16,19,20,21

60:24 61:1,7

66:14 70:20 87:8

103:21,22 106:14

106:21 107:11

108:12,13,14

109:2,4,13,15,23

109:24 110:11,12

110:19,22,22,23

111:7,11,14

112:22,24 113:6,8

113:17 114:1,5,10

115:9 116:3

knowing 16:5

knowledge 43:1

known 3:13 7:12

39:13

Korea 85:12,23

86:24 88:4

Korean 77:14

78:12,17

Korea's 88:3

L

LA 92:18

Lab 29:7

label 3:4,14,16 5:5

5:8 6:5,17 7:4,16

8:9 10:24 11:20

11:21,22,24 12:2

12:3,5,5,11,12

13:9,12,14 14:5,6

14:7,23 15:22,24

16:10,13,20 17:6

20:10,17,19 21:14

21:14 24:1 25:16

26:5 27:8,9 29:10

31:21 32:10 33:17

33:23 35:4,9,16

36:13,16 37:7,9

37:19,21 38:17,17

38:19,21,24 39:2

40:3,9 41:7 43:6

43:13,19 44:13,15

45:15,18 46:13

47:11 48:11,12,13

48:19,21 49:8,11

49:15,19 50:7

52:16 55:20 56:2

56:10 57:7,13

62:16 67:21 68:5

69:5 71:14,14,22

71:23 72:8,19

74:10 75:21 76:4

76:7,10,14,14

77:14,15 78:12,20

78:21,22,24 79:4

79:7,17,23 80:1,2

80:9 85:9,9 87:16

89:12 90:20 91:12

91:20 92:13,16

93:5,20 97:4,13

100:7 101:9,13

103:6 104:23

105:18,23 106:6

106:11 107:24

108:23 109:3,8

114:11 116:12,19

117:6,22 119:10

120:8,11

labeled 57:20 82:14

104:6

labeling 3:21 6:21

12:1 15:4 27:11

28:7 41:6,11

43:18 44:11 80:11

81:8,14 83:6

84:21,23 88:3

118:14 119:2,5

labels 1:6 5:1 7:8

7:16,18 11:2 14:9

14:18 15:7,9 20:8

21:21 22:6,14

23:20 31:20,24

32:6 38:9,11,16

40:13,15,19 41:2

45:14 46:23 47:5

47:5,17,22 48:1,9

62:10,10,11,24

63:2 66:17,24

67:3,7 68:10,15

68:22 69:5,17

71:3,6,10 72:9,10

73:4,20 74:1,24

75:1 81:10,24

82:8,10,18,19

83:14,15,21 84:3

84:6,9 90:15

91:17 97:16 98:2

105:20 117:19

119:7,8

label's 41:12

Laboratory 108:11

laden 25:7

Lakes 62:4 64:4

land 10:19 58:21

63:7

language 26:21

106:15

large 13:8 28:7

83:4 89:17,24

99:14

largely 62:12

larger 44:7 59:9

75:7 78:16 99:9

largest 21:12

Lastly 32:5 45:12

late 95:24

launch 17:7

Laura 2:12 88:7,11

law 6:20 7:23 35:23

lawyers 34:2

layout 40:14 71:14

78:21 93:11

lays 41:6

lead 11:22 13:24

14:1,10 66:3 72:5

79:20 80:9 82:8

leaders 23:1,5,11

Leadership 23:4

leading 45:17 90:7

Leaf 99:5,6,11,19

100:24 117:14,16

117:17

learn 23:23 72:6

learned 11:11

leave 34:1 38:2

led 23:3

left 103:24

legacy 104:5

legal 33:21

length 29:18

letter 12:14,18,23

16:14,14,23 17:1

17:12,17,21 18:9

18:15 19:21 21:2

22:3 23:24 24:19

25:4,5 26:10,14

35:3 36:22 37:4

41:8 48:13,16,20

48:24 49:5,6,8,13

52:6,20 56:2,11

56:23 57:1,8,15

57:18 58:5,16

59:3,11,20 60:7,8

60:10 71:24 72:1

72:11,15 73:23

76:13,15 77:1,24

80:4 83:19 85:9

87:1,10 90:17,20

93:9,17,21,24

94:1 105:3,9

106:3 115:16

116:3,7 119:19,22

119:24 120:4,8

letting 50:21

let's 106:7,18 108:6

level 26:6 32:9,12

36:6 63:24 78:10

101:2

levels 19:11,20

100:2

leverage 96:16

LEVII/Pavley
Jensen Reporting 312-236-6936

Page 13

69:22

lie 52:7

life 61:24 108:11

110:23

lifetime 100:17

light 15:23 16:16

18:17 21:2 46:24

67:12 72:14,17

75:6 118:15 119:5

119:23

light-duty 40:3,12

41:10 42:1

Likewise 48:24

49:21

limit 49:22 113:5

limitations 14:12

43:14

limited 13:14 41:21

limits 9:10 95:9

line 104:2

link 119:15

liquefied 31:23

liquid 68:3

list 8:21

listed 32:24 33:1

89:8

Listen 117:24

118:2

listening 6:9

little 38:2 52:11

60:6 66:22 85:17

95:17 104:21

114:7

live 65:17 108:9

lived 56:7

livelihood 63:18

livelihoods 81:22

LiveNote 121:7

lives 52:2

LLC 10:18

local 63:23

locally 64:6 65:10

logical 12:4

logistics 78:24

long 32:6,11 55:17

89:19 101:16

long-standing 64:1

long-term 99:21

102:18

look 6:3 13:3 14:16

37:10 38:20 42:19

52:17 57:12,13,18

57:18 58:24 59:1

70:23 103:8

105:23 116:16

looked 19:15

looking 8:3 11:15

19:14 29:6 66:2

69:18 99:7 117:20

looks 22:11 38:12

54:24 55:5,20

105:8

Los 8:6

lose 26:14

lot 8:1 34:19,20

36:13,20 38:9,15

50:21 51:2,11

52:7,15 53:23

55:10,23 56:19

58:21 61:6,7,11

83:19 108:12

109:4

lots 3:15

Louisiana 64:3

low 18:1 26:23 30:3

64:18 102:5,10

110:4,7

lower 65:3 78:16

79:3 91:5 100:16

100:17 102:20

low-emission 81:1

low-income 80:24

Lucinda 2:12 88:8

90:4

Luke 2:5 9:24 10:5

15:15,18

M

main 6:18 37:24

76:9 97:24

maintain 103:7

maintenance 45:22

major 12:8 65:2

66:15 75:9,24

80:19 88:23

majority 11:15

13:8 42:1,14

65:12

making 4:3 5:13

18:23 31:10 40:23

52:1 56:18 58:13

58:15,22,22 62:18

72:9 112:23

manage 14:4

manager 75:16

mandate 3:20 40:5

41:11 42:7 96:23

mandates 44:11

47:6

manufacturers 5:6

10:15,16,17 12:9

13:16 14:3 45:4

54:23 58:12 62:22

89:21

manufacturing

65:15 92:2

marginal 29:1,5

32:23

Marine 23:7

market 4:8 18:2,5

18:5 25:11 43:4

77:9 78:12 96:5

96:20 100:5

101:21 102:9

103:9,21

marketplace

102:17

mass 23:13 103:21

match 104:10

materials 5:18,21

11:9,11

math 74:18

matter 14:20 29:10

31:16 34:19,19

37:3 82:21 93:3

98:15 106:2

matters 34:20,22

maximize 45:24

maximized 47:12

Mazda 10:20

mean 13:19 33:15

34:19 36:20 37:10

52:8 54:24 57:3

57:15 61:3 86:16

112:6 115:12

meaning 35:18

meaningful 27:13

30:12,24 49:3

82:19 84:9,9,24

120:6

meaningless 44:1

means 17:12 30:23

65:20 82:19

109:20 113:2

115:12

meant 34:24 91:18

measure 14:19

31:8 32:1

measured 30:17

31:11

measurement

30:16 31:16

measures 89:6

measuring 74:12

89:9 91:2

mechanical 30:21

Medford 2:2 3:1,6

6:13 35:2,22

36:10,14,17 37:12

38:7 39:5 46:5

50:19 56:21 57:11

57:24 61:20 74:8

74:21 75:12 80:13

85:7,18,23 86:2

86:18,24 87:14,20

87:24 88:5 92:22

93:3,5,12 94:5,10

112:13,16,22

114:14 115:15

116:6,22 117:4,8

117:10,24 118:10

120:13,15

media 11:10

meet 14:16 19:8

24:8,10,17 42:15

69:7 103:12

meeting 6:12 16:7

71:9 121:10,14

meets 24:23

members 8:22 11:7

15:21 46:9 62:7

62:19 63:1,6,19

64:7,11,16 69:15

74:4 88:15,19

mention 6:19 7:7

28:21 44:22

105:17

mentioned 6:15

7:15 8:7 37:12,13

59:19 64:19 67:4

68:18 74:24 105:7

Mercedes-Benz

10:20

merely 97:13

100:19

message 83:4 107:6

115:5,6,6

method 72:16

76:15 79:10

methodology 76:17

77:9 78:4 79:15

79:17

methods 89:9

metric 12:6 17:2,16

21:22 30:11,12

45:5 67:5 77:24

90:17 91:2 93:21

106:9 110:20

112:19

metrics 16:19,21

31:14,15 47:18,22

71:13 83:18

105:19 111:14

Michigan 62:5 64:7

mid 114:3

midst 70:5

Midwest 62:15

63:20 65:11,13

90:5

mid-size 14:17

Mike 2:14 95:13

103:14 112:13

118:5

mile 21:23,23 104:5

107:11,13,16

111:18 112:18

113:4,6,15

mileage 83:16,21

110:12

miles 30:6,7,10
Jensen Reporting 312-236-6936

Page 14

31:1,7 33:22

35:19 41:12 46:24

68:13 73:16 74:11

74:14 97:23,23

106:1,13 111:23

112:3,13 113:14

113:17 114:1,12

115:1,1,3 116:14

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miles-per-gallon-...

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military 21:19 23:2

23:5

million 15:21 62:7

69:14 90:7

mind 11:14 28:10

107:22 117:5

minimum 79:19

80:9

minivan 24:11,14

83:7,24

minivans 14:18

82:20 83:10

minor 42:3

minority 39:13,19

Minsk 2:6 10:1

22:16,17,18 32:22

33:1,7,10,21 35:2

35:8 36:8,11,16

36:19

minutes 8:20 62:19

94:24

misconception

61:15

misconstrued

76:20

misinterpreted

57:2

misleading 67:19

106:17 109:18

mispronouncing

9:19

missed 87:14

Mitsubishi 10:20

mix 13:15,17 28:23

29:3 107:19

mixing 108:2,3

mixture 111:13

mode 106:1 111:21

114:20,20

model 8:9 15:23

38:3 40:10,24

42:6 44:10 45:15

45:17 61:15 70:8

80:1 90:24 99:22

models 17:16 18:7

19:7,8 43:16,17

76:19 77:4 78:1

modern 84:20

modes 114:22

modified 77:2,10

modify 10:24

moment 60:3

monetary 21:4

money 16:6 49:20

53:11 54:17,22

63:10,11

Monroney 14:5

38:16 39:2 44:15

month 39:24 109:5

months 80:9 99:6

moral 25:17

motor 10:18 40:3

46:14 75:18,19

101:16

motoring 45:19

Motors 10:19,20

move 51:12 52:2

79:9 86:7 106:7

moved 44:9

moves 22:15 30:22

moving 4:24 42:13

100:1

MPG 21:16 33:13

33:15,17 41:12,16

43:7,7,7,12 74:10

106:16,19 110:1,2

110:11,15,20

114:11

MPGe 30:15 31:9

106:7,9 107:5

108:4

MPG-equivalent

45:2

multifamily 80:24

multiple 16:24 19:6

22:10 67:18

murky 108:3

N

N 69:12

NAMAD 39:14,18

46:2

name 6:9 10:13

15:18 22:18 39:8

39:11 46:7 61:23

62:2 69:12 80:15

88:11 90:4 96:1

118:15

names 9:18,20 10:4

95:17

name's 50:20

103:14

narrowed 43:2,15

nation 3:15 7:11

national 1:3 3:7,18

5:11 6:1,13 11:24

14:23 15:2,3

23:15 29:7 39:13

40:1 51:4 53:20

54:1 55:2 61:24

62:3,5 69:3 81:4

103:17 108:11

nationalize 99:17

nationally 7:12

nationwide 46:9

90:7

nation's 22:22

23:15

natural 15:19

31:23 34:8 64:2

80:21

naturally 57:17

nature 37:18 59:7

nearly 27:12 32:14

necessarily 30:8

34:4 59:5 92:4

necessary 46:20

79:22 98:13

need 4:1,18 7:4

11:1,21 12:13

14:22 25:9 37:7

48:19 53:12,13

55:13 61:4 63:1

66:24 67:1 68:15

81:23 83:8 97:6

100:22 102:4

105:1,2,2,6

108:16 110:14,15

110:16 111:12

115:22

needed 30:1 62:11

73:21

needlessly 9:9 95:8

needs 12:16 14:16

16:8 24:8,10,11

24:18,23 25:15

48:10 58:23,24

59:11 61:19 71:9

83:22

Neighborhood

75:14 80:17

NEIS 118:23

Nelson 2:14 95:14

118:11,12,16

never 105:22 112:3

Nevertheless 84:19

new 3:5,14,21 6:19

7:1 8:8 11:1,10,15

14:5,6,6,15 15:22

17:15 22:5,6,10

25:24 37:21 39:21

40:11 41:14 42:7

42:8,12 44:11

45:14 46:14,16,23

47:5,8,10 48:24

49:3 50:14,17

54:11 56:2 62:9

62:10 65:14,20

66:17,22 67:7

68:16,22 69:5

70:7 71:22,23

73:4,5,7,10,22

81:7 82:10 89:8

89:11 97:4 98:5,6

98:7,9,18 99:21

100:19,23 104:7

104:19 118:15

119:5,23 120:4

newer 118:14 119:5

119:8,10

newly 89:12

NHTSA 3:18 5:16

6:16 7:9,23 10:23

11:4 15:10 40:2

43:5 44:9 45:12

46:12 47:10,15,24

57:5 69:4,15

73:13,20 75:20

79:9 84:7 90:10

NHTSA's 13:11

nice 55:20

Nissan 96:3,5,9,10

96:11 99:4,5,6,11

99:19 100:24

101:15,16 103:4

116:8

Nissan's 102:12

nonpartisan 23:10

nonplug-in 113:16

nonprofit 39:18,20

90:8

non-ideological

22:21

non-profit 81:1

noon 94:5

North 1:9 96:3

101:16

Notably 44:8

NOTARY 121:24

note 5:13 13:6

26:20 40:18

noted 20:13 49:24

notes 41:24 121:12

nothing's 107:3

noticed 115:19

noting 32:14

notoriously 29:13

Notwithstanding

101:19

not-for-profit

23:11

not-too-distant

79:13

November 5:15 8:7

33:6

NRDC 9:24 15:20

15:24 16:9 20:23

21:21 22:11

Nuclear 118:23
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nukes 118:24

number 8:2,18

16:23 18:6 19:15

19:24 20:22 21:13

27:13 33:12 35:6

35:10 37:8 58:4

60:12,13,16 76:8

107:2 108:8,22

109:10 110:7,15

110:16 111:20

112:2 115:8 116:4

117:7 119:24

120:4,8

numbers 28:7

35:17 70:9 110:13

111:17

numerical 77:15,23

80:5 87:2,12

NWF 62:12 63:15

64:1,11,22

O

Oak 29:7 32:22

oath 121:5

Obama 70:7

obfuscates 12:12

objecting 61:12

objective 12:7

objectives 69:7

obligated 109:17

obscure 111:13

obscured 107:24

obscuring 114:7

observations 104:9

obvious 73:8

obviously 51:20

52:24 86:20

occasion 37:2

oceans 82:22

OCTOBER 1:12

offer 82:1 119:11

offering 92:17

offers 41:19 119:24

office 42:24 62:4

90:5

officers 6:12 9:7

23:2 95:6

offset 21:7

oh 52:16 57:16

113:21

Ohio 65:16 118:16

oil 22:24 53:19

54:16 55:8,23

63:9 64:5,9,10

65:12 70:18 71:4

71:7,9 74:3

okay 55:22 87:1

109:21 111:22

115:15 117:10

118:2

old 92:16 119:7

older 27:22

onboard 30:1

once 45:14 58:23

61:13 92:18 95:22

103:11

ones 105:22 114:16

online 13:22

on-the-ground

80:19

open 5:17

open-minded 23:19

operating 20:5

28:19 29:9,11,12

30:4 31:2,6 32:2

32:16 51:19 71:19

73:5,11 81:13

99:2 100:17

Operation 50:24

51:6

operational 16:19

20:23,24 21:9

73:10,14 106:1

operations 60:9

opinion 114:23

115:20

opinions 93:23

opportunities

63:10,14 68:20,23

69:2

opportunity 9:3

15:13,17 22:17

26:15 34:13 46:3

46:10 50:11 55:1

62:8,14 63:3 69:8

69:11 75:20 81:6

85:5 90:12 92:20

95:2 103:12 110:8

opposed 35:15

58:19 70:16 74:19

78:8

opted 77:16

optimally 44:8

option 12:4,23 41:7

41:11,15,19 54:20

59:13,15 76:14

118:13 119:4,18

options 11:20 12:1

41:22 76:8

orange 58:16

oranges 31:13 83:1

order 8:22 10:4

23:14 89:10

organization 22:21

39:18,20 63:15

88:13

organizations 62:6

80:22 100:8

original 33:14

109:16

originally 103:15

Oser 2:11 75:14

80:14,15,16

outreach 45:16

51:2

outside 8:17 51:15

76:2 94:22

overall 12:18 26:10

35:11 38:13 41:13

67:9 68:9,19

69:16 76:21 90:17

91:23 92:5

overcome 23:2

overdue 89:20

overhaul 6:16

overseas 65:11

overstate 30:3

overwhelming 42:1

42:13

overwhelmingly

17:11

owners 29:19

P

pace 101:19

package 48:18

panel 2:1 7:11 8:22

9:2,3,16,17,22

17:4 39:5,6 50:21

75:12 88:6 94:17

94:19 95:1,2,12

95:13

panels 2:4 8:21

panel's 61:21

paper 95:17

papering 34:11

part 4:20 5:5 9:12

21:20 40:5 51:9

65:2 82:15 87:20

91:11 95:10

101:21 118:19

119:2

participant 50:2

participants 20:14

participated 118:7

participating 23:23

particular 13:18

24:10 28:8,9 34:1

38:13 47:1 58:17

58:18 60:12,14

61:14,15

particularly 30:24

59:3 62:15 65:3

98:8

parties 23:21,23

partnered 3:13

partnership 90:8

passenger 82:4

96:14

pasted 3:14

path 5:7 34:6

pathway 119:3

pathways 100:14

patience 95:23

pave 16:11

pay 65:21

payback 29:14

payment 81:20

pays 29:16

penalize 24:11

penalizing 12:21

58:18

people 3:24 4:21

8:18,24 19:15

25:8,15 26:2,16

31:17 32:12,18

34:13,23 35:10,14

35:17 36:20,20,21

36:24 48:4 51:2

52:15,16,21,24

53:5,22,23,24

54:9 56:24 58:7

60:21 61:14 63:6

63:6,18 81:14,18

83:7 84:6 87:7

99:6,13 108:10

109:2,16,19

110:11,14 112:19

people's 9:19 74:17

percent 10:16

11:13,16 18:22

19:2,3,4 20:20

30:5,6 34:23

66:22 77:4 82:5

96:15 99:5 107:19

percentage 32:18

82:9 99:14

perception 98:20

perfect 110:8

performance 4:19

16:16,18,24 17:18

18:19 20:1 26:11

28:9 32:5 38:19

38:24 41:9 42:11

42:16,19 44:21,24

46:1 48:22 50:8

60:9 66:16 67:9

74:1 76:16,19

77:11 87:10 90:24

92:5 113:23 120:2

performing 6:23

60:15 105:13

performs 67:11

period 5:14 29:17

119:21

permanent 99:18

person 8:19 52:12

94:23

personal 16:7

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personalized

119:15

personally 63:8

64:13

perspective 44:7

perspectives 8:3

Peter 2:7 39:7 46:7

petroleum 16:2

21:17,23 23:16

106:20,24 107:1

107:18,19,23,24

111:4,9,10,23

112:6 113:9

petroleum-powe...

21:17

Phase 49:24

phases 47:15

PHE 105:18

PHEV 29:24

phone 6:9 119:17

photo 38:14

phrase 91:18

physics 106:14

pick 54:12,13,13,14

picture 38:9,12,13

68:8

pie 111:9

piece 49:2 75:9

92:10 107:4

pieces 95:17

place 6:20 32:14

106:19,22 108:14

placed 99:8

places 53:24

plan 8:11 13:21

33:5 71:4 101:8

planning 59:21

plans 62:12

plant 20:16

plasma 28:14

play 42:11 104:1

played 114:2

playing 78:10

plays 103:24

please 8:16 9:17,24

10:2 39:7 40:18

59:17 94:21 95:13

95:16

pleased 6:11

plethora 43:1

plug-in 4:9 7:3 11:3

18:6 20:10 29:22

30:6 44:22 72:19

73:1 77:7 104:15

104:16 105:16

108:1,2 111:15,20

114:18 115:2

plug-ins 34:7

plunged 81:22

plus 53:8 68:12

point 3:22 12:4

28:21 34:8,17

36:4 38:23 40:18

66:12 79:15 82:10

93:19 98:1 109:21

109:22,24 112:8

116:16

pointed 20:14

pointing 37:4

points 5:13 10:11

52:15 53:18 62:15

62:18 76:9 84:10

policies 22:22

23:12 26:18

policy 22:19 23:3

62:3 63:22 64:24

96:8

policymakers

47:20

political 23:2

polling 65:19

pollutant 91:15

pollutants 6:24

35:15 36:1,1

91:19

pollution 17:2,13

47:4 63:23 67:24

68:11 70:19 72:23

83:1,2 119:12

population 96:23

Porsche 10:20

portion 79:4 91:20

96:22 98:8

ports 14:12

position 116:9

positioned 96:5

positioning 43:12

positions 10:23

possible 24:15

31:12 89:11 91:10

104:2

possibly 14:4 73:14

88:2

posting 106:19

potential 73:6 79:4

85:2

potentially 67:19

pounds 104:3

power 20:15 27:16

68:4 73:1 98:9,17

101:15 102:14,24

powered 27:5

powers 72:21

precedence 109:14

predicting 13:16

predominantly

106:4

prefer 13:9 35:13

79:17 87:3

preferable 87:5

preference 47:17

116:11,12

preferences 50:17

preferred 107:9

preliminary 42:22

prepared 102:17

present 43:6 46:4

88:18 89:20 119:6

presentation 35:5,7

41:18 45:2 50:16

presented 12:24

21:10 43:9 45:11

102:8

president 23:8 70:7

96:2 118:22

presiding 6:11 9:7

95:6

pretty 52:23 56:3

58:3 104:12

110:12

prevalent 77:9

previously 89:17

price 31:3,9 64:9

65:4

prices 42:2 55:8,13

pricing 44:16

primarily 98:3

primary 11:19

16:18 20:1,2

26:24 68:4 81:9

91:2

principles 16:9,22

90:14

print 37:13 79:2

Printer 79:1

printers 14:13

printing 37:22 38:4

79:1,5

prior 45:18

priorities 67:4

probably 33:3 88:4

problem 45:3

88:24 110:24

procedure 104:14

109:9

procedures 27:2

104:18,19

proceed 45:7

proceedings 120:16

121:10,13

process 8:21 13:2

17:14,20 21:11

22:14 23:23 37:6

46:15 47:14,20

50:12 70:21 112:9

procure 14:8

produce 17:22

produced 83:4

producing 24:12

111:10

product 7:13

production 20:18

32:23 38:5

products 17:8

43:22 89:4

Professional 121:6

profile 29:3,4

profound 63:17

program 3:18 15:2

15:20 27:11 28:5

28:8 57:6 87:21

87:23 88:3 96:10

100:2

programs 102:21

projected 83:21

projector 10:9

proliferation

101:22

prominent 16:13

23:1 64:14 67:15

68:10,13 71:24

73:12

prominently 34:20

34:21 49:4

prominently-dis...

48:16

promote 24:9

promotes 24:22

96:7 98:5

promoting 23:12

promulgated 45:14

propane 31:23

proper 45:1

properly 84:10

proportion 68:2

proposal 3:4 5:13

5:14,23 20:10

36:7 40:2,5 41:6

41:24 75:21 78:5

79:7 86:22 97:5

103:6 105:6

proposals 13:3

proposed 1:6 6:4

6:16 7:8 11:18

12:3 14:2 15:17

20:13 32:5 40:12

46:12 47:5,21

48:9,11,12 50:6

58:5 62:9 69:6

76:7,10,14 77:1,3

78:7 79:21 81:6

85:10 86:16 89:7

90:15 119:8

proposing 69:16

73:20

prospect 84:20

prospective 40:15

40:21 42:1,8,17

43:10 44:20

protect 119:9
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Protection 1:1 3:3

3:12 4:4 39:24

81:4

prototypes 101:11

proud 75:23

provide 5:18 11:7

13:21 16:1 27:12

35:23 36:3 37:7,9

37:16 46:19 47:11

47:24 49:1 59:12

59:21,23 61:13

62:8 63:3 67:7

68:7 73:21 76:3

78:2 80:7 81:10

83:18 88:2 98:3,4

98:21 109:17

112:24 115:11,13

provided 47:20

87:17 98:7 100:6

115:21

provides 12:5 49:9

67:6 71:18 78:9

79:8 97:14 120:1

120:5,9

providing 47:9

48:17,21 49:16

58:14 61:12 68:6

71:5 73:15 77:7

77:18 97:5,18

106:16

Proving 29:17

public 1:5 3:2 5:6

8:5 10:22 21:18

32:14 41:3 45:13

45:19 67:20 82:7

96:8 97:2,3 98:20

99:23 102:5,8

121:24

pump 16:7 49:20

63:12 69:24 74:3

purchase 4:3 18:11

21:11 24:14 32:10

32:15,19 42:12,23

50:16 53:10 61:17

64:21 76:6 82:11

89:2

purchased 99:14

117:13

purchasers 40:15

40:21 42:2,9,18

43:10 44:20

purchases 27:17

63:5 65:9 66:10

purchasing 11:16

12:14 21:8 24:12

41:4 46:20 49:19

50:14 69:1 73:1

73:22 89:11,23

101:7 111:13

119:23

purely 91:12

purpose 68:4 83:6

purses 119:10

push 25:15

pushing 24:17

put 6:20 7:15 33:15

33:17,18,22 43:21

53:22 56:14 63:10

95:17 106:22

108:14 110:8

putting 54:18

93:23 104:3 105:4

p.m 8:13,15 94:13

P.X 23:6

Q

quadruple 18:8

quality 12:19

quarter 90:6

question 33:12,14

33:22 38:8 56:24

58:1,11 60:19

74:9,22 92:22

113:6,8,11 114:21

questions 9:4 15:14

32:20 44:19 92:23

95:3 112:9 113:7

quick 67:6 72:5,7

88:1 94:17

quickly 17:18 31:5

33:3 37:5 48:2

91:17

quite 59:12 61:10

65:5 72:7

quoting 18:22

R

R 2:14 69:12

118:16

raised 33:12 44:19

90:14 99:7

range 17:15 18:19

36:15 71:11 98:2

105:18 108:16,19

116:18

rank 18:10

rankings 58:3,4,6,9

rate 20:3 43:23

57:5 110:6 114:9

rated 78:7

rates 108:19

rating 4:15 6:22

18:16 20:2 36:1

57:6 76:21 77:19

80:5 84:11

ratings 14:19 44:1

44:2 49:14 84:13

86:5 100:7

reached 5:3

reaction 99:10

reactions 90:14

read 48:2 57:23

111:7

readily 73:8

ready 37:19 38:3

39:5,9 75:12

79:17 95:20

103:21

real 93:9 114:21

realistic 89:15

realities 43:4

reality 42:5

realize 40:5

realized 114:5

really 31:1,18

34:17 36:5 51:24

52:13,21 53:12,19

54:24 55:8,9,14

56:4,9,22 57:19

66:12 74:12 75:9

87:24 106:2 107:3

107:21 111:20

116:15

reason 51:5 106:10

106:20

reasonable 9:10

43:8 95:9

reasons 53:20

78:19 81:9

receive 77:5 119:16

received 19:13

78:16

receiving 68:8

reception 8:17,23

recession 81:21

recognize 40:8

42:14 81:18 96:22

recognizes 24:7

84:4

recognizing 49:5

recommend 29:6

35:10 79:9 91:19

recommendation

13:11 43:5 110:9

recommendations

104:10,13

recommended

17:11

reconsider 79:24

reconvene 8:14

94:6,16

reconvening 94:12

record 9:9 33:4

95:7,19

redesign 14:5

46:12

reduce 18:12 71:8

102:9 106:23

107:1

reducing 22:23

63:9 70:18

reduction 96:17

100:16

reductions 98:13

redundant 15:9

reference 117:11

referenced 32:22

references 88:2

refining 68:1

reflect 23:17,22

30:2 50:17

reflection 90:23

92:4

reflects 48:13

100:11 119:19

regard 11:18 30:20

40:18

regarded 26:8

regarding 3:2,20

4:2,22 5:13 43:1

44:20 67:23 68:19

71:18 76:10 78:20

89:2 104:12

regardless 72:12

83:16

regards 62:16

region 13:18 28:24

regional 63:23

Registered 121:6

regular 87:20

regulated 42:15

regulation 75:16

89:7,19 99:20

regulatory 28:5

100:22

reinforcing 110:1

reiterate 53:19

relabeling 52:4

relative 31:4,6 32:3

41:9 48:23 65:4,5

65:23 66:6 67:11

67:13 68:17,18

72:4 90:23 92:23

109:23 119:13

relatively 18:2

25:24 27:4 42:3,3

90:18 91:9

relevant 91:24

reliability 12:17

reliable 99:1

relied 31:3 98:4

relieve 21:5

rely 12:13 28:6,24

29:1 66:21 98:21

relying 20:2

remainder 120:11

remarkable 99:4

remarks 10:4

118:12,13,18

remember 27:20

95:18 120:10
Jensen Reporting 312-236-6936

Page 18

remind 45:19

reminder 94:17

95:18

remove 77:16

removed 77:13

85:11

removing 77:18

renders 44:1

renewable 101:17

108:13

renewed 82:6

repair 81:20

repetitious 9:10

95:8

report 27:9 31:7,24

49:24 72:2 100:11

100:13 111:18

113:24

reported 114:3

121:9

Reporter 121:5,6,7

reporting 4:5 27:7

75:7

represent 15:20

representation

49:10 52:12

120:10

representative 51:6

74:12 93:13

represented 20:16

representing 10:14

10:16 34:18 39:21

80:16 103:15,16

represents 22:5

39:19 88:13

requests 101:13

require 14:1 80:2

required 4:14 14:5

15:9 46:23 49:4

74:11 114:16

requirement 33:16

requirements 6:20

6:21 14:7 15:4

19:9 33:20 38:1

89:21 104:6

109:14

requires 7:24 33:22

35:23 38:24

requiring 5:7 6:21

26:3

research 7:10

11:12 52:10 72:8

80:19 97:7 103:18

116:14,20 117:12

117:15,22

researcher 118:18

reservationists

99:12

reside 118:16

resist 99:9

resolution 105:2,6

115:18 116:2

resolve 103:1

resonated 51:23

resource 64:2

102:2

resources 15:1,19

28:24 80:21

respect 23:19 27:7

41:18 44:3,13

respective 32:1

respond 44:19 48:9

58:10 64:8

responding 64:4

responds 48:20

50:7

response 10:23

24:15 99:20

responses 12:3

13:1

responsibilities

96:4

responsibility 28:2

responsible 20:9

72:24

responsive 98:22

rest 49:11

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vast 14:2

vehicle 4:3,17 7:6

10:16 11:14,15,17

11:22 12:8,19

14:14,15,17,21

16:3,12,17,18

17:15,16,19 18:15

18:20,24 19:2,3,4

19:7 20:23 21:1,8

21:11,21 22:10,10

24:6,8,9,19,20,22

25:3,9,20,22 27:8

27:11,14,14,16,24

28:9 29:2,6,10,13

29:19 30:11,22

32:10,11,17 36:5

36:15 38:9,11,12

41:4,15 42:4,9,12

43:6 44:6,8,16,16

44:17 45:4 46:14

46:18 47:1 48:3

48:15,23 49:23

50:2 51:14 52:8

52:20 53:4,12

54:11 59:9 60:21

61:17 66:10,16

67:11 68:6,18,21

68:21,22 69:1,16

70:7 71:8,19 72:5

72:6,12 73:1,6,8

73:10,22 76:19,21

78:2,10,13,17

80:10 81:8,12

82:12 83:12,16,22

87:15 88:20 89:10

89:15 90:24 91:5

91:6 96:13,23

97:17 100:5 101:7

101:9 105:4,23

107:9,17,23

109:12 111:2

112:5,15 113:13

113:24 119:1,14

119:21 120:3,4

vehicles 3:5,14,21

4:9,10 6:22 7:2,2

8:10 11:2,3,4,6,8

12:20,21 13:19

14:16 16:5,16

17:23,24 18:2,4

18:10,17,19,23

19:14,16,22 20:3

20:5,7,11,15,18

20:21 21:12,17

22:1,4,7,8 23:13

24:2 25:11 26:22

27:3,21,21 28:7

28:16 30:13,14,18

31:5 32:7,18 34:6

34:8,9 36:23,24

40:3,12 42:15

43:2,23 44:3,23

45:1 47:8,18 48:8

48:23,24 49:17,19

50:4,9,14 51:21

52:4 58:13 59:5

61:13 62:17 64:17

65:5 66:11,18,20

67:1,6,14,17,24

71:17 72:15,20,22

75:6,7 77:8,11,18

77:19 78:7 79:11

79:16,18 80:1

82:4,8,15,19 83:4

84:11,16,18,23

85:1,19 86:8 87:6

87:19 91:2,24

92:3,14 93:1,1,2

93:24 96:20,21

97:1,2,9,12,13,19

97:20,22 98:23

99:1,18 100:4,9

100:12,15,18

101:3,19,21,23

102:3,9,13,16,19

102:23 103:2,8,10

104:15,20 105:3,5

105:10,16,17

110:3,4 111:1,3

116:23 119:12,13

vehicle's 20:9

26:10 41:8 42:9

43:12 44:20 68:9

71:6 72:1 84:1

vehicle-specific

40:17

verge 66:14,15

verses 116:5

version 40:24

87:12 114:23

versions 17:6 45:18

versus 5:7 68:24

117:2

vet 51:7

veteran 50:22 56:6

veterans 50:24

51:1

vice 96:2

Vice-President

22:19

view 36:7,18 62:20

93:19 116:7,11,13

116:18

views 3:10 6:4

22:12 23:17

virtually 30:22

43:20 50:2

virtue 59:7

visible 12:6

vision 11:23

visiting 11:12

vital 72:19 82:11

volatile 31:4

volatility 31:9

Volkswagen 10:21

volt 32:9

volume 74:20

volunteer 50:24

Volvo 10:21

vulnerable 54:3

W

W 23:7

waiting 116:9

waiver 102:14

walking 83:19

wallets 119:10

want 7:7 9:13

23:18 26:5,13

34:3,19,21 35:2

46:2 52:16,24

53:3,10,12 54:7

56:8 62:19 63:1

65:9 74:23 79:24

83:7 86:2,4,6,21

92:1 93:22 94:21

96:6 97:8,10

105:17,21 107:3,5

107:5 110:5

113:14 114:21,22

wanted 47:22 50:3

51:24 60:19

wants 118:1

war 54:5

warming 17:1

55:24 63:8,16,23

68:11 70:18 88:18

88:22 119:12

water 31:21 63:7

way 13:16 16:11

25:20 34:4 47:12

53:21 54:19 61:14

68:20,21 73:24

74:12 78:2 82:8

85:8,12,14 86:11

87:11 94:2 96:7

102:7 107:7
Jensen Reporting 312-236-6936

Page 23

108:17 114:24

115:14 116:23

ways 51:21 76:2

86:15 97:20

weather 109:1,1

Web 11:9 28:20

49:12 58:6,8

100:7 109:20

119:15 120:12

Web-based 13:2,4

week 41:1 92:18

weight 96:17

100:16

weighted 84:12

welcome 3:1 6:8

39:7 62:11 94:15

well-informed 97:3

well-known 76:17

went 35:5

weren't 49:14

we'll 8:2 34:17

59:23 86:22 94:12

112:10

we're 3:15 5:13 8:3

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39:5 54:2,3,4,15

58:12 59:11,14,17

61:11 74:18 75:12

87:11 94:6 99:20

104:2 105:3

106:11,20,21,22

107:5,7 108:20,23

111:23 113:22,23

118:7 120:15

we've 53:23 58:4

86:16 96:13 99:4

104:24,24 116:14

117:15

wheels 107:13

whichever 75:8

white 79:7 80:9

91:12

wide 17:19 19:10

widely 3:13 7:3

72:2

wider 77:20

widespread 102:3

102:22

Wild 61:24

wildlife 62:4,5 63:7

63:17 64:2 69:3

willing 98:18 100:9

willingness 65:21

wind 27:5

window 3:14 15:6

38:22 46:13 67:3

68:22 71:3,5,10

73:20 74:1

windows 8:9 15:8

winter 109:6

wish 51:13 94:9

wishes 8:15

wishing 51:20

witness 9:11

witnesses 9:2,16

95:1,10

wonder 38:10

wondered 116:8

wondering 59:20

Wood 2:3 5:10

word 43:22 91:20

117:1

work 14:8 29:6

37:18 45:12 53:3

65:16 66:24 70:22

74:6 84:5,7 90:4

90:11 91:22 92:19

102:15 103:1,17

worked 14:24

26:22 45:15

working 69:20 90:9

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works 106:14

world 90:10

worldwide 63:19

world's 55:21 56:1

worried 87:11

worry 111:16 112:4

worst 4:19 43:20

worthy 12:21

wouldn't 91:7

114:17

wrap 112:2

write 33:11 39:7

writing 37:16

106:11

written 8:6 13:23

22:13 23:22 33:6

33:8 37:24 74:23

76:12 86:21,23

116:9,13

wrong 107:6 115:5

wrote 109:16

WYNDHAM 1:8

X

x 30:5,6

Y

Yeah 75:5 112:16

year 3:11 8:9 15:23

27:19 38:3 40:10

40:24 42:6 45:15

45:17 70:1,1,12

70:12 80:1

years 6:18 14:23

18:8 24:6 40:8,20

46:22 48:15 49:20

51:8 52:9,9 55:7

55:22 69:17,19

70:8,22 79:14

99:22 103:19

104:14 118:21

119:7

York 49:3

y'all 33:2

Z

Zalzal 2:7 39:7

46:6,7,8 59:18,23

zero 20:11 86:10

87:4 93:14 101:9

102:19 105:8

112:1 113:9,11

zero-to-100 87:2

115:16

$

$20,000 53:11

$3 70:10,11

$6 70:12

0

0-to-100 77:23 80:5

084-002761 121:20

1

1 12:12 16:23 24:1

48:9,11,13 49:15

49:19 50:7 69:23

76:14 78:21 79:4

87:1 107:19

118:13 119:4,11

119:18,24

1.3 15:21 69:14

10 96:15

100 21:23 30:6,7

73:16 74:11,14

86:10 87:4,8

93:14 99:5 105:8

105 42:8

110 32:8

12 10:15

1204 118:17

130 113:14

14 1:12

150 114:12

17 82:5

19 118:16

19.7 19:4

1994 104:16

2

2 12:3 35:9 36:13

36:16 39:6,6 48:9

48:12 59:13,15

70:1 116:12,19

117:22 119:12

120:4

20,000 99:8

2003 51:9

2005 96:15

2007 4:12 6:20 40:7

47:1 69:21 96:11

2008 40:10 45:15

2009 121:22

2010 1:12 8:7

2011 14:3 38:1

40:24

2012 8:9 15:23 38:3

40:4 42:6 45:18

70:8 80:1 87:19

2016 70:8

2017 70:23

2020 70:1,12

2025 70:23

2030 70:2,12

22 103:19

22nd 5:15 8:7 33:6

230,000 99:6

25 66:22

28th 23:6

3

3 19:24 35:13,16

119:14 120:8

3MM 36:10

30 6:17 7:10 40:20

46:22 69:17 79:20

105:24 119:7

30th 6:15

30-something

107:13

32-year-old 80:17

32.9 19:3

33.7 115:9,10

4

4 20:22 62:7 75:12

119:14

4:00 8:13

40 55:22 88:14

110:11 118:21

40s 110:13

47 62:6

5

5 21:13 87:2 119:16

50s 110:13

53.6 18:22

6

6:00 8:15 94:7,12

60611-2707 118:17

62.8 19:1

633 1:9

7

70 11:13

700,000 46:9

75 20:20 113:17

77 10:16
Jensen Reporting 312-236-6936

Page 24

8

80 77:4 87:8

81 11:16

85 116:5

9

90 79:19,21 87:8,8

90s 114:3

95 116:5

98 107:11,14,16

99.9 34:23