State of California 

AIR RESOURCES BOARD 

STAFF REPORT: INITIAL STATEMENT OF REASONS FOR 

RULEMAKING

NOTICE OF PUBLIC HEARING TO CONSIDER PROPOSED 

AMENDMENTS TO NEW PASSENGER MOTOR VEHICLE 

GREENHOUSE GAS EMISSION STANDARDS

Date of Release: August 7, 2009 

Scheduled for Consideration: September 24-25, 2009

This report has been reviewed by the staff of the California Air Resources Board and 

approved for publication. Approval does not signify that the contents necessarily 

reflect the views and policies of the Air Resources Board, nor does mention of trade 

names or commercial products constitute endorsement or recommendation for use. 
2

State of California 

AIR RESOURCES BOARD 

Staff Report: Initial Statement of Reasons 

for Proposed Rulemaking

PUBLIC HEARING TO CONSIDER PROPOSED AMENDMENTS TO 

NEW PASSENGER MOTOR VEHICLE GREENHOUSE GAS 

EMISSION STANDARDS 

Date of Release: August 7, 2009 

Scheduled for Consideration: September 24-25, 2009

TABLE OF CONTENTS 

I. INTRODUCTION AND BACKGROUND................................................................... 2 

II. DESCRIPTION OF PUBLIC PROBLEM, ADMINISTRATIVE 

CIRCUMSTANCE PROPOSAL IS INTENDED TO ADDRESS; PROPOSED 

SOLUTIONS AND RATIONALE FOR EACH REGULATORY PROVISION..... 3 

III. SUMMARY OF RECOMMENDED ACTION............................................................ 5 

IV. AIR QUALITY, ENVIRONMENTAL, AND ECONOMIC IMPACTS ................... 7 

A. Air Quality .......................................................................................................... 7 

B. Economic Impact ............................................................................................. 7 

C. Alternatives........................................................................................................ 8 

V. ENVIRONMENTAL JUSTICE .................................................................................... 9 

VI. LIST OF APPENDICES .............................................................................................. 10 

VII. REFERENCES.............................................................................................................. 11 

I. INTRODUCTION AND BACKGROUND 

Climate change is critically important to California. If left unchecked, its far-reaching 

consequences will dramatically affect many aspects of our lives including public 

health, the economy, and the environment. In 2002, in response to the threat of 

global warming, California adopted AB 1493 (Pavley (Chap. 200, Stats.2002)), which 

directed the Air Resources Board (ARB) to develop regulations to reduce 

greenhouse gas emissions from the new passenger vehicle fleet (passenger 

vehicles are responsible for approximately 30 percent of the total greenhouse gas 

emissions in California). 

In September 2004, the ARB adopted regulations (known as the “Pavley 

regulations”) requiring significant reductions in greenhouse gas emissions from 

passenger cars and light-duty trucks (i.e., vehicles less than 8,500 lbs. gross vehicle 
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weight) and sport utility vehicles (i.e., medium-duty passenger vehicles). These 

requirements, which are phased-in from 2009 through 2016, will reduce emissions 

from the new vehicle fleet by 30 percent within this timeframe. 

The Pavley regulations reduce greenhouse gas emissions from new passenger 

vehicles by requiring that each year between 2009 and 2016, manufacturers meet 

separate increasingly stringent fleet average greenhouse gas levels based on the 

size of the vehicles – a lower one for passenger cars and the smallest of the lightduty trucks (PC + LDT1), and a higher one for larger light-duty trucks and mediumduty passenger vehicles (LDT2 + MDPV). The greenhouse gas emissions that are 

included within the scope of the Pavley regulations include carbon dioxide (CO2), 

methane (CH4), and nitrous oxide (N2O). In addition a manufacturer may earn 

credits toward complying with the requirements by equipping vehicles with an 

advanced “low-leak” air conditioning system or one that uses a refrigerant with a 

lower global-warming potential than HFC-134a, which is most commonly used today. 

To demonstrate compliance with the fleet average greenhouse gas requirements, a 

manufacturer must first group the vehicles in its fleet based on similarities, such as 

engine, transmission type, or weight, that impact greenhouse gas emissions. A 

manufacturer must then conduct testing to determine the greenhouse gas emissions 

from each group of vehicles. Using this data, and applying any emission credits that 

may be earned for vehicles that are equipped with advanced air conditioning 

systems, the average grams per mile of “CO2 – equivalent” emissions is calculated 

for each vehicle group. A manufacturer must then calculate its overall fleet average 

greenhouse gas level by calculating the sales – weighted average CO2 – equivalent 

emissions from its PC + LDT1 fleet and from its LDT2 + MDPV fleet. Manufacturers 

are required to submit emissions testing data and sales data in sufficient detail to 

allow staff to verify a manufacturer’s fleet average greenhouse gas levels for each 

model year. 

II. DESCRIPTION OF PUBLIC PROBLEM, ADMINISTRATIVE CIRCUMSTANCE 

PROPOSAL IS INTENDED TO ADDRESS; PROPOSED SOLUTIONS AND 

RATIONALE FOR EACH REGULATORY PROVISION 

Since Board approval in 2004, motor vehicle manufacturers and their trade 

associations have challenged the Pavley regulations in numerous federal and state 

court proceedings and have opposed California’s request to (U.S. EPA) for a 

required waiver of preemption under the federal Clean Air Act to allow California to 

enforce its adopted standards. In the waiver context and elsewhere they have also 

argued that other states, exercising their right under section 177 of the Clean Air Act 

to adopt California’s vehicle emission standards, will create an unmanageable 

“patchwork” of different programs due to variations in the mix of vehicles sold in 

each of the states. 

On May 19, 2009, challenging parties, automakers, California, and the federal 

government reached agreement on a series of actions that would resolve these 

current and potential future disputes over the standards through model year 2016. 

In summary, the U. S. Environmental Protection Agency and the U. S. Department of 
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Transportation agreed to adopt a federal program to reduce greenhouse gases and 

improve fuel economy, respectively, from passenger vehicles, to achieve equivalent 

or greater greenhouse gas benefits as the Pavley regulations for the 2012 – 2016 

model years. Manufacturers agreed to ultimately drop current, and forego similar 

future legal challenges, including challenging a waiver grant, which occurred June 

30, 2009. 74 Fed.Reg. 32744 (July 8, 2009). For its part, California committed to: 

(1) revise its standards to allow manufacturers to demonstrate compliance with the 

fleet average greenhouse gas emission standard by “pooling” California and Section 

177 State vehicle sales; (2) revise its standards for 2012-16 model year vehicles 

such that compliance with EPA-adopted greenhouse gas standards would serve as 

compliance with California’s standards; and (3) revise its standards as necessary to 

allow manufacturers to use emission data from the federal Corporate Average Fuel 

Economy (CAFE) program to demonstrate compliance with the Pavley regulations. 

The current proposed amendments to the Pavley regulations, which are discussed in 

greater detail below, address the first and third commitments made by California. 

Amendments to the regulations that will be needed to implement the second 

commitment are scheduled for presentation to the Board for consideration in 

December of this year. 

As to the second commitment, revising the standards to allow compliance with the 

EPA-adopted greenhouse gas standards in lieu of compliance with California 

standards, EPA is anticipated to issue a Notice of Proposed Rulemaking (NPRM) on 

the national program in August 2009. While the particulars of the federal program 

are unknown at this time, we anticipate that its compliance provisions will be similar 

to California’s in that manufacturers will be required to meet a fleet average 

greenhouse gas requirement and will accrue credits for over compliance with the 

fleet average and debits for under compliance. 

Under either the existing regulations requiring California-only sales data or under the 

proposed pooling option, we foresee compliance and no debits in 2009 and 2010, 

and for most manufacturers, none in 2011 either. However, in the unlikely event that 

debits are incurred they must be equalized within the five model years provided in 

the regulation, at which time California will be participating in the federal program 

with its own scheme for the generation of credits and debits. In order to ensure that 

debits incurred in the 2009 through 2011 model years are equalized, California will 

likely require that manufacturers opting into the federal program will offset any debits 

incurred in California by earning a commensurate number of credits in the federal 

program and retiring those credits rather than using them to meet their federal 

obligations. Staff will consider amending the Pavley regulations at the December 

Board hearing, to address this issue. Manufacturers that do not equalize debits 

within the five model years provided in the regulations shall be subject to penalties 

under the provisions of section 43211 of the Health & Safety Code. Under the 

proposed pooling option, debits that are not equalized in the time specified must be 

apportioned between California and the Section 177 states according to their new 

vehicle sales in the model year the debits are first accrued. However, as EPA 

indicated in granting California’s waiver, (74 Fed.Reg. 32744, 32778 (July 8, 2009)), 

while debits from model year 2009 may offset credits generated in later years and 

reduce available credits, noncompliance or civil penalties cannot be based on 2009 

MY debits. While it is currently unknown exactly how credits earned under the 
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Pavley program in the 2009 through the 2011 model years will be treated under the 

federal program, this issue will presumably be address by EPA in their final rule. 

III. SUMMARY OF RECOMMENDED ACTION 

Consistent with the aforementioned agreement, staff is proposing two types of 

modifications to the Pavley regulations to address manufacturers’ concerns. 

 

Allow Manufacturers to Meet the Fleet Average Greenhouse Gas Emission 

Standard by “Pooling” the California and Section 177 State Vehicles

First, staff proposes to allow a manufacturer to comply with the fleet average 

greenhouse gas requirement based on the combined sales of passenger cars and 

light-duty trucks in California and the other states that have adopted California’s 

vehicle regulations (“Section 177” states). Manufacturers have stated that this 

approach will allow them to reduce overall compliance costs and implementation 

concerns, since they will be able to develop a compliance plan for all states subject 

to the Pavley requirements, without having to address the particular vehicle mix in 

each individual state 

Accordingly, manufacturers that choose to comply with the fleet average GHG 

requirements by pooling GHG emissions for California and Section 177 states must 

state their intention to do so prior to the start of the model year. Since the 

certification process for model year 2009 and 2010 is already underway, 

manufacturers must notify the Executive Officer of their intent to comply by pooling 

emissions in writing within 30 days of the effective date of the amendments. 

Beginning with the 2011 model year, manufacturers must notify the Executive Officer 

in writing prior to the start of the applicable model year. A manufacturer choosing 

emission pooling as a compliance option must commit to pooling emissions from 

California and all Section 177 states. A manufacturer that chooses to pool GHG 

emissions for any model year may not opt-out for that model year, however, it may 

opt out for future model years. 

Any manufacturer that chooses to comply with the Pavley regulations by meeting the 

fleet average greenhouse gas requirements based on the combined sales of new 

passenger vehicles in California and the Section 177 states will be required to 

submit emission testing data and sales data for the combined fleet. The data must 

be submitted in sufficient detail to allow staff to verify the manufacturer’s average 

greenhouse gas levels for each model year. This is an additional reporting 

requirement. A manufacturer must still provide to the Air Resources Board 

California-specific test data and sales data in sufficient detail to allow staff to easily 

calculate the fleet average greenhouse gas emissions for new passenger cars and 

light-duty trucks sold in California in each model year. This data is needed in order 

to track progress in meeting the targeted GHG emission reductions from the 

transportation sector called for in AB 32. Manufacturers must also provide statespecific test data and sales data for each of the Section 177 states. In many cases, 

these states have their own GHG programs similar to California’s AB 32 program 

that require emission reductions from sectors other than the transportation sector. 
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Accordingly, these states too will need to track progress in reducing GHG emission 

data from the transportation sector. The state-specific test and sales data must be 

submitted separately from the combined California plus Section 177 state data. 

Allow the Use of Data from the Federal CAFÉ Program to Demonstrate 

Compliance with the Pavley Regulations 

The second change that staff is proposing is to allow manufacturers to use emission 

test data from the federal CAFE program to demonstrate compliance with 

California’s Pavley regulations. This change will also reduce costs to the 

manufacturers, by reducing the number of tests that must be conducted solely for 

the purpose of California’s regulations. 

To demonstrate compliance, manufacturers must submit GHG emission data for the 

worst case vehicle for each test group. Manufacturers may submit additional test 

data for vehicles within the test group with lower GHG emissions than the worst case 

configuration. Consistent with the May 19, 2009 agreement, manufacturers may use 

emission data from tests conducted as part of the federal CAFE program. When 

submitting emission data from the federal CAFE program, manufacturers must make 

a demonstration that the appropriate vehicle emission test data, consistent with the 

regulatory requirements, has been selected. A manufacturer that elects to use 

CAFE Program data to demonstrate compliance with the greenhouse requirements 

must use all acceptable data from the program, and may forego testing of the “worstcase” configuration. 

Furthermore, because manufacturers are not required to measure methane (CH4) 

and nitrous oxide (N2O) emissions under the CAFE Program, a manufacturer that 

uses CAFE data to demonstrate compliance with the greenhouse gas requirements 

will be allowed to substitute the term 1.9 CO2-equivalent grams per mile for the 

terms “296 x N2O + 23 x CH4” in the following equation, which is used to calculate 

the CO2-equivalent values for the vehicles. 

CO2-Equivalent Value = CO2 + 296 x N2O + 23 x CH4 - A/C Direct Emissions 

Allowance - A/C Indirect Emissions Allowance 

 

The 1.9 CO2-equivalent grams per mile value was derived from EMFAC, California’s 

inventory model for on-road vehicles. Specifically, an emission rate of 0.005 

grams of CH4 per mile was derived from the EMFAC emission rate for CH4 for 2019 

model year light-duty vehicles. An emission rate of 0.006 grams of N2O per mile 

driven was derived from the ratio of N2O to oxides of nitrogen (NOx) determined 

from emission test data generated at ARB’s vehicle test facility (Behrentz, E., Ling, 

R., Rieger, P., and Winer, A.M. Measurements of nitrous oxide emissions from lightduty motor vehicles: a pilot study. Submitted to Journal of Atmospheric Environment, 

April 2004). This ratio was then applied to the EMFAC emission rate for NOx for 

2019 model year light-duty vehicles. These values, expressed as CO2-equivalent, 

were then used to establish the fleet average greenhouse gas values (Initial 

Statement of Reasons for Proposed Rulemaking, Public Hearing to Consider 

Adoption of Regulations to Control Greenhouse Gas Emissions Form Motor 

Vehicles,” August 6, 2004). Therefore, for CAFE vehicles, it is appropriate to allow 
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use of this default value to account for N2O and CH4 emissions, when no actual N2O 

and CH4 test data is available. 

Adopt Minor Changes to the Test Procedures 

Staff is also proposing a number of minor amendments to the test procedures for 

light- and medium-duty vehicles, to align them with current federal requirements. 

These amendments consist primarily of updating the test procedures to ensure that 

the applicable dates of the sections of the Code of Federal Regulations that are 

referenced therein are current. 

IV. AIR QUALITY, ENVIRONMENTAL, AND ECONOMIC IMPACTS 

A. Air Quality 

Pooling emissions for all states may result in minor changes in greenhouse gas 

reductions within the individual states due to the portability of credits and debits 

incurred by the manufacturers. Because exactly how manufacturers will comply 

under an emission pooling scheme is unknown at this time, staff is unable to quantify 

the emissions impact for the individual states. Nonetheless, staff anticipates that 

there will be no significant emissions impact from this proposal because it does not 

fundamentally change the fleet average greenhouse gas requirements to which a 

manufacturer must certify its fleet. 

B. Economic Impact 

The proposed amendments will provide vehicle manufacturers that are subject to the 

requirements of California’s passenger vehicle greenhouse gas regulations with an 

optional method for complying with the Pavley regulations. Staff expects that the 

proposed amendments could reduce the cost of compliance for vehicle 

manufacturers that choose to meet these alternative requirements. In any instances 

where the proposed amendments would increase compliance costs, manufacturers 

retain the option to comply with the regulations as originally written. 

Manufacturers are already required to conduct emission testing to measure the CO2

emissions from their passenger fleet as part of the CAFE program. So, allowing a 

manufacturer to use these data to demonstrate compliance with California’s 

greenhouse gas requirements would reduce the number of emission tests that will 

need to be conducted solely for the California program. However, this economic 

impact, while positive, is expected to be minimal. If a manufacturer chooses to 

comply with the Pavley regulations as they currently are written, there would be no 

economic impact from these amendments on that manufacturer. 

Similarly, staff does not expect there to be any economic impacts due to the test 

procedure revisions, since manufacturers will continue to use the same test 

procedures for both California and federal purposes rather than having to conduct 

two different procedures. 
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The proposed amendments also may impose additional reporting requirements if 

manufacturers choose to calculate fleet average emissions across all states that 

have adopted the Pavley regulations. While manufacturers are currently required to 

report California sales data that are used to demonstrate compliance with the Pavley 

regulations, the amendments would require manufacturers to also report sales data 

from the other states that have adopted the Pavley regulations. The additional 

reporting requirements are needed as part of the multi-state pooled sales 

compliance option, the proposal of which is an essential element in the May 2009 

commitments. This and the other commitments best ensure that California achieves 

the greenhouse gas emission reductions required by AB 1493 and assumed toward 

meeting AB 32. Thus with this Initial Statement of Reasons staff proposes that the 

Board find it is necessary for the health and welfare of the people of the State that 

any additional reporting required by the proposed amendments apply to the affected 

businesses. 

The additional cost due to this amendment is not expected to be significant, since 

under the current regulations, each state already requires manufacturers to submit 

sales data for each of these states. The proposed amendments will simply require 

this data to also be submitted to the Air Resources Board. Manufacturers may 

choose to submit only California sales data and comply with the regulations on an 

individual state basis as they currently are written, in which case there would be no 

economic impact from these amendments on that manufacturer. 

There will be no fiscal impacts to the State from the proposed amendments, either in 

terms of tax revenue or personnel requirements. These amendments are not 

expected to change vehicle prices in a way that would alter vehicle purchase 

decisions. The inclusion of alternative compliance options does not substantially 

increase the volume of data to review that would justify hiring additional staff. 

C. Alternatives 

1. Evaluation of alternatives considered and reasons for 

rejecting them

Staff considered the following regulatory alternative to the proposed amendments. 

Do not amend current Pavley regulations. The significant proposed changes to the 

Pavley regulations (allowing manufacturers to comply with a single greenhouse gas 

fleet average level for California and all the other states that have adopted our 

regulations, and allowing manufacturers to demonstrate compliance with the Pavley 

regulations using data from the federal CAFE program) are, according to 

manufacturers, needed to reduce their costs and simplify their compliance 

demonstration. These changes could provide cost benefits for manufacturers, and 

they would maintain the emission benefits of the current regulations. The proposed 

changes to the test procedure – in addition to those changes simply implementing 

proposed changes in the regulatory text – are needed to maintain alignment with 

federal testing requirements. 
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This alternative was rejected because California committed to making the proposed 

amendments as part of the agreement that was signed by California, the federal 

government, and other parties on May 19, 2009, as discussed in section II. 

Furthermore, maintaining the Pavley regulations in their current form would provide 

no greater emissions benefit than the proposed changes, but at a likely higher cost 

to the affected industry. 

2. Description of reasonable alternatives considered that would 

lessen impact on small business

No alternatives were considered to lessen the impact on small business, because 

small businesses will not be impacted by these proposed amendments. 

3. Evidence relied upon to support initial determination in the 

notice that the regulation will not have a significant adverse 

economic impact on business

The proposed amendments will not significantly affect businesses, since vehicle 

purchase price and model availability will not be adversely impacted. Vehicle 

manufacturers will not be required to expend any money to comply with the new 

requirements. Rather, this proposal could save them money. 

4. Justification for adoption regulations different from federal 

regulations contained in the Code of Federal Regulations

There are currently no federal regulations to reduce greenhouse gas emissions from 

passenger vehicles. However, climate change threatens California’s public health, 

water resources, agricultural industry, ecology, and economy. Due to this threat 

Chapter 200, Statutes of 2002 (AB 1493, Pavley) specifically directed the Air 

Resources Board to adopt regulations to control greenhouse gas emissions from 

motor vehicles. 

V. ENVIRONMENTAL JUSTICE 

"Environmental Justice" is defined as the fair treatment of people of all races, 

cultures, and incomes with respect to the development, adoption, implementation, 

and enforcement of environmental laws, regulations, and policies (Government 

Code §65040.12(c). 

Staff does not believe that this proposal will have any adverse environmental justice 

impacts because the stringency of California’s passenger vehicle greenhouse gas 

requirements is not affected by the proposed changes to the regulations. 

Furthermore, since the criteria pollutant regulations must still be met on an individual 

state-by-state basis, there will be no increase in criteria pollutants in California due 

to mix shifting of vehicles between California and other states. 
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VI. LIST OF APPENDICES 

Appendix A: Proposed Regulation Order 

Appendix B: Proposed Amendments to the California Exhaust Emission Standards 

and Test Procedures for 2001 and Subsequent Model Passenger Cars, Light-Duty 

Trucks, and Medium-Duty Vehicles 
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VII. REFERENCES 

1. Alliance of Automobile Manufacturers, Letter from The Honorable David 

McCurdy, President and Chief Executive Officer, to The Honorable Ray 

LaHood, Secretary, United States Department of Transportation and The 

Honorable Lisa P. Jackson, Administrator, United States Environmental 

Protection Agency, May 18, 2009 

2. American Honda Motor Company, Inc., Letter from John Mendel, Executive 

Vice President, Automobile Sales, American Honda Motor Company, Inc., to 

The Honorable Ray LaHood, Secretary, United States Department of 

Transportation and The Honorable Lisa P. Jackson, Administrator, United 

States Environmental Protection Agency, May 17, 2009 

3. Behrentz, E., Ling, R., Rieger, P., and Winer, A.M. Measurements of nitrous 

oxide emissions from light-duty motor vehicles: a pilot study. Submitted to 

Journal of Atmospheric Environment, April 2004 

4. BMW, Letter from Dr.-Ing. Norbert Reithofer, Chairman of the Board of 

Management, BMW, to The Honorable Lisa P. Jackson, Administrator, United 

States Environmental Protection Agency and The Honorable Ray LaHood, 

Secretary, United States Department of Transportation, May 18, 2009 

5. California Air Resources Board, Letter from Mary D. Nichols, Chairman, to 

The Honorable Lisa P. Jackson, Administrator, United States Environmental 

Protection Agency and The Honorable Ray LaHood, Secretary, United States 

Department of Transportation, May 18, 2009 

6. Chrysler LLC, Letter from Robert L. Nardelli, Chairman and Chief Executive 

Officer, Chrysler LLC to The Honorable Ray LaHood, Secretary, United 

States Department of Transportation and The Honorable Lisa P. Jackson, 

Administrator, United States Environmental Protection Agency, May 17, 2009 

7. Daimler AG, Letter from Dr. Dieter Zetsche, Chairman of the Board of 

Management of Daimler AG and Head of Mercedes-Benz Cars, and Dr. 

Thomas Weber, Member of the Board of Management, Group Research & 

Mercedes-Benz Cars Development, to The Honorable Ray LaHood, 

Secretary, United States Department of Transportation and The Honorable 

Lisa P. Jackson, Administrator, United States Environmental Protection 

Agency, May 18, 2009 

8. EMFAC, 2003. Version 2.2, Updated April 23, 2002. 

9. Federal Register, Volume 74, No. 129 / Wednesday, July 8, 2009 / Notice, 

Environmental Protection Agency, “California State Motor Vehicle Pollution 

Control Standards; Notice of Decision Granting a Waiver of Clean Air Act 

Preemption for California’s 2009 and Subsequent Model Year Greenhouse 

Gas Emission Standards for New Motor Vehicles.” 
12

10. Ford Motor Company, Letter from Alan R. Mulally, President and Chief 

Executive Officer, Ford Motor Company, to The Honorable Ray LaHood, 

Secretary, United States Department of Transportation and The Honorable 

Lisa P. Jackson, Administrator, United States Environmental Protection 

Agency, May 17, 2009 

11. General Motors Corporation, Letter from Frederick A. Henderson, Chief 

Executive Officer, General Motors Corporation, to The Honorable Lisa P. 

Jackson, Administrator, United States Environmental Protection Agency and 

The Honorable Ray LaHood, Secretary, United States Department of 

Transportation, May 17, 2009 

12. Mazda North American Operations, Letter from Jim O’Sullivan, President and 

Chief Executive Officer, Mazda North American Operations, to The Honorable 

Ray LaHood, Secretary, United States Department of Transportation and The 

Honorable Lisa P. Jackson, Administrator, United States Environmental 

Protection Agency, May 18, 2009 

13. State of California, Air Resources Board, “Initial Statement of Reasons for 

proposed Rulemaking, Public Hearing to Consider Adoption of Regulations to 

Control Greenhouse Gas Emissions Form Motor Vehicles,” August 6, 2004 

14. State of California, Letter from Governor Arnold Schwarzenegger to The 

Honorable Lisa P. Jackson, Administrator, United States Environmental 

Protection Agency and The Honorable Ray LaHood, Secretary, United States 

Department of Transportation, May 18, 2009 

15. State of California, Office of the Attorney General, Letter from Edmund G. 

Brown, Jr., Attorney General, State of California, to The Honorable Lisa P. 

Jackson, Administrator, United States Environmental Protection Agency and 

The Honorable Ray LaHood, Secretary, United States Department of 

Transportation, May 18, 2009 

16. Toyota Motor Sales, Letter from James E. Lentz, President, Toyota Motor 

Sales, to The Honorable Lisa P. Jackson, Administrator, United States 

Environmental Protection Agency and The Honorable Ray LaHood, 

Secretary, United States Department of Transportation, May 17, 2009 

17. U.S. Environmental Protection Agency and U.S. Department of 

Transportation, “Notice of Upcoming Joint Rulemaking to Establish Vehicle 

GHG Emissions and CAFE Standards,” 

http://www.nhtsa.gov/staticfiles/DOT/NHTSA/Rulemaking/Rules/Associated%

20Files/Joint_CAFE_GHG_Emissions.pdf

18. Volkswagen Group of America, Letter from Stefan Jacoby, President and 

Chief Executive Officer, Volkswagen Group of America, to The Honorable 

Lisa P. Jackson, Administrator, United States Environmental Protection 
13

Agency and The Honorable Ray LaHood, Secretary, United States 

Department of Transportation, May 17, 2009