Daniel F. Akerson 

Chairman and Chief Executive Officer 

General Motors Company Mail Code 482-C39-B10 300 Renaissance Center Detroit, MI 48265-3000

Tel 313-667-3588 Fax 313-667-3122 

July 29, 2011 

The Honorable Ray LaHood 

Secretary 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. 

Washington, D.C. 20590

The Honorable Lisa Jackson 

Administrator 

Environmental Protection Agency 

Ariel Rios Building 

1200 Pennsylvania Avenue, N.W. 

Washington, D.C. 20460

Dear Secretary LaHood and Administrator Jackson: 

General Motors Company recognizes the benefit for the country of continuing 

the historic National Program to address fuel economy and greenhouse gases 

that the Environmental Protection Agency (EPA) and the National Highway 

Traffic Safety Administration (NHTSA) began in 2009 with the standards for 

model years 2012 through 2016, and that those agencies are continuing for model 

years 2017 through 2025. 

General Motors Company fully supports proposal and adoption of a continued 

National Program. We understand that the continued National Program will be 

subject to full notice-and-comment rulemaking, affording all interested parties, 

including General Motors Company, the right to participate fully, comment, and 

submit information, the results of which are not pre-determined but depend 

upon processes set by law. General Motors Company welcomes the opportunity 

to be a partner in helping to advance a continued, harmonized National 

Program. 

General Motors Company believes that the robust and comprehensive mid-term 

evaluation described by EPA and NHTSA in the Supplemental Notice of Intent is 

critical, given General Motors Company’s view of the uncertainty associated 

with the model years 2022-2025 standards. Although General Motors Company 

may not have full knowledge about the evolution and cost of technologies 

necessary to meet these standards, particularly in 2022-2025, the mid-term 

evaluation provides a basis for General Motors Company’s support for adoption 

of standards for model years that far into the future. 

General Motors Company also commits to working with EPA and NHTSA, the 

states, and other stakeholders to help our country address the need to reduce 

dependence on oil, to save consumers money, and to ensure regulatory 

predictability and certainty by developing this kind of strong, coordinated 

National Program. 
The Honorable Ray LaHood 

The Honorable Lisa Jackson 

Page Two 

July 29, 2011 

In order to promote the adoption of the continued National Program, General 

Motors Company commits to take the following actions, subject to the 

understandings described below. 

1. General Motors Company commits not to contest the final standards 

 established by this rulemaking and by California for MYs 2017 through 2025 

 if: 

a. EPA proposes national GHG standards and NHTSA proposes CAFE 

 standards for MYs 2017-2025 as substantially described in the 

 Supplemental Notice of Intent to conduct rulemaking, but with necessary 

 technical corrections and any non-substantive refinements, and if the 

 agencies adopt standards as substantially proposed. 

b. California adopts standards on GHG emissions from new motor vehicles 

 for MYs 2017 through 2025 such that compliance with the GHG emissions 

 standards adopted by EPA, even if amended after 2012, shall be deemed 

 compliance with the California GHG emissions standards, in a manner 

that is binding on states that adopt and enforce California’s GHG 

 standards under Clean Air Act (CAA) section 177. 

2. General Motors Company reserves all rights to contest final actions taken 

 or not taken by EPA, NHTSA, and CARB as part of or in response to the 

 mid- term evaluation. 

3. General Motors Company commits that it will not contest final actions taken 

 or not taken by EPA granting California’s future request for a waiver of 

 preemption under section 209 of the CAA for its GHG emissions standards for 

 motor vehicles for MYs 2017-2025, if California revises its regulations as 

 described above in (1)(b), but this does not apply to subsequent amendments 

 California may make. 

4. General Motors Company will use its best efforts to ensure that the trade 

 association(s) to which General Motors Company belongs will not contest the 

 actions discussed in (1) and (3) above. 

Sincerely, 

Daniel F. Akerson 

 Chairman and Chief Executive Officer