Document ZJawJNkKmw6YBJVEe4LB8Y1Vd

I N ATIO N AL COALITION FOR ADVANCED TRANSPORTATION April 9, 2018 The Honorable Scott Pruitt Administrator U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, NEW. Mail Code; "l 10 i A Washington, D.C, 20460 The Honorable Elaine L. Chao Secretary U.S. Department of Transportation 1200 New Jersey Ave, S.E. Washington, D.C. 20590 Re: EPA Mid-Term Evaluation and Upcoming Joint Rulemaking Dear Administrator Pruitt and Secretary Chao: As members o f the National Coalitionfo r Advanced Transportation (NCAT), we write in response to the U.S. Environmental Protection. Agency's April 2, 2018 Notice regarding the MidTerm Evaluation o f its Model-Year (MY) 2022-2025 greenhouse gas emission standards for lightduty vehicles (MTE Notice) and the upcoming joint rulemaking described in the notice. The United States is undergoing an unprecedented transformation o f its economy, including the simultaneous reshaping of both, the transportation and energy sectors. No country7is better positioned to lead the world in creating and building the transportation system of the future. We are confident that we will succeed beyond any past measure if we do not falter in our commitment to deliver to consumers anywhere in the world the highest-performance, smartest and cleanest vehicles and, consistent with this Administration's goals, the modem infrastructure needed to support them, While the MTE Notice Identifies a range o f uncertainties associated with this pivotal period of technology transition, we firmly believe that weakening fuel economy or greenhouse gas standards in reaction to short-term uncertainties would be self-defeating and wholly inconsistent with our shared goals o f strengthening U.S. competitiveness, growing jobs and protecting our current technological superiority. NCAT stands ready to work with you and the Administration, to find a path forward that addresses any short-term challenges while preserving, and Indeed accelerating, the transportation and energy transformation that consumers eagerly seek and that will help secure America's technology leadership for decades. We ask that you engage with NCAT, its members, and other stakeholders in a robust dialogue regarding how to ensure that these standards continue to reward innovation and preserve and strengthen stable growth o f advanced vehicle technologies. Sierra Club v. EPA 18cv3472 NDCA Attachments Prod 2 ED 002061 00181905-00001 NCAT is a coalition o f companies that supports electric vehicle (EV) and other advanced transportation technologies and related infrastructure, including business leaders engaged in energy supply, transmission and distribution; vehicle and component design and manufacturing; and charging infrastructure production and implementation, among other activities. Our members support government initiatives, including federal and state vehicle standards, that provide regulatory, financial, infrastructure and other support for emerging EV and other clean vehicle technologies to compete in the marketplace, NCAT also recognizes the critical role that California and other states play in adopting and implementing vehicle standards that support advanced technologies. Such state leadership has historically ensured that the United States remained on the cutting edge of technology development, and we see no reason to reconsider that approach at this key j uncture. If stakeholders work together, we firmly believe that state and federal interests can remain aligned to ensure ongoing regulatory certainty and stable, long-term signals to guide investment. NCAT's members are concerned by, and strongly disagree with, many o f the statements in EPA's MTE Notice regarding the availability, affordability, consumer acceptance and benefits o f EV technologies. EV and related technologies and infrastructure provide major economic and energy security benefits, and LbS, leadership in this space is critical to our economic health, global competitiveness and environmental quality. As detailed in our October 5, 2017 comments to EPA on its reconsideration o f the January 2017 Mid-Term Evaluation final determination, there have been substantial advances in EV technologies and corresponding decreases in costs since 2012. Sales of these vehicles are increasing significantly, demonstrating growing consumer demand. ti.S. and other manufacturers are scaling up investments and rapidly expanding their EV offerings across a range of vehicle types and price points. Range, performance, options and affordability are all improving rapidly, making EVs increasingly attractive to consumers. The simultaneous rapid development of autonomous vehicle technologies and on-demand transportation, both of which work synergistically with EV technologies, signal the beginning o f a major transformation in our transportation system. In recognition o f these trends, governments across the world are announcing policies to transition away from conventional vehicles and towards EVs, creating a race among manufacturers to capture the expanding global market for these vehicles. To win that race, the United States must establish and maintain leadership through robust long-term fuel economy and greenhouse gas standards at the federal level. When the current standards were adopted in 2012, it was clear that this Mid-Term Evaluation would find us where we are now - in the early stages o f a transition from predominant reliance on efficiency improvements in conventional vehicles to increasingly greater reliance on EVs. While it may he tempting to look to short-term signals, the federal greenhouse gas emissions and fuel economy programs are intended to take the longer view. When we do take that longer view, all signs clearly support our readiness to make this transition. Failure to recognize, embrace and support these trends presents serious risks that the United States will lose its role as a global leader in these technologies of the future. NCAT respectfully requests that you work closely with our members and other stakeholders in the period leading up to issuance o f a proposed rule for the MY 2022-25 standards. These issues are too important and the stakes are too high to rely exclusively on the notice-andcomment rulemaking process to reach outcomes that meet our shared objectives. A more iterative, Sierra Club v. EPA 18cv3472 NDCA ? Attachments Prod 2 ED 002061 00181905-00002 interactive and inclusive dialogue is needed. We stand ready to work with you and others to identify solutions that can address any near-term challenges while preserving the benefits o f the current standards and strengthening long-term growth o f EVs and other advanced technologies. Thank you for your consideration. Sincerely, Robert A, Wyman Devin O'Connor Latham & W atkins LLP Counsel to NCAT 555 1I th Street, NW Washington, DC 20004-1304 National Coalition for Advanced T ransportation (lifipsv/wwwJwacatmoin) Ampaire Atlantic City Electric Baltimore Gas & Electric Commonwealth Edison Company Deimarva Power Edison International EVgo Exelon Los Angeles Department of Water & Power Pacific Gas and Electric Company PECO PEPCO Portland General Electric Sacramento Municipal Utility District Tesla Workhorse Sierra Club v. EPA 18cv3472 NDCA 3 Attachments Prod 2 ED 002061 00181905-00003