Document rB0KxGXrEL9kakNk63j0zKKKJ

Natural Gas Vehicles (NGVs): The Common Sense Solution To Achieving Emissions Reduction Compliance At Low Cost and Low Risk NGVs ideally suited to help pickups, light duty trucks reach 2025 emissions goals o Light duty trucks face biggest compliance challenge, are critical to Big Three future o EVs not an option - batteries too expensive, too heavy for larger vehicles - NGVs are proven: Ford F150, Chevy Silverado, Dodge Ram Correcting NGV incentives is straightforward - and justified o No consideration of NGV technology in 2016 Technical Assessment Report despite availability of abundant domestic fuel and vehicle technology - Game-changing Renewable Natural Gas (RNG) delivers more than 85% lifecycle emission reductions o Restore pre-2015 "0.15 divisor" to harmonize EPA with statutory CAFE incentives, - Parity with EV incentives: just as EV incentives reflect renewable energy, restoring 0.15 divisor for NGVs would reflect emissions benefits of RNG (85%) - Would allow OEMs to easily meet 2025 targets for pickups o Parity: eliminate arbitrary driving range requirement imposed on bi-fuel NGVs - Plug-in hybrids have no requirements despite much shorter electric range o Provide NGV pickups with same emissions credits as "Strong Hybrids" - Eliminate minimum penetration for NGV pickup incentives: NGVs as 10% of all pickups not immediately feasible for alt fuel like natural gas Additional opportunity for smarter regulations: encourage retrofits o Retrofitting deployed vehicles with natural gas reduces emissions of existing fleet o Build on NGV retrofit successes in Oklahoma, greatly expand benefits of rules o Allow converters to receive credits based on vehicle's remaining useful life, sell/transfer to OEMs Restoring parity between NGVs and EVs, and between EPA and NHTSA, will provide automakers much-needed compliance flexibility for light trucks and pickups - and by making these changes effective immediately, we can start building this industry today. Sierra Club v. EPA 18cv3472 NDCA Tiers 8&9 ED 002061 00119249-00001