June 12th, 2023

Re: Docket ID No. EERE-2021-VT-0033, Petroleum-Equivalent Fuel Economy Calculation;

Notice of proposed rulemaking; request for comment

These comments are submitted by the International Council on Clean Transportation (ICCT).
The ICCT is an independent nonprofit organization founded to provide unbiased research and
technical analysis to environmental regulators. Our mission is to improve the environmental
performance and energy efficiency of road, marine, and air transportation, in order to benefit
public health and mitigate climate change. Over the past decade, the ICCT has been highly
engaged with United States vehicle regulations, participating in expert working groups,
submitting public comments on regulations’ technical designs, and regularly publishing research
on vehicle regulations and standards.

We commend Department of Energy (DOE) on its continuing effort to lower fossil fuel
dependency and provide Department of Transportation’s Corporate Average Fuel Economy
program (CAFE) with technical support. The proposed Petroleum-Equivalent Fuel Economy
calculation provides updates to the June 2000 Final Rule for 10 CFR Part 474 that will more
accurately represent the petroleum-equivalent fuel economy of electric vehicles compared to
their conventional gasoline counterparts. We support the proposed calculation and recommends
its adoption, based on the three following points.

First, as DOE mentioned, the fuel content factor of 6.67 (or 1/0.15) leads to the overvaluation of
electric vehicles (EVs) in CAFE fleet compliance, allowing vehicle manufacturers to produce
relatively small number of EVs and less efficient internal combustion engine (ICE) vehicles. This
counters the need of the nation to conserve energy, in particular petroleum, as in the original
intent of the PEF value calculation. The removal of the fuel content factor and the consequent
reduction of the PEF value from 82,049 Wh/gal to 23,160 Wh/gal would represent more
accurately the fuel savings capability of EV technology and ensure that automakers continue to
produce EVs to achieve CAFE compliance.

Second, using the 2029 projected electricity generation mix for the MY 2027 to 2031 PEF
calculation under the scenario in which the United States achieves 95% renewable electricity
generation in 2050 better accounts for more recent policy changes. These policies, such as the
Inflation Reduction Act and the Infrastructure Investment and Jobs Act that provide significant
incentives for electric vehicles, will result in further investment and reliance on renewable
energy resources for electricity generation. The 2029 mix also represents the midpoint year of
the 2027 to 2031 CAFE compliance period.
Third, the updated PEF utilizes more recent data for energy production, transmission, and
distribution efficiencies, aligning with ICCT previous recommendation to update these values
based on our observations from the GREET model.

We would be glad to clarify or elaborate on any points made in the comments. DOE staff can
feel free to contact Anh Bui (a.bui@theicct.org) or Dr. Stephanie Searle
(stephanie@theicct.org).

Stephanie Searle, PhD

Acting Deputy Director
International Council on Clean Transportation