Final Rule Webinar

This is a text version of the Webinar: Final Rule on Electric Drive Vehicles and Infrastructure video.

COORDINATOR: Welcome and thank you for standing by. At this time, all participants are in a listen-only mode. Please hold your questions until the question-and-answer session. At that time, to ask a question, please press star 1 and record your name.

This webinar is being recorded. A recording of the webinar will be available on the EPAct Transportation Regulatory Activities website. That URL will be provided in a slide during the webinar and will be emailed to you afterward. If you have technical difficulties during the webinar, please press star 0 to speak to an operator. I'd now like to turn the call over your host, Ted Sears. Thank you, and you may begin.

TED SEARS: Okay, thank you, Tiffany. Welcome everyone to the webinar on the U.S. Department of Energy's final rule on electric drive vehicles and infrastructure that is part and parcel of U.S. DOE's Alternative Fuel Transportation Program, which is also referred to as the EPAct State and Alternative Fuel Provider Fleet Program.

Today, we are going to provide an overview of the vehicle and investment credit allocations under the new rule as well as some of the other program modifications that were set forth in the newly released rule.

My name is Ted Sears. I'm with the National Renewable Energy Laboratory, and I serve as a project leader and provide direct support to the Department of Energy for the EPAct State and Alternative Fuel Provider Fleet Program.

I'm joined today by Ira Dassa, and Ira and his team at New West Technologies provide direct support also on this program providing consistent support for the program—both its regulatory phone and email hotline. So glad to have Ira join me today. We are going to do a little bit of a tag team back and forth a few times. So hopefully we'll not confuse you but keep you in the loop.

So the new rule I think most people probably know was published March 21, of this year and establishes credit allocation levels under the standard compliance method of the alternative fuel transportation program for the acquisition of certain electric drive vehicles and investments and qualified alternative fuel infrastructure, qualified alternative fuel non-road equipment and emergent technologies as well.

The applicable vehicles include certain hybrid electrical vehicles, plug in electric drive vehicles, fuel cell electrical vehicles and medium or heavy duty electric vehicles as well as neighborhood electric vehicles. And the new credit allocations apply to vehicle acquisitions and investments that are made in model year 2014 and future model years.

The approach that DOE took in setting forth this rule or establishing the final rule essentially increases the number of the creditable actions within the program. And as a result expands the range of available compliance options and therefore is expected to facilitate compliance by a regulated entities or covered fleets. So DOE does intend that this rule will be very helpful for fleets.

In today's program or agenda it's fairly straightforward. We're going to begin with a little bit of a regulatory background. We don't want to get too deep into the weeds of the regulations but we do think it's important to recognize that this is a regulatory program whose provisions track and implement Congress' language set forth in statutes or laws. So we will provide a bit of background so that we're all on the same page as we proceed through our slides or presentation.

And as a result of this being a regulatory program specifically there are a couple of points we want to be sure to cover because they really are the lynch pin for a few key distinctions that the new rule either sets forth or clarifies particularly in the context of alternative fuel vehicles or AFVs. So a portion of our presentation will go on these distinctions regarding AFVs. We'll then provide an overview of the credit allocations under the new rule as they relate to vehicle acquisitions and investments.

And then also provide some information on other program modifications that essentially provides some streamlining to the program try to facilitate program function, provide clarity to newly covered fleets as well as consistency. And then of course provide a short summary and contact information as provided on the last slide.

Now we do expect to have plenty of time for questions. I think Tiffany mentioned that this is being recorded and we also expect to generate a Q&A document if we have sufficient number of questions.

So at this point I will turn it over to Ira to provide a little bit of program and regulatory background.

IRA DASSA: Well thank you Ted. As I think everybody is aware the program or as Ted indicated sometimes referred to as State and Alternative Fuel Provider Fleet Program sometimes referred the AFTP generally today you'll hear me just referring to as the program. The program itself stems from the Energy Policy Act of 1992 or what we sometimes refer to as EPAct 92.

This law that Congress passed has a goal of promoting alternative fuel use to the maximum step practicable and for state government and alternative fuel provider fleets it requires certain fleets those that are covered that meet the coverage criteria. These fleets are required to when they acquire new light duty vehicles every year a certain percentage have to be light duty alternative fuel vehicles or light duty AFVs.

At present the acquisition requirements for covered state government fleets is that 75% of all annual non-excluded light duty vehicle acquisitions have to be light duty AFVs and for alternative fuel provider fleets the percentage is 90%. And so 90% of an AFP or an Alternative Fuel Provider fleets new light duty vehicle acquisitions have to be light duty AFVs.

For alternative fuel provider fleets there is a requirement that stems from the statute that the alternative fuel vehicles that are required must use alternative fuel when the vehicle is operating in an area where the alternative fuel is in fact available. There are as Ted intimated earlier there are under the program two compliance methods that exist under the program. The first is what we generally refer to what we'll be talking for the most part about today standard compliance.

This is what was in the statute initially in EPAct initially and under this approach state fleets and alternative fuel provider fleets when they are covered you'll meet your requirement at any given year by either acquiring light duty AFVs as a result of Congress' action in 2005. Fleets also have the ability to earn up to 50% of their annual AFV acquisition requirements by purchasing and using in the fleet's medium and heavy duty vehicles biodiesel B20 or a higher blend.

And then the third primary means through which a fleet can achieve compliance under the standard compliance method is if necessary applying for and getting exemptions from DOE in the event that a particular alternative fuel vehicle in a particular vehicle type and if an AFV is not available or if alternative fuel for a particular AFV is not available.

As it's set out on the slide you see three bullets the state plan is also a compliance method that's available to state fleets but it's actually embedded in the standard compliance option but we've broken it out separately here. A state can submit a plan and the what having a state plan enables you to do is you can then have other fleets be a part of your plan and therefore the state can take credit or earn credit for the AFV acquisitions that those partner fleets make in any given year.

To date we have not had—DOE has not had any state that has submitted a plan under this particular aspect of standard compliance. And then the other compliance method that's available to all covered fleets under the program is what we refer to as alternative compliance or AC. Under alternative compliance fleets submit an alternative compliance application the key portion of which is known as a petroleum reduction plan and that plan sets forth the means by which the fleet will go about reducing its petroleum use in its motor vehicles.

And there's a certain petroleum reduction requirement that the fleet has to meet in any given year in order to be compliant with its requirements. And so alternative compliance is a little different from standard compliance in that it really is driven by alternative fuel use as opposed to alternative fuel vehicle acquisition.

So let's jump forward now to the rule about which we're speaking today generally referred to as the 133 final rule133 being the provision of the Energy Independence and Security Act of 2007 that directed the DOE issue the rule.

Congress included this provision in the 2007 energy law and as you can see it directed DOE to allocate AFV credit under the program in an amount to be determined by DOE for on the one had acquisition of certain electric drive vehicles the vehicle that Ted alluded to earlier, hybrid electric vehicles, plug in hybrid electric vehicles and several others Ted will be discussing those momentarily.

And then on the other hand for fleets that make investments in either qualified alternative fuel infrastructure, qualified alternative fuel non-road equipment or emerging technologies which are technologies that relate to any of the electric drive vehicles that we will be discussing today.

And so a little preliminary background under the program for a vehicle to be considered an alternative fuel vehicle it has to be either a dedicated vehicle or a dual fueled vehicle. A dedicated vehicle under the program is a vehicle that operates solely on one or more alternative fuels. That's actually one minor modification that DOE included in his rule making the definition of a dedicated vehicle has now been revised to make it possible for a particular vehicle to operate on one or more alternative fuels. Previously it was just on an alternative fuel.

And the second avenue for a vehicle to qualify as an AFV is for it to be considered a dual fueled vehicle. This is a vehicle that is capable of operating on either alternative—excuse me—on alternative fuel and also on gasoline or diesel either gasoline or diesel. A key aspect of the dual fueled vehicle definition with respect to plug in electric vehicles is that NHTSA has to—well NHTSA has what we refer to as minimum driving range criteria.

And for a dual fueled electrical automobile to be considered a dual fueled vehicle it has to be able to complete the EPA city and highway test cycles on electricity alone and NHTSA together with EPA makes that determination and DOE abides by that determination.

So if a vehicle a particular vehicle is either a dedicated vehicle or a dual fueled vehicle than under the program it always has and it will continue to receive one AFV credit assuming it's an excess or an early acquisition. If it's not one of those well then DOE will be treated as an AFV and will count it towards your AFV acquisition requirements in that particular year. Any vehicle that does not meet the definition of either a dedicated vehicle or a dual fueled vehicle then it is not considered an AFV under the program.


TED SEARS: Thank you Ira. So the key point there is whether as Ira noted is whether or not it's a dedicated vehicle or a dual fueled vehicle. As Ira mentioned the other—the types of vehicles it satisfies the state and alternative fuel provider fleet acquisition mandates are again going to be determined primarily by the definitions of alternative fuel and alternative fuel vehicle. So in the new rule DOE has assigned credits for those electric drive vehicles that are identified in the statute in EISA Section 133 that do not already qualify as alternative fuel vehicles as AFVs.

And it's done so based on yardstick of petroleum displacement. And AFV essentially displaces more petroleum that does a non-AFV or in the reverse. A non-AFV doesn't have a significant effect on the potential for petroleum replacement as compared to an AFV.

So the allocations that DOE has established in the new rule are really intended to ensure consistency with the overall approach that relevant provisions within EPAct 1992 which focuses on replacement of petroleum fuels through the use of replacement fuels to the maximum extent practicable.

As I address the various credit allocations in the next few slides it's going to be important to understand that if a given vehicle type already qualifies as an AFV it's already eligible for a credit or to be counted towards the fleet's AFV acquisition requirements. If it's not an AFV then the focus shifts to whether or not the specific vehicle type is among the electric drive vehicle set forth in EISA Section 133.

So the first group category classification of vehicles would be hybrid vehicles that are neither dedicated vehicles nor dual fueled vehicles. In other words they are not AFVs and these would be classified as potentially as hybrid vehicles and under the new rule DOE is allocating half a AFV credit for these vehicles. We think it may be easiest to have this decision tree or allocation tree we call it so I'll try to walk through this a little bit.

Tracking what Ira was saying that, you know, the first question is "Is the vehicle a dedicated vehicle and does it operate solely on alternative fuel?" You know, is it a battery electric vehicle? Could it be potentially a flex fuel hybrid electric vehicle or a CNG hybrid electric vehicle if it's one word to exist presently and not aware of one. If it's a dedicated vehicle then if the answer is yes then it is already an AFV. It already receives one credit under the existing program.

If it's not a dedicated vehicle the next question you might want to ask yourself is, is it a dual fueled vehicle? That is does it meet the NHTSA criteria that IRA spelled out? Again if the answer is yes if it's a dual fuel then it's already an AFV it already receives one credit under the existing program. So some examples of this might be for example a plug in hybrid electric vehicle that meets the NHTSA minimum driving range criteria and thus qualifies as a dual fuel of electrical automobile.

An example might be the Chevy Volt for example. Another example might be if the word exists right now a fuel cell electric vehicle that operates solely on alternative fuel or on all fuel and gasoline diesel as well. So is it dedicated? Is it dual fueled? And then if the answer is no to both of those then the question is well is it a hybrid vehicle? And so these are non-AFV hybrid vehicles such as a non-AFV hybrid electric vehicle. It's with the allocated one half of an AFV credit under the new rule.

A non-AFV plug in hybrid electric vehicle is also are allocated one-half of an AFV credit. Again this would be a vehicle that lacks a liquid or gaseous alternative fuel capable engine and also does not meet the NHTSA minimum driving range criteria.

At this point the only vehicle that we're aware of that does is not a dedicated vehicle and does not meet the NHTSA criteria and yet is a plug in hybrid would be the Toyota Prius plug in for model years 2012, 13 and 14. Because it did not complete both test cycles on electricity alone so it's not an AFV. Hence that plug in hybrid electric vehicle would get half the credit.

One other point to note and I know there have been some questions. As soon as the rule came out so when do for what model year would credits be available? All credits under EISA Section 133 including these for the vehicles apply for model year 2014 and forward. Okay so that's the hybrid vehicles.

The next group or classification would be neighborhood electric vehicles. For a number of reasons that are set forth in the preamble to the rule DOE is allocating one quarter of a credit for each neighborhood electric vehicle that is acquired. It should be noted that in essence, well not in essence but in fact studies are showing that neighborhood electric vehicles tend to travel a great fewer number of miles and a conventional fleet vehicle might cover.

And actually might be more irrelevant to provide an NEV than one-eighth of a credit. But DOE decides to provide one-quarter of a credit to neighborhood electric vehicles. Again as with the other vehicles that covered to this point credit is earned for a neighborhood electric vehicles that are acquired for model year 2014 and acquisitions and forward.

The next group of vehicles would be the medium and heavy duty electric vehicles. DOE needed to address these acquisitions of medium, heavy duty vehicles. You have to—one thing to remember is that this program is essentially a light duty vehicle program. The AFV acquisition requirement for fleet in any given year is based on the number of light duty vehicles it is acquiring of plans to acquire. And the requirement is achieved or met through the acquisition of light duty AFVs as well as some of the other means that Ira mentioned but principally through the acquisition of light duty AFVs.

With that said fleets may earn credits that they can bank for future use or for trading by acquiring medium duty and heavy duty alternative fuel vehicles and now with the promulgation of this new rule other non-AFV medium duty and heavy duty vehicles. So there of course a couple of different kinds of medium and heavy duty vehicles that fall into this category. A plug in hybrid electric vehicle or PHEV hybrid electric medium or heavy duty vehicle as well as the battery electric medium and heavy duty vehicle these are considered AFVs and they are already entitled to a credit under the program.

The reason for this is that NHTSA to which as Ira alluded to which DOE looks to for a vehicle classification determinations considers it medium duty and heavy duty PHEVs are dual fuel vehicles. And so for the purpose of consistency DOE is following NHTSA's declaration on PHEV and battery electric medium duty and heavy duty vehicles. And NHTSA also treats medium duty and heavy duty vehicles that operate on gasoline and E85 individual fueled vehicles and noting that.

So you may recall from a little earlier in this presentation that the question you might ask yourself in the context of light duty vehicles if you determine that the vehicle is not a dedicated vehicle as well as a dual fueled. Well the NHTSA minimum driving range requirements does not apply to medium or heavy-duty vehicles. And so it would not be possible for other types of hybrid medium duty or heavy-duty vehicles to be considered dual fueled and that's an AFV.

So only those that are specifically set forth there the battery electric vehicles and the PHEVs are AFVs and all the other hybrids are non-AFVs and would be as a hybrid allocated one half of a credit. One caveat to note and you may and hopefully are aware that it does apply to credits for these medium duty and heavy-duty vehicle acquisitions as has been the case in the program to this point.

A credit is only earned after the fleet meets its light duty AFV acquisition requirements. So regardless of whether that's met through light duty vehicle acquisitions of biodiesel purchased for use or exemptions or credit traits it doesn't matter. The—it that being the light duty vehicle AFV acquisition requirement simply must be met before any credits based on medium duty or heavy duty vehicle acquisitions can be earned in that.

Okay so that's the allocation under the rule for vehicles. The next category of credits that are allocated under the rule as related to investments and there are three groupings. The first is related to alternative fuel infrastructure. Now covered fleets may earn AFV credits or investments in alternative fuel infrastructure and this would include alternative fuel refueling stations. It would include charging or battery exchange stations including neighborhood electric vehicle charging stations.

And one thing that's important to note is that, you know, your typical or your average 120 volt electrical outlet and your basic wall outlet is excluded from the alternative fuel infrastructure for which you can earn credit. And so how are credits earned or allocated for this classification alternative fuel infrastructure? Well a fleet that invests $25,000 or more would be entitled to earn AFV credits. There is a maximum or cap on credits in each model year. The highest cap is a ten credit maximum for publicly accessible stations.

With $25,000 invested per credit so that would be for an expenditure up to $250,000. The emphasis here and the larger cap here is based on serving DOE's desire to serve as much of the general population as possible to be congruent with the programs overarching goals. So there's a 10 credit maximum for publicly accessible stations. There's a five credit maximum for private stations with $25,000 earned for credit. So for expenditure investment up to $125,000 you can earn as many as five credits. If of course you went over $125,000 you're still capped at that five credit maximum.

And there is an overall ten credit annual maximum so that would be one publicly accessible station or two private stations. Four things I'd like to note. The fleets may see credit for investments that they make in infrastructure that is owned or operated by another fleet or entity but not for infrastructure that is there's that another entity paid for. So the fleet has to have paid for it but it doesn't matter who owns that infrastructure.

The second point is that the investment can be for new infrastructure or for an expansion of existing infrastructure. The third point is that a fleet should be seeking credit in the model year that the infrastructure is actually put into operation. So if you've started building the infrastructure in this model year but did not put it into operation until model year 2015 then you would see credit in 2015.

And then the last point there is the fleets can earn credit for investments in model year 2014 and forward. I should note also that when a fleet is filing its annual report you would have to provide information on fuel type for the infrastructure, the location of the infrastructure, the date it was initially put into operation as well as you might imagine the amount of money that was spent.

Okay so that's alternative fuel infrastructure category. The next category for which fleets can earn credit is the alternative fuel non-road equipment category. So this includes mobile non-road equipment. This would be self-propelled equipment. For example a fork lift or a mobile farm or landscaping or construction equipment and riding lawn mower but would not include for example a walk behind mower or a generator that is mobile only to the extent that is it moved around on a trailer. So this would have to be mobile equipment.

Also important to note is that the non-road equipment must operate on alternative fuel. As with the infrastructure category credits are earned or allocated with the one AFV credit for every $25,000 that the covered fleet invest with maximums or caps as before specifically there's a five credit maximum per model year and this equates to an expenditure or investments of $125,000.

There are four points with this category I'd also like to note the investments need to happen or need to made by the requesting fleet and only for the fleet's own acquisitions so not for any acquisitions for other fleets it has to be for the fleets own use. A fleet should see credit in the model year that equipment is put into operation.

As with the other categories credits may be earned in model year 2014 and thereafter and then also there's as with the other categories certain information will need to be provided with annual report regarding as you might imagine the amount of money invested, the model year that the equipment was put into operation, what was acquired and then also a certification that it's being operated on on alternative fuel.

And then the last investment category is the emerging technology category. This would be for pre-production or pre commercial versions of the EISA Section 133 electric drive vehicle, the vehicle that we've been talking about. So how are credits allocated or earned for this category? Here's a little bit different and the difference is simply driven by the way Congress drafted the statutory language. A fleet again earns credits based on the amount of money invested or spent. A fleet earns two AFV credits for the first $50,000 invested. So there's no initial $25,000 for which a credit can be earned.

Once you've spent $50 you get two credits or you earn two credits. And then each of the next $25,000 increments also achieves an additional one AFV credit. There is a maximum or a cap as with the other categories of 5 credits from the model year, which of course equates to an expenditure of $125,000, meaning $25,000 increments. And for this category of investments or credits a fleet may find itself accessing or weighing its options as to what's the best approach.

For example and bear with me not to lose people by throwing some number sin here but for example if the covered fleet spent say $500,000 for ten pre-production electric drive alternative fuel vehicles kind of assuming that each one was $50,000 per vehicle. And the options might include in the annual report claiming ten credits for the ten vehicles. In other words ten alternative fuel vehicles and ten credits.

So not taking credit for the investment but rather for the vehicles acquired or it might be a better approach with a fleet to actually take five credits for investing in three of the vehicles. So each vehicle being $50,000, a total of $150,000 spent on these vehicles and five credits earned for those three. And then earning an additional seven credits for the remaining alternative fuel vehicles as vehicle acquisitions and there are the totals as well versus ten with the first approach.

So the key point here is that there may be more than one way to view the investment and vehicle acquisitions. But it's equally important to note that no double counting is allowed. So the qualifying pre-production vehicles for which investment credit is sought can be also counted as AFV acquisitions or allocated AFV credit. It's either one or the other.

Four points as with the other categories I have four points. The fleet should seek credit in the model year that the emerging technology has put into operation. Second as with the other categories the fleet earns credits for its investments in model year 2014 and forward. Third the requesting fleet must be the one that made the investment.

And fourth the fleet is going to need to provide detailed information as with the other categories to that, you know, DOE would be able to verify the purposes and the investment and the number of credits that the investment qualified for as well as, you know, when the technology was put into operation.

Okay so those are the credit investment credit categories and how the credits are earned. There are a few general concepts regarding credit allocations that I'd like to address. As you may have noted with the investment categories there are no fractional credits. There are all in whole another credits. But fleets may aggregate the monetary sums that are invested in a particular model year to reach an applicable investment credit threshold.

So the amount of money invested in alternative fuel infrastructure, alternative fuel non-road equipment and emerging technology can be aggregated such as the funds from multiple categories can be used to achieve the applicable threshold for the purpose of earning an AFV credit. So for example if a fleet invested $10,000 in a private alternative fuel station and $15,000 in non-road equipment those are obviously coming from two different categories. Neither category achieved a $25,000 level but you could aggregate these to $25,000 to earn that one AFV credit.

The only caveat to this is that you not be allowed to aggregate from a category for which your fleet has already been allocated the maximum number of credits for that category.

So for example if you already earn the maximum number of credits five for a non-road equipment category because perhaps you spent $135,000 and you earned five credits you can't take that extra $10,000 that is the $135,000 minus $125,000 you can't take that extra bid and aggregate it with money from one of the other categories because you've already achieved—you've already earned the maximum number from that non-road equipment category. So one small caveat there.

A second general concept to note regarding multi-year investments. So while the credit may only be sought for the model year in which, you know, your infrastructure, or your non-road vehicle or emerging technology began operating investments, you know, can obviously span more than one model year.

So if your fleet say spent—excuse me—spent say $12,500 in one model year and then an additional $12,500 in the following model year you would be entitled to one investment credit for the $25,000 total that you invested in that second model year assuming that that is the year in which the infrastructure began operating. There is a key here and that is that you see credit in the model year that the off field infrastructure or off field non-road equipment or emerging technology is put into operation.

So you wouldn't see that credit in the first year and you also would not see credit for prior year investments but rather the year in which it was put into operation.

And then the third general concept that I want to touch on is rounding which actually applies not just to investments but to all of the credits. As certainly you note the approach that DOE has set forth and the rule allocates less than one credit for acquisitions certain vehicle types and a whole of values for investments.

So when you're filing your annual report fleets have to of course total the credits that are earned including all the fractions and then round. And so you round to the nearest hole number. So as you might imagine fractions that are greater than or equal to .5 or one half should be rounded up and fractions less than .5 would be rounded down and this approach is consistent with how fleets round for purposes of calculating AFV acquisition requirements. And that covers the general concepts.

So I will Ira is up next I think.

IRA DASSA: Thank you Ted. So there as Ted had indicated at the outset of the presentation there are a number of other program modifications that DOE has included in the 133 final rule and over this next couple of slides I will describe those for you. The first general program modification that DOE made pertains to credit activity reporting and what we'll refer to as a credit activity report the acronym you see on the slide here CAR.

For fleets to get credit for any of their 133 vehicle acquisitions or for any of their 133 investments the three categories that Ted just mentioned you're going to have to provide certain information to DOE so that DOE can verify and allocate et cetera, et cetera. And all of this information is to be provided via the credit activity report. This will be—this is not to be a new requirement that DOE is establishing rather what DOE has done. The credit activity report is now incorporated into it. It's become a part of the annual report that you're all very familiar with and accustomed to filling out on an annual basis.

And so the certainly for fleets that file their annual reports online you shouldn't see any real change the information will come to DOE in the same manner and all the information that you need to provide in order to get credit for your electric drive vehicle acquisitions or your investments will get to DOE it will just be delineated a little differently either your credit activity report or otherwise.

And for those fleets that still used the annual report form the spreadsheet that is on the DOE website this too has been modified accordingly so that it clearly states that the credit activity report is now part of the annual report and all of the necessary information is set forth there and you will fill in your blanks and all of the information that DOE needs will get to DOE.

I should note DOE intends—we intend to hold at least one maybe more than one webinar over the near term perhaps next month remains to be the date is yet to be determined but we will let everybody know when we will be holding webinars to give you some more information about the updated annual reporting compliance tool and the updated forms. Of course as I think everybody is aware annual reports the annual reporting period doesn't start until the current model year ends which will not happen until August 31.

But we do intend to—DOE does intend to hold at least one or more webinars to discuss the new form or the—I should say the updated form and the credit activity portion of it which is directly related to the 133 final rule.

The second program modification that we'll discuss here has to do with the exemption process under standard compliance and in particular the timing that's associated with the exemption process. DOE has codified in the regulations language that brings the regulatory provisions in line with what's been existing practice under the program for some time now. And that is that you are expected to submit your exemption request after not prior to the submission of your fleet's annual report for any given model year.

And corresponding with that that would mean exemption requests are to be submitted no sooner than September 1 in any model year and no later than January 31 following the close of that model year. And so this would mean if a fleet files its annual report in a timely manner let's just assume for argument sake that the annual report is filed on the December 31 deadline than that particular fleet would have a full month to complete its exemption request and DOE believes that this is more than sufficient time for the fleet to complete the exemption requests and submit it.

DOE has also added language to the regulations to make it clear that if DOE is in need of additional information upon receipt of a fleet's exemption request then the fleet has to respond to DOE's request for additional information within a 30 day time frame.

And for any fleet that for whatever reason does not respond to that request for additional data in a timely manner then DOE will go ahead and process the exemption request as received but fleet should take note that this may mean that DOE doesn't have the information it needs to enable it to grant an exemption request in full. So it behooves fleets to comply with this timeframe and respond to DOE in a suitable manner such that DOE has all the information it needs to process the exemption request.

And then finally language has been added to the regulatory provisions both in the state fleet subpart and the alternative fuel provider fleets subpart of the Part 490 Regulations explaining that if a fleet's annual report shows that it has an acquisition deficiency for the model year then DOE asked that the fleet indicate in this report if it intends to submit an exemption request. This just gives DOE some advance notice as to whether an exemption is forthcoming or not.

One other key aspect or modification it's really not a modification but certainly worthy of note today. So as Ted pointed out earlier non-AFV hybrid electric vehicles, vehicles like the Ford Focus—excuse me—not the Focus the Ford Fusion hybrid or whether the Toyota Prius is hybrid that's been out on the road for some years now those vehicles are not AFVs but they will be getting half credit for fleets that acquire them in model year 2014 and thereafter.

DOE is now going to be taking a position similar to the position that it's taken with respect to biodiesel for some time now. And that is non-AFV hybrids are widely available across the country and the fuel for them gasoline also is available everywhere. So in a fleet's exemption request DOE is going to expect the fleet to now indicate in its exemption whether it met at least 50% of its annual acquisition requirements through the acquisition of such non-AFV hybrid vehicles.

And if the fleet did not then the fleet is expected to demonstrate to DOE that either non-AFV hybrids were not available in the vehicle type that the fleet needs and only if that demonstration is made will the fleet be able to get potentially the full number of exemptions it's seeking. If the fleet doesn't make that showing, doesn't make that demonstration then as DOE has done for some time now with biodiesel DOE will limit the number of exemptions that are granted based on the shortfall of non-hybrid AFV—excuse me—non-AFV hybrid acquisitions by that fleet and that model year.

And then finally DOE made a number of program modifications to the alternative compliance provisions in the Part 490 Regulations. In particular DOE eliminated the—prior to the 133 Final Rule there were two application deadlines and DOE has now made it more consistent throughout.

There is a single application deadline that now applies for every fleet that is interested in the alternative compliance option and that deadline will now be July 31 which for all intense and purposes is the deadline that virtually every fleet if not all fleets that have ever submitted an application under all internal compliance have ever abided by.

But it's now in the regulations that this is the only deadline you have to have your application in by July 31. Importantly the deadline for submitting your intent to apply for alternative compliance is unchanged that remains March 31 prior to the model year in question.

DOE has also clarified a number of the regulatory provisions in the AC Regulations that govern the rollover of excess petroleum reductions or the use of previously rolled over excess reductions in a particular model year. And then finally DOE has added a regulatory provision to make it clear that if a fleet's alternative compliance waiver is revoked by DOE and the fleet is then returned to standard compliance for where that particular model year then exemptions are not available to that fleet for that model year.

Ted you want to summarize now?

TED SEARS: Bring it back together here. So thanks Ira. Hopefully from these prior 19 or 20 prior slides you've seen that the final rule is in fact increases the number of creditable actions under the program and as a result expands the range of available compliance options for covered fleets. And then this expanded flexibility is expected to facilitate compliance recovered fleets under this regulatory program. I think the summary is fairly straightforward.

You know, we have this regulatory program that focuses on light duty vehicles and as Ira pointed out alternative fuel vehicles have earned one credit and they'll continue to earn one credit but that there is some vehicles that are not AFVs but address in the EISA Section 133 provision.

And so DOE is allocating credit to those vehicles that are non-AFVs that are hybrid electrical vehicles they earn a half a credit. Medium duty and heavy duty vehicles that are hybrids that are not AFVs earn half a credit as well. And neighborhood electric vehicles earn a quarter credit. In addition today we've reviewed three investment categories for which fleets may earn credits and the monetary thresholds were the maximums for each model year.

And we talked a little bit about the three components or aspects of credits in terms of aggregation for the investment expenditures, multi-year investments and then of course the rounding of fractional credits as well. And Ira went through some of the more important program modifications that are not associated with the vehicles or credit investment credits. And also Ira noted importantly the webinars expect to have at least two I think.

And the first one probably be in the May timeframe that will provide fleet POCs Points of Contact a good background on the updated annual reporting compliance tool which is also as he noted been revised and is intended to facilitate the whole compliance process and just really streamline things and make things easy for you. And along that I just do also want to note that we do have a very strong regulatory hotline both through the phone and email systems and so I would encourage you with questions both about this rule but also going forward to make use of that.

Compliance outreach is a very important part of the EPAct state and fuel complete program and we just want to make sure that you know that we're here for you if you have questions and provide compliances since we can.

This last or second to last slide has just set forth some of the credit allocations that we've talked about where you see HEV, PHEV, fuel cell electric vehicle and NEVs and the medium and heavy duty. Of course these are for non-AFV vehicles and then also you'll see the alternative fuel infrastructure, alternative fuel non-road equipment and emerging technology. The credit allotments are set forth there and any pertinent limitations are set forth in the right hand column. All things that we have covered.

And of course this will be available online and I think we may be able to provide it by email to fleet POCs as well.

And then the last slide is just simply a link to our—to one of the pages of our program website. There's a lot of good information on our program website, guidance documents and information explanations, frequently asked questions, a number of fact sheets and more plenty more that you can access by going through this link or more directly through the program home page. And of course Dana O'Hara is the US Department of Energy contact for the Regulatory Program and then there's my contact information and Ira's as well.

So certainly feel free to reach out to us. And I think even that I will leave it on this slide and then I think if Tiffany's there we can open it up to questions.

COORDINATOR: Thank you. We will now begin the Question and Answer Session. If you would like to ask a question please press Star 1 on your touchtone phone. Please unmute your phone and record your name clearly when prompted. Your name is required to introduce your question. To withdraw your question you may press Star 2. Once again if you would like to ask a question you may press Star 1 at this time. One moment for the first question.

TED SEARS: Thank you Tiffany.

COORDINATOR: The first question comes from Genevieve Cullen. Your line is open.

GENEVIEVE CULLEN: Oh hi. Thanks—first of all thanks for holding this it's actually it's been really full to just get a walkthrough of this sometimes quick dense rule. So I appreciate it. My question and forgive me if this is too specific but in the emerging technology section the metric is pre-commercial or pre-production and I wonder and at some points in discussion it talks about not widely available. I just wondered if there were more specific metrics of what would fall within emerging technology?

I thinking, you know, obviously if something is offered for sale then it's, you know, commercially available, you know by some definitions or if some cars are just offered in California but, you know they're widely available in California but not in say Nebraska. Maybe I'm over thinking but I just wondered if there were some details or maybe forthcoming details on what the metrics of emerging was?

TED SEARS: Right so very good question. The—there will be some information forthcoming on this because this is sort of as you've correctly identified it's an area where there could be some gray areas or at least questions as to—as you point out. For example in California there may be some vehicles available and not elsewhere. So it's not something that we might address to this point. So I know that's...


TED SEARS: …not an answer at this particular moment.

GENEVIEVE CULLEN: No actually it's helpful to know that nobody knows yet.

TED SEARS: Yes right. But certainly if it's something that is—again there's no specific answer yet but if it's something that is widely available or is available for sale generally then one would imagine that that would be and considered not pre-production.

GENEVIEVE CULLEN: Okay thank you.


COORDINATOR: The next question comes from Leonard Lincoln. Your line is open.

LEONARD LINCOLN: Okay yes I was not able to pull this up on the video. I was able to listen in. I didn't catch the website that I could go to actually review this later.

TED SEARS: I think I believe we're going to be sending it via email. So if you have logged in we will be able to send it to you. I think it may be easier than just the URL which is a long string.

LEONARD LINCOLN: Okay thank you...

TED SEARS: The WebEx but I've made a note here so I will make sure that that is sent out.

COORDINATOR: The next question comes from Ivan Baris. Your line is open.

IVAN BARIS: I'm assuming maybe that's Ivan Baris so that would be me. So Ivan Baris. I have a question. If I understand this appears to be model year 2014 and forward what consideration is being given to companies that have already made a sizeable investment in electric vehicles alternative fuel vehicles in years prior to 2014?

TED SEARS: Well the way that the DOE has directed things under the Administrative Procedures Act rules are and they only have their future affect and that goes along with the fact that, you know, determining whether or not a fleet has met its requirements in any given years is done in that particular model year. So for example one couldn't apply credits if there were even some sort of clause that would allow that couldn't apply credits or previously to come into compliance.

So but the bottom line is that credits may be earned for acquisitions made in 2014 and forward. So if you had acquired vehicles in model—in applicable, you know, hybrids for what you could earn half a credit if you had acquired them in model year 2013 or previously then you would not—credit would not be available for those.

IVAN BARIS: And what—so what if that fleet was already 98% alternative fuel? How would they meet the requirement to go forward because there really wouldn't be the capacity to add? Do you know what I mean?

TED SEARS: Yes. So well the way it works is essentially your requirement to acquire alternative fuel vehicles or credits towards compliance is driven by the number of vehicles that you are acquiring in a given year.


TED SEARS: Given model year. So for example if in this coming model year you were not acquiring any new light duty vehicles you have no requirement. It's driven by the number of vehicles that you're...

IVAN BARIS: Okay and is...

TED SEARS: ...require.

IVAN BARIS: a percentage?

TED SEARS: Yes it's a percentage. So I think one of the first slides notes that if you're a state fleet then it's 75% of your acquisitions would need to be of your light duty acquisitions would need to be alternative vehicle. So for example if you are planning to acquire 20 light duty vehicles in that given model year then 15% or 75% would need to be alternative fuel vehicles. If your utility or I'm sorry alternative fuel provider fleet like a utility then that requirement is 90% and your requirement would be 18% of the 20%.

But if you don't buy any or you're not planning to buy any and you don't buy any light duty vehicles then you have no requirement.

IVAN BARIS: Okay, all right. Thank you very much.

COORDINATOR: The next question comes from Tara Kelley.

TARA KELLEY: Hi this is Tara Kelley. I have two questions. One is a clarification on earning credits for investments and infrastructure and non-road equipment. You can earn those credits at any time. In other words you don't need to meet your light duty vehicle acquisition requirements before getting those credits correct?

TED SEARS: That's correct.

TARA KELLEY: And then my second question is you made mention to when you claim vehicles under this program you need to utilize the appropriate alternative fuel in those vehicles when the fuel is available. And my question centers around let's just pick E85 for example you have select fuel vehicles in your fleet. We may have E85 available at several public refueling stations within our service territory however our fleet is prohibited from refueling at public stations because we have our own fuel stations specifically for municipal and utility operations.

And so is that an adequate reasoning for why perhaps we have one E85 tank and it's not centrally located to all of our fleets. So there are some E85 flex fuel vehicles that cannot refuel with E85. Is that acceptable even though E85 might be available at a public station nearby?

TED SEARS: Ira, does this fall into your court?

IRA DASSA: It could. I'd be happy to handle it Ted. Can I ask Tara you're referring to in your case you would a state government fleet correct?

TARA KELLEY: An alternative fuel provider.

IRA DASSA: Okay all right, well I was just going to highlight again that state government fleets for and this stems from the statutory language that Congress adopted at EPAct 92 alternative fuel provider fleet yes are required to use alternative fuel and their AFVs when those vehicles are operating in an area where the fuel is available. That is not the case for state government fleets. So in your case if you're referring to an alternative fuel provider fleet the situation you're describing is for a lack of a better term I'll describe it as it's a little funky I suppose.

So you're saying you've got public stations available but your fleet is prohibited from accessing those public stations...

TARA KELLEY: Correct they...

IRA DASSA: ...and...

TARA KELLEY: ...are forced to refuel at one of our own refueling stations which not everyone has an E85 tank at it.

IRA DASSA: ...sure what I would suggest to you Tara is why don't you pose that question to us via the Regulatory Information Hotline and describe the circumstances as best you can. I'm saying that only because this is not a—your question is not something that grows out of the 133 final rule. It's—this would be more of a—this is a specific to an exemption request and not having to do with any of the provisions that DOE has just promulgated in the final rule.

So if you wouldn't mind pose the question or put the question into an email or if you want to call us on the Regulatory Information Hotline and then we'll get back to you after some discussion I would imagine.

TARA KELLEY: Thank you.


Coordinator: The next question comes from Magda Comeau.

MAGDA COMEAU: Magda Comeau, calling from Rutgers University in New Jersey. My question is how will we know if the hybrid meets the NHTSA criteria?

TED SEARS: Okay, so what the National Highway Traffic Safety Administration is -- or NHTSA -- has a website for which we will provide the link, is available and you'll be able to see what vehicles are posted.

But better yet, the labels that are posted on the vehicles will state that the vehicle is a dual-fueled vehicle or it's not a dual-fueled vehicle.

And of course as Ira was pointing out early on in the presentation, if it's a dedicated vehicle or a dual-fueled vehicle then it is an alternative fueled vehicle. If it does not say dual-fueled on there then it would not be considered an AFV.

IRA DASSA: Ted, can I interject something as well?

TED SEARS: Absolutely.

IRA DASSA: And Magda, it's really—your question, you were inquiring about hybrids and there's sort of a dividing line here.

If you're talking about a traditional hybrid electric vehicle or an HEV, something like the standard Toyota Prius or the Ford Fusion or any other hybrid electric that's out there, that's in a different category as opposed to plug-in hybrid electrics.

The plug-in hybrid electrics is really where DOE has to look to NHTSA and EPA to ascertain whether the vehicle completed the test cycles.

For a traditional hybrid electric and the ones that are out there on the road today, are vehicles that while they have an electric motor, they do not run on anything other than gasoline.

And so all hybrid electric vehicles of the traditional variety, again like the Prius, like the Ford Fusion, those vehicles are not AFV. The only way they could become AFVs in the future is if they happen to be equipped with an engine that runs on something other than, or in addition to gasoline.

So if there was an HEV out there that could run on E85 as well as gasoline, then it would be a dual-fueled vehicle. Or if you had a hybrid -- I think Ted alluded to this at the outset -- if there were a hybrid out there; there isn't one today -- but if there were a hybrid that were equipped with an engine that could run on CNG, then again it would be—that might actually be a dual-fueled or it might be a dedicated, depending upon the—how the vehicle is equipped.

But it's only for the plug-in hybrid electrics where DOE has to look to whether the vehicle met the NHTSA test minimum range criteria.

MAGDA COMEAU: Okay, then I think I'm still falling short. So the hybrid electric vehicles that are receiving one-half credit, do we need to check to see if those are meeting the criteria of NHTSA, or are we automatically to assume that the hybrid electrics that are—you know, that qualify for the half credit, they automatically will receive the half credit?

IRA DASSA: Again, if it's not of the—if it's not—if you're not talking about a plug-in hybrid then there are no criteria you have to look to. You can assume that you would qualify.

MAGDA COMEAU: Well how about the Leaf?

IRA DASSA: Well the Leaf would be considered a battery electric vehicle. That one is...

MAGDA COMEAU: Oh okay, so that gets the full credit?

IRA DASSA: Right, right. When I'm saying a hybrid I'm talking about the—again the traditional hybrids that are out there. There's no plug-in capability. It doesn't plug into a charging station or a wall socket. The only fuel is the gasoline that you put in the engine.

MAGDA COMEAU: Okay, thank you very much.


COORDINATOR: The next question comes from Steve Rosenstock.

STEVE ROSENSTOCK: Hello. I was wondering, could you go back to the previous slide—Slide 21 real quick. That's not my question, but okay, thank you very much.

TED SEARS: That's an easy question. I like that.

STEVE ROSENSTOCK: Well I'm going to ask another one or two questions here anyway. In terms of the infrastructure and some of the—for the last three categories about the amount invested, I was wondering about if an entity was using some sort of amortization schedule with their lease purchase or some sort of loan or some sort of capital investment where they're amortizing, they're putting the equipment in in year one.

Let's $50,000, they're putting it in in year one but they're actually paying for it over a series of let's say three or five or ten years. Would they still be able to count the $50,000 in year one?

TED SEARS: Obviously this is a question of first impression, so we would need to take a closer look, but it's a good question. I think the initial reaction would be that since we're looking at—you would claim it in the year in which it's put into operation. That would really be the driving factor.

And so—because in other words you couldn't claim in the later year after all the money has been invested.

So I think you would have—I believe the DOE would have to give you credit for the money that's noted up front. But again, that's a question for DOE, so we would have to look at that.

STEVE ROSENSTOCK: Yes, the reason I ask is I'm sure that some people will try to, you know, they typically, you know, it's a capital investment so it probably would be amortized.

So when you say, you know, $25,000 what does that mean? Is that the year of commitment or the year of the—you know, say the final payment? So I just figured I'd—yes, but that might be...

STEVE ROSENSTOCK: to get that clarification.

TED SEARS: Okay, so duly noted.

STEVE ROSENSTOCK: I have other questions but I'll just stop there because I'm sure other people have questions. Thank you very much. I really appreciate it.


COORDINATOR: The next question comes from Ms. Cosby.

SARAH COSBY: Hi, this is Sarah Cosby at Dominion. Can you hear me?

TED SEARS: Sure can.

SARAH COSBY: Okay, great. So I had a question about the plug-in hybrid electric vehicle versus the all-electric vehicle.

And you noted that the Toyota Prius plug-in for example, is not considered an AFV. But I'm thinking that the Chevy Volt or the Nissan Leaf would not be either because they don't meet that 200 mile when operating on the alternative fuel.

I'm wondering what's special about the Toyota Prius plug-in. Or would all of those vehicles that can't meet the 200 mile threshold operating on the alternative fuel, would all of those be considered dual-fueled and thus be given half credit?


IRA DASSA: Sure, Ted. The answer is—well the Leaf, the Volt, let me assure you they are in fact AFVs. And the reason for that is the 200 mile range requirement that you're referring to, that actually applies to liquid and gaseous alternative fuels. It does not apply in the case of electric automobiles or dual-fueled electric automobiles...


IRA DASSA: NHTSA refers to them.


IRA DASSA: For a dual-fueled electric, as NHTSA has always said, the dual-fueled electric vehicle, for it to be considered as such has to be able to run the EPA highway and city test cycles on electricity alone, albeit recharging is allowed in-between each test. So you can run one test cycle, you can recharge, and then you run the other test cycle.

If the vehicle completed both test cycles on the electricity alone then you are a dual-fueled electric automobile for NHTSA and CAFÉ purposes. The EPA conducts the test, NHTSA makes the determination. So therein lies the difference.

There is not a 200 mile requirement for some electric vehicles and a lower range requirement for others. It's the same for all of them and it's the EPA city and highway test cycles.

SARAH COSBY: I see. So you can have multiple charging events provided you can meet that 200 miles with those multiple charging events?

IRA DASSA: No, let me clarify still further. So throw out the 200 miles. It doesn't apply in the case of...


IRA DASSA: ...plug-in electric vehicles at all.

SARAH COSBY: I got it. Okay.

IRA DASSA: That requirement is only applicable to liquid or gaseous alternative fuels. So an E85 vehicle or a CNG vehicle or a propane vehicle, or any other liquid or gaseous alternative fuel.

But for plug-in vehicles, and it's—we're not talking about plug-ins that are dedicated vehicles. You're not talking about the Nissan Leaf, you're not talking the Ford Focus, but any other battery electric vehicle where electricity is the sole fuel.

It's only for the plug-in hybrids and then that's where the minimum range requirement comes in.

SARAH COSBY: And again, that 200 miles is only required for gaseous not for electric?

IRA DASSA: Correct. Correct. That is right.

SARAH COSBY: So what was special about the Toyota Prius plug-in, because I assume that could operate also I mean, just like the Leaf or the Volt?

IRA DASSA: Well it is similar to—it's different from the Leaf. It's gasoline fueled as well as being—as well as having electric motor. It's similar to the Volt. Both it and the Volt are what we call plug-in hybrid electrics but the difference is the battery size.

But all that matters for DOE purposes under the 133 Final Rule is the Prius plug-in did not complete the EPA city and highway test cycles on electricity alone.


IRA DASSA: And for that reason it doesn't qualify as an AFV. It will get a half credit but it does not qualify for a full credit under the program.

SARAH COSBY: Okay. And I had one other question and that is, I know under the definition of alternative fuel providers it's included I guess, any provider that owns, operates, leases, or otherwise controls 50 or more non-excluded light duty vehicles, at least 20 of which are capable of being centrally fueled and are primarily used in metropolitan municipal areas or consolidated MSA with a 1980 census population of 250,000 or more.

So my question related to that is does this mean that any fleet, regardless of whether it serves a state government or not, could there just be any private fleet that meets those criteria is considered an SFP or an alternative fuel provider? Or do they have to be serving a state government entity?

IRA DASSA: Ted you want to handle that or would you like...

TED SEARS: Sure. The program is focused on state agencies, state agency fleets. They could be state—a college or a state university, Department of Transportation; something like that. Or alternative fuel provider fleets which are typically, for the most part, in utilities you tend to think of them.

DOE, in a prior rule making had looked at private and local fleets and had determined—had made a determination that they would not be subject to this program.

And so the program is only focused on state agency fleets and the alternative fuel provider fleets.

SARAH COSBY: When you say utility, do you mean like municipal utilities and cooperatives, or do you also mean investor owned utilities that are shareholder owned and regulated but don't necessarily serve—only serve a municipality?

TED SEARS: No it would include those that you mentioned, municipalities and cooperatives could also be included.

SARAH COSBY: But it would not include investor owned utilities?

TED SEARS: No it would include investor owned utilities.

SARAH COSBY: It would?


SARAH COSBY: So an investor owned utility fleet would fall under this final rule?

TED SEARS: Yes, assuming that it meets the threshold requirements that you noted like the 50 light duty vehicles.

SARAH COSBY: Right. So it doesn't necessarily have to be an IOU that serves a state government?


SARAH COSBY: Okay, thank you.


COORDINATOR: Next question comes from Bob. Your line is open.

BOB: Hello?

TED SEARS: Yes, go ahead.

BOB: Is there going to be any fuel credit issued for alternative energy on the mounted equipment like the GM's product on Altec?

TED SEARS: I'm sorry, could you just clarify? Like the GM, is that what you said?

BOB: Like a GM's unit.

TED SEARS: If you're referring to the GM vehicle...

BOB: No, I was talking about an alternative energy use for mounted equipment like on a medium duty truck.

TED SEARS: Oh, mounted equipment; no. So for example if you had a—like a bucket truck?

BOB: Yes.

TED SEARS: Right. So there's no credit for the hybrid component of a bucket truck that's not related to the propulsion of the vehicle.

BOB: Okay, how about the Eden product that's in the medium duty?

TED SEARS: Well that would be the—again, if it's related to operating a bucket or ancillary equipment then the answer would be no.

I would just point out that fleets—covered fleets could earn credit towards compliance if they were operating under alternative compliance for the fuel savings that that equipment generates.

But under standard compliance there would be no AFV acquisition credit for those vehicles.

BOB: So we'd have to generate the fuel savings otherwise to get that credit?

TED SEARS: Right. So in terms of fuel savings the alternative—the program has two compliance options essentially—standard compliance and alternative compliance.

Fuel savings are addressed through alternative compliance. The new rule addresses compliance under standard compliance which is really based on vehicle acquisitions.

BOB: Thank you.

COORDINATOR: And once again to ask a question please press star 1. The next question comes from Bill Ising. Your line is open.

BILL ISING: Hello. My question regards some clarification on the alternative fuel non-road equipment. Does one credit per $25,000 invested, is that investment in infrastructure or in the purchase of non-road equipment?

TED SEARS: That would be for the purchase of non-road equipment as opposed to, I guess you're referring—when you said infrastructure, perhaps you're meaning alternative fuel like refueling infrastructure?

BILL ISING: Correct.

TED SEARS: So that would fall under the—there are three categories for which one can earn credit for their investments. One is alternative fuel infrastructure. A second would be the alternative fuel non-road equipment, and the third would be pre-production or pre-commercial emerging technology.

So it sounds like you were offering investments in two different categories, and that would be the non-road equipment and also alternative fuel infrastructure.

BILL ISING: So for example is purchase of electric powered forklifts; would that qualify for credits?

TED SEARS: Yes, those are non-road equipment and they're mobile equipment.

BILL ISING: How about propane powered?


BILL ISING: Thank you.

COORDINATOR: There are no further questions at this time.

TED SEARS: Okay. Well why don't we give people another minute and see if there's another question or two and then...

COORDINATOR: If you would like to ask a question press star 1.

IRA DASSA: Ted while people are gathering their thoughts to ascertain whether they have any final questions, I thought it might be worthwhile just to point out to everyone or just to reiterate what Ted had said earlier.

If you have any questions about particular vehicles, don't hesitate. Send us an email to the Regulatory Information Hotline or call us on the phone and we would be happy to entertain that question and get back to you with a firm answer.

Whether it's specific to a particular plug-in hybrid or any other vehicle and you're uncertain as to whether it's AFV or not, we would be happy to get back to you with an answer.

You just have to send us an email or get to us on the information line and we'll be able to get back to you.

TED SEARS: All right, thanks Ira. Okay, well if there are no further questions then I'd like to say thank you to everyone for taking the time to listen in. And this will be archived I know, so if you want to come back and hear it again, or certainly reach out as Ira suggested.

So, thank you everybody. Thank you, Ira.

COORDINATOR: This concludes today's conference. All parties may disconnect at this time.