Submitted Comment Name William Mancilla Affiliation Environmental scientist Subject EREVS Message EREVs should be placed in the emissions bin right above the ZEV0 proposed bin: in the ULEV50 as EREV generators have high efficiency of fuel conversion to energy compared to traditional combustion engines. Because the engine operates purely as a generator, automakers can tune it to run with high compression ratios and thermal efficiencies approaching 46% - 50% (similar to top-tier Formula 1 cars), compared to the 30% - 35% typical of conventional vehicles. File Upload (i.e., Attachments): N/A N/A
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