Submission Number: 8818
Submission ID: 61556
Submission UUID: 727c5dde-0b0b-4912-b39d-20258f917065

Created: Mon, 06/22/2026 - 10:07
Completed: Mon, 06/22/2026 - 10:07
Changed: Mon, 06/29/2026 - 10:28

Remote IP address: 18.68.29.84
Submitted by: Anonymous
Language: English

Is draft: No

Flagged: Yes


Submitted Comment
William Mancilla
Environmental scientist
EREVS

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.

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