| Comment | Ford Motor Company (Ford) appreciates the opportunity to comment on
the California Air Resources Board's (CARB's) proposed
modifications to section 1961.1 "Greenhouse Gas Exhaust Emission
Standards and Test Procedures – 2009 and Subsequent Model Passenger
Cars, Light-Duty Trucks, and Medium-Duty Vehicles", dated January
7, 2010. Ford supports CARB's intent to permit compliance with
California Greenhouse Gas (GHG) standards based on a manufacturer's
ability to comply the Federal GHG Emissions Standards.
As previously recommended in the Ford September 15, 2009 and
December 9, 2009 comments on the CARB proposed amendments, Ford
offers the attached comments in support of the use of Federal CAFE
data to demonstrate compliance with the California GHG standards,
with suggested regulatory language changes that would implement our
comments. We also offer comments on some areas where the proposed
regulations present some timing concerns. Ford welcomes the
opportunity to discuss this information in detail with CARB staff.
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