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TransPower is encouraged, and future generations well served we
believe, by the inclusion of language and technical considerations
embodied in the section of the proposed rules titled "Alternate
Emission Standards for Heavy-Duty Hybrids with at Least 35 Miles
AER".This variation of HD propulsion will be much aided on its path
to commercialization by a consistent and forward-thinking
regulation as drafted here. Range-extension of a battery dominant
heavy duty hybrid vehicle using a lighter duty engine, in a serial
generation mode, may help accelerate early adoption of cleaner
trucks by reducing up-front dependence on initially scarce charging
infrastructure while at the same time providing deployment
flexibility for early adopters. We ask for continuing flexibility
of thought as such solutions are brought to market and begin to
prove their merits.