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This regulation is needed, relevant and timely.  New Flyer is the
largest HD transit bus manufacturer in America and offers zero
emission transit buses for sale in trolley bus, battery electric
and fuel cell technology.  However, mass deployment has not yet
happened as all of these technologies have some road blocks to
broad deployment. Battery cost and range are a roadblock to broad
deployment of battery electric buses.  Fuel cell cost and
infrastructure cost are concerns for fuel cell buses.  Battery
dominant series drive electric buses with a small ICE
engine-generator for range extension are a realistic path to deploy
HD buses with zero-emission miles that would significantly reduce
emissions compared to solutions that are available today.  However.
today's HD engines are too big compared to the power required for
operation as a range extended generator. They are too heavy and
would not operate in their optimum power range for low emissions
and good fuel efficiency. There needs to be a reasonable path to
certify a small ICE engine as a range extender in a zero emission
battery bus. Please continue to develop this regulatory solution.