Comments on the CAFE petroleum equivalency factor (PEF; used for calculating electric vehicle fuel economy) were submitted to DOE on February 28. California and environmental NGOs are seeking to have the 6.67x electric vehicle fuel economy multiplier removed from the PEF. Our comments defend that multiplier and advocate that if any changes are made, they must be done in coordination with CAFE rulemaking so that the change can be accounted for when the standards are set.