In this 2004 letter to the NHTSA, Amory Lovins challenges the agency’s proposed policy about the Automobile Fuel Economy Standards Program. He argues that NHTSA’s policy should be performance-based, not prescriptive; that the standards should be neutral as to vehicle mass, or favor the down-sized vehicles; if fuel-economy choices are desired to be decoupled from vehicle-size-class choices, then this is done by normalizing to size; and the standards should be technology-neutral or technology-forcing.