Comments on Weakening Fuel Efficiency Standards for Cars, SUVs and Light Trucks

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Comments on this rule change are CLOSED

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Comments on Docket number: EPA-HQ-OAR-2015-0827-6325
Considering the rigorous prior analyses done by and for EPA and NHTSA, I believe that any attempt to reconsider the standards is an irresponsible waste of taxpayer dollars, and a reversal of these determinations would be damaging to the environment as well as to both our national and economic security.

Background
In 2012, after extensive deliberation and technical analysis and public comment, NHTSA and EPA set greenhouse gas (GHG) pollution standards–which is directly correlated to fuel mileage–for cars and light trucks for model years (MY) 2017 to 2025. These agencies concluded that the costs of such regulation were far exceeded by the benefits, both in terms of decreasing GHG pollution and consumer savings in fuel costs. In 2016, due to the long period under review (2017-25), NHTSA and EPA initiated an additional analysis and public comment period, and again determined in that the standards proposed in 2012 were appropriate and feasible using technologies already available in the marketplace. In fact, analyses show that these aggressive targets could reduce CO2 emissions from 180g/km in 2012 to 93g/km by 2025.
A 2015 NAS report (Cost, Effectiveness and Deployment of Fuel Economy Technologies for Light-duty Vehicles) provided technical and cost support for the 2017 conclusion (1). In addition, a 2013 NAS report, Transitions to Alternative Vehicles and Fuels, concluded that an 80 percent reduction in petroleum consumption in the light-duty vehicle fleet was feasible by 2050 (2). This study examined highly efficient internal combustion vehicles, biofuels, electric, and hydrogen vehicles. Though such a dramatic reduction would not provide the same economic benefits to vehicle owners as the CAFE standards, the report shows that the decline in petroleum consumption can be continued in the long-term.

Regulatory Impact
Fuel efficiency standards that were brokered by the Obama administration and agreed to by key stakeholders created a stable regulatory and investment environment for automakers. Industry analysts have attributed the resilience of the American auto industry to the predictability of market demands and the regulatory landscape (1). We believe changing the agreed-upon standards now, and in contradiction to previous agreements and analyses, is reckless will create chaos in the automobile market, harming both consumers and manufacturers at a time when they face increasing domestic and foreign competition.

Economic Impact
The improvements in fuel economy that will result from the higher CAFE standards will more than pay for any increase in vehicle cost. In fact, even steeper increases in fuel economy might be justified. Furthermore, petroleum product prices have dropped significantly due in large part to reduced demand, which provides economic benefits throughout the US economy. Instead of the cost of crude oil soaring above $100/barrel, as was feared 20 years ago, it is half that.

Environmental Impact
Limiting GHG emissions from vehicles is one of the most important steps industrialized nations can take to tackle global warming. While some steps to combat climate change result in higher energy prices, in this case, consumers will directly benefit from increased fuel efficiency. The increasing number and intensity of severe weather events shows that we are already experiencing the early effects of climate change. Tackling climate change requires a concerted effort across all sectors, and increasing fuel efficiency standards is an essential step in this effort.

National Security Impact
Increasing the fuel efficiency of the US auto fleet contributes to our nation’s energy independence. In 2016, OPEC estimated that the US imported 1.1 billion barrels of oil. Previous EPA analyses suggest that the increased 2022-25 standards will save 1.2 billion barrels of oil, significantly reducing the need for foreign oil imports from unfriendly regimes. According to the Energy Information Administration, net imports of petroleum products has dropped from over 60 percent of consumption in 2005 to less than 25 percent, due in large part to improved fuel economy of vehicles (3). This reduction in global demand, together with the resulting drop in petroleum prices, has had significant national security benefits for the United States. Unfriendly oil-exporting nations, such as Iran, Russia, and Venezuela, have suffered steep decreases in national income and leverage, to the benefit of oil-importing nations that are friendly to our interests.

Public Support
A poll conducted for the Alliance of Automakers showed broad bipartisan support for increasing standards, with 69% of Democrats and 63% of Republicans saying that standards should be higher. This echoes previous polling by the Natural Resources Defence Council that showed 79% of respondents wanted the federal government to maintain increased fuel efficiency standards (5).
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Comments on Docket number: EPA-HQ-OAR-2015-0827-6325

I appreciate the opportunity to comment on the proposed changes to the fuel efficiency standards for cars and light trucks. Considering the rigorous prior analyses done by and for EPA and NHTSA, I believe that any attempt to reconsider the standards is an irresponsible waste of taxpayer dollars, and a reversal of these determinations would be damaging to the environment as well as to both our national and economic security.

Background
In 2012, after extensive deliberation and technical analysis, in part by the National Academy of Sciences (NAS) and public comment, NHTSA and EPA set greenhouse gas (GHG) pollution standards–which is directly correlated to fuel mileage–for cars and light trucks for model years (MY) 2017 to 2025. As part of this process, the agencies concluded that the costs of such regulation were far exceeded by the benefits, both in terms of decreasing GHG pollution and consumer savings in fuel costs over the lifetime of the vehicle. In 2016, due to the long period under review (2017-25), NHTSA and EPA initiated an additional analysis and public comment period, and again determined in January 2017 that the standards proposed in 2012 were appropriate and could be accommodated using technologies already available in the marketplace. In fact, analyses show that these aggressive targets could reduce CO2 emissions from 180g/kilometer in 2012 to 93g/kilometer by 2025, approximately halving emissions.

A 2015 NAS report (Cost, Effectiveness and Deployment of Fuel Economy Technologies for Light-duty Vehicles) provided technical and cost support for the 2017 conclusion (1). In addition, a 2013 NAS report, Transitions to Alternative Vehicles and Fuels, concluded that an 80 percent reduction in petroleum consumption in the light-duty vehicle fleet was feasible by 2050 (2). This study examined highly efficient internal combustion vehicles, biofuels, electric, and hydrogen vehicles. Though such a dramatic reduction would not provide the same economic benefits to vehicle owners as the CAFE standards, the report shows that the decline in petroleum consumption can be continued in the long-term.

Despite the clear and well-supported conclusions of these analyses and public comments, on August 10, 2017, EPA and NHTSA, opened a new comment period questioning whether the MY2021-25 standards are appropriate under the Clean Air Act.

Regulatory Impact
Fuel efficiency standards that were brokered by the Obama administration and agreed to by the major automakers, state of California, UAW, and other key stakeholders created a stable regulatory and investment environment for automakers. Industry analysts have attributed the resilience of the American auto industry since the financial crisis of 2008 to the predictability of market demands and the regulatory landscape (1). I believe changing the agreed-upon standards now, and in contradiction to previous agreements and analyses, is reckless and serves to create chaos in the automobile market. This will harm both consumers and manufacturers at a time when they face increasing domestic and foreign competition.

Economic Impact
The improvements in fuel economy that will result from the higher CAFE standards will more than pay for any increase in vehicle cost. In fact, even steeper increases in fuel economy might be justified. Furthermore, petroleum product prices have dropped significantly due in large part to reduced demand, which provides economic benefits throughout the US economy. Instead of the cost of crude oil soaring above $100/barrel, as was feared 20 years ago, it is half that.

Environmental Impact
Limiting GHG emissions from vehicles is one of the most important steps industrialized nations can take to tackle global warming. While some steps to combat climate change result in higher energy prices, in this case, consumers will directly benefit from increased fuel efficiency. The increasing number and intensity of severe weather events and wildfires shows that we are already experiencing the early effects of climate change. These events will become more frequent and damaging as the planet continues to warm. Tackling climate change requires a concerted effort across all sectors, and increasing fuel efficiency standards is an essential step in this effort.

National Security Impact
Increasing the fuel efficiency of the US auto fleet contributes to our nation’s energy independence. In 2016, OPEC estimated that the US imported 1.1 billion barrels of oil. Previous EPA analyses suggest that the increased 2022-25 standards will save 1.2 billion barrels of oil, significantly reducing the need for foreign oil imports from unstable, potentially hostile regimes. According to the Energy Information Administration, net imports of petroleum products has dropped from over 60 percent of consumption in 2005 to less than 25 percent, due in large part to improved fuel economy of vehicles (3). This reduction in global demand, together with the resulting drop in petroleum prices, has had significant national security benefits for the United States. Unfriendly oil-exporting nations, such as Iran, Russia, and Venezuela, have suffered steep decreases in national income and leverage, to the benefit of oil-importing nations that are friendly to our interests. In addition, the risk of a major disruption to global trade has been significantly reduced.
Public Support
In a 2017 presentation, Mitch Bainwol, president of the Alliance of Automobile Manufacturers, stated that consumers want tougher regulations on fuel efficiency and that their voices should be heard (4). A poll conducted for the Alliance showed broad bipartisan support for increasing standards, with 69 percent of Democrats and 63 percent of Republicans saying that standards should be higher. This echoes previous polling by the Natural Resources Defence Council that showed 79 percent of respondents wanted the federal government to maintain increased fuel efficiency standards (5).

1. https://www.nap.edu/catalog/21744/cost-effectiveness-and-deployment-of-fuel-economy-technologies-for-light-duty-vehicles
2. https://www.nap.edu/catalog/18264/transitions-to-alternative-vehicles-and-fuels
3. https://www.eia.gov/outlooks/aeo/pdf/0383(2017).pdf
4. http://www.nytimes.com/2012/09/05/business/august-us-car-sales.html?_r=2
5. https://www.nrdc.org/media/2016/160804-0