Vehicle Standards Rollback Proposal

Public Comment Period Extended Through October 26, 2018

Public Hearings Set for September 24-25-26

NHTSA and EPA will jointly hold three public hearings on the proposal -- on September 24 in Fresno, California; on September 25 in Dearborn, Michigan; and on September 26 in Pittsburgh, Pennsylvania. See EPA's web page and hearing notice for additional information on the hearings and how to participate.   If you would like to present oral testimony at one of these public hearings, contact the agency staff listed in the hearing notice at least 10 days before the hearing.  The Save EPA public hearing tips page can help you make the most of your testimony.

Read the proposal @ https://www.regulations.gov/document?D=EPA-HQ-OAR-2018-0283-0756

Submit your comment to EPA @ https://www.regulations.gov/comment?D=EPA-HQ-OAR-2018-0283-0756

Submit your comment to NHTSA here

Docket information https://www.regulations.gov/searchResults?rpp=25&po=0&s=EPA-HQ-OAR-2018-0283&fp=true&ns=true

Docket ID #: EPA-HQ-OAR-2018-0283

What’s at Risk, Talking Points, and What You Can Do

The Trump Administration is proposing to weaken critically important standards for climate pollution and fuel economy from new cars, SUVs and light trucks.  These vehicles account for about 20 percent of climate pollution emitted in the United States, and emissions from the transportation sector as a whole now exceed those from electricity production.1  In addition to combatting climate change, these standards save drivers money at the gas pump and promote the nation's energy independence.

EPA FINAL RULE (BEFORE PROPOSED ROLLBACK)

In 2012, EPA set climate pollution standards for cars, SUVs and light trucks for model years (MY) 2017 to 2025, in tandem with corporate average fuel economy (or “CAFE”) standards issued by the National Highway Traffic Safety Administration (NHTSA).2 These greenhouse gas (GHG) standards require automakers to achieve average real-world fuel economy for cars and light trucks of about 36 mpg in 2025, or an improvement of about 1 mpg per year.  EPA and NHTSA set the standards after conducting a comprehensive and extensive technical analysis.  That analysis showed that automakers could build cars and light trucks that emit much less GHG pollution, largely by increasing the use of technologies that were already in use or were getting ready to go on the market.

EPA also found that automakers could achieve these standards at reasonable cost, and that fuel savings over the life of the vehicles would more than make up for the increase in vehicle cost.  To date, most manufacturers have slightly bettered (i.e. surpassed) the standards, at a time of record-setting vehicle sales.

Because of the long time-frame of the MY2017-2025 standards, EPA agreed to conduct a mid-term evaluation of the 2022-2025 standards to determine whether they continued to be appropriate.  EPA conducted a comprehensive, updated technical analysis, and based on that analysis, proposed in November 2016 that the MY2022-2025 standards were still appropriate.   After considering public comments, EPA determined in January 2017 that the standards continue to be technically feasible at reasonable cost.3  According to EPA’s analysis, the standards can be achieved by relying mostly on the application of technologies already in commercial production, without the need for extensive use of hybrids or all-electric vehicles. The projected average per-vehicle costs remain reasonable and are in fact lower than EPA projected in 2012.  The MY2022-2025 standards would continue to achieve significant greenhouse gas and oil reductions, providing significant benefits to consumers and to the public in reduced fuel costs and reduced climate pollution.  The net benefits of these standards far exceed the costs of the program, the review confirmed.

TRUMP ADMINISTRATION ROLLBACK PROPOSAL

Now-departed EPA Administrator Scott Pruitt took an initial step toward weakening the climate pollution standards on April 2, 2018.  Reversing EPA's January 2017 finding, Pruitt signed a new determination that the existing model year 2022-2025 greenhouse gas standards for cars, SUVs and light trucks should be revised.  Pruitt concluded that the standards "may be too stringent."  

In a second step, the Trump Administration August 2 announced a proposed rule to weaken the greenhouse gas (GHG) emissions standards and fuel economy standards.   Rather than tightening standards over time like the existing rule, the proposal would freeze standards at model year 2020 levels through model year 2026.  The effect would be to would roll back stronger vehicle standards that are already on the books -- EPA's GHG emissions standards for 2021-2025 and NHTSA's fuel economy standards for 2021.  The Trump Administration bases the proposed rollback on a new economic analysis purporting to show that the rollback would reduce projected traffic fatalities and be good for the country's overall welfare.  The new analysis contradicts the earlier economic analyses of the existing standards and, as detailed below, has been disavowed by EPA's career technical experts.  The Trump Administration also suggests that the existing standards would do little to reduce climate change.

In addition to rolling back existing standards, the proposal would withdraw a 2013 EPA waiver that allows California to have stronger vehicle emissions standards than the federal government under three state programs -- the Advanced Clean Car program, Zero Emissions Vehicle mandate, and GHG emission standards for 2021-2025.  Federal law requires EPA to grant California waivers if certain criteria are met, in recognition of California's longstanding need for and leadership in reducing vehicle pollution.  EPA has granted California waivers many times over the last 40 years.  Federal law also gives other states the ability to adopt California's vehicle standards, and many states have done so.  If EPA withdraws California's waiver for greenhouse gas standards and two other programs, other states will no longer be able to adopt them.  

HOW TO COMMENT

The proposal notice in the August 24 Federal Register indicates that EPA will accept public comments until 11:59 PM Eastern Time on October 23, 2018.  Docket information and a link for submitting comments are available at https://www.regulations.gov/searchResults?rpp=25&po=0&s=EPA-HQ-OAR-2018-0283&fp=true&ns=true.  Comments can be submitted both NHTSA and EPA; comments to NHTSA should be submitted here.

If you wish to submit comments by mail, fax, or other means, see the full EPA public comment policy at https://www.epa.gov/dockets/commenting-epa-dockets.  This web page also provides information about CBI or multimedia submissions, and general guidance on making effective comments.  Comments on this proposal must be identified by the following Docket ID:  EPA-HQ-OAR-2018-0283.

TIPS ON WHAT TO SAY

First, explain why you’re commenting on this notice – why the vehicle standards matter to you.  For example, if you live in an area prone to flooding, wildfire, or drought, explain that combatting climate change is vitally important to you.  Or if you don't like spending a lot of money on gas, explain that you want to drive a vehicle that doesn't cost you so much at the pump. 

If you have relevant expertise, say so. You don’t have to be an expert to make a valid and valuable comment, but if you do have expertise, share your knowledge.

If you have information relevant to the rule (for example, news articles or anecdotal information about how climate change is affecting or is expected to affect your community, or how you have responded to advertising which uses improved fuel economy as a selling point) include that information and highlight it.

Be constructive and civil.  Don’t write a lot if less will do.

SOME SUGGESTED TALKING POINTS

(For additional critiques of the Trump rollback proposal, please use the links below to information and analysis provided by several environmental organizations)

Strong action on climate change is urgently needed now. 

Carbon dioxide pollution and other greenhouse gases (GHGs) are the primary cause of recent climate change, threatening the lives, health, and well-being of my family, other Americans, and people around the globe.

We need to cut emissions now.  Once emitted, carbon dioxide pollution stays in the atmosphere for tens of years to thousands of years, harming us today and for many generations to come.  The National Research Council of the National Academies has warned, “The warming induced by added carbon dioxide is expected to be nearly irreversible for at least 1,000 years.”4

Climate change fueled by GHGs has wide-ranging, life-changing impacts in the U.S. and worldwide.  These impacts are already being felt in different parts of the country and will get worse over time.  My family is already facing some of these impacts.

More frequent and intense heat waves and record high temperatures that lead to more heat-related illnesses and deaths, especially among the poor and elderly

More frequent and intense droughts, wild fires, damaging storms, and floods that cause deaths and injuries as well as property and infrastructure damage

Northward migration of tropical diseases; increased health problems from smog pollution; and increased production of allergens and the respiratory problems they cause

Changes to the oceans that kill coral, fish, and mammals; changes in the ranges of plants and animals, or their outright extinction; damage to crops and fisheries; and potential increases in world hunger and other destabilizing changes

Possible rapid changes in climate that could cause even more abrupt and severe impacts for people and ecosystems  [For more information including scientific sources, click here.]

Climate change affects not only me and my family.  Sadly, it disproportionately threatens the health and welfare of vulnerable people in the U.S. and around the world, including children, the elderly, the poor, and  native peoples.  

Climate change threatens to impose terrible costs.  The National Oceanic and Atmospheric Administration reports that between 1980 and October 6, 2017, extreme weather disasters cost $1.3 trillion in inflation-adjusted damage and resulted in 9,905 deaths, and that's not counting Hurricanes Harvey, Irma, and Maria.5  Our nation's climate scientists warn that climate change already has exacerbated extreme weather and can be expected to have even greater effects in the future.5  Climate change is also a driver of the increasing number and severity of wildfires in the U.S.7  More than two million acres had burned in 111 large fires in 12 states by mid-August 2018.8

We need stronger standards, not weaker ones.

This proposal dangerously takes us in the wrong direction.  We need to be waging war on climate pollution, not rolling back achievable GHG and fuel economy standards for cars, SUVs and light trucks, which account for a large portion of US climate pollution.  

Rather than keeping the existing GHG standards that tighten gradually each year, the Trump Administration's preferred option in the proposal would freeze standards at model year 2020 levels through model year 2026.  Freezing standards would increase GHG emissions by nearly 900 million metric tons over the lifetimes of the vehicles sold in those years.9  We can't afford to allow GHG emissions to increase when they can be avoided by building vehicles using already available technology.

Documents in the rulemaking docket show that EPA experts strongly objected to key aspects of the analysis justifying the proposed weakening -- especially the modeling assumptions that DOT used to claim increased traffic accident fatalities from cleaner cars. “EPA’s technical issues have not been addressed, and the analysis performed … does not represent what EPA considers to be the best, or the most up-to-date, information available,” an EPA expert wrote in a critique less than two months before the proposal was released.  In the end, EPA's experts considered DOT's analysis so indefensible that they asked EPA's logo and name be taken off the document.  Their request was not granted.10

If increased traffic fatalities were a real concern, DOT has the authority to require automakers to build less polluting, more fuel efficient cars in a way that also keeps them safe.  There is no necessary trade-off between cleaner cars and safer cars.   

The Trump Administration's own analysis indicates that its rollback of GHG/fuel efficiency standards would increase daily oil consumption by 2-3% -- an increase of a half million barrels per day.11  In other words, drivers would be buying more gas AND facing more climate pollution and impacts.  Only oil companies would come out ahead.

The Trump Administration's time-worn argument that stronger standards won't accomplish much12 ignores the basic facts of climate change and what it will take to combat it. 

GHGs are emitted by many activities in many countries, and the build-up of GHGs over time will determine how severe climate change will be. 

Alone, no single measure like reducing U.S. vehicle emissions will solve the problem.  As the Supreme Court recognized in Massachusetts v. EPA, the case leading to the adoption of EPA's vehicle GHG standards, reducing U.S. vehicle emissions will reduce the severity of climate change to some extent.  But to achieve the reductions needed to stop the build-up of GHGs, many countries must cut emissions from many sources. 

The U.S. is the world's largest cumulative contributor (1850-2011) to the build-up of GHGs in the atmosphere and the second largest emitting country on an annual basis.13  The transportation sector and fossil-fuel-fired power plants are the two largest U.S. sources of greenhouse gas emissions.  If the U.S. fails to reduce emissions from its largest sources, there is little reason to believe that other countries will do their share, either.  Without a major reduction in global emissions, scientists warn, the result will be dangerous levels of climate change.

It is irresponsible and even nihilistic for the Trump Administration to fail to do what can be done because it won't, on its own, be enough.  That's just throwing in the towel when the lives and well-being of Americans and people around the world are at stake.  It is critical to preserve the existing vehicle GHG standards and reduce emissions from the largest U.S. sources of GHGs over time.  

The Existing Standards Should Not Be Rolled Back.

  • EPA’s existing GHG standards for vehicles are a critical component of the nation's effort to address climate change.  The Department of Energy’s analysis of the sources of GHG pollution in the United States shows that the transportation sector is becoming the largest source of emissions.  The auto industry must do its part to control climate pollution.
  • EPA's existing vehicle GHG standards are a good deal for America.  They will save billions of gallons of gasoline and billions of dollars in fuel costs, and avoid billions of tons of climate pollution.  The benefits of the rule far outweigh the costs to society, according to extensive EPA and DOT analyses under the previous administration.
  • The existing standards will help make the U.S. more energy independent.  The amount of oil that the 2022-2025 standards are estimated to save exceeds the total amount of oil imported from OPEC countries in 2016.  (Sources of information: Energy Information Agency website for OPEC import figures— about 1.1 billion barrels of OPEC oil imported in 2016.  EPA Proposed Determination table ES-3 – about 1.2 billion barrels of oil saved as a result of 2022-2025 standards).  Although the Trump Administration's supporting analysis notes that net imports have dropped and says the U.S. is projected to become a net exporter of petroleum and petroleum products by 203014, we are not there yet -- and this proposal cuts the wrong way. 
  • The existing standards save consumers money and pay for themselves.   In about 5 years, a vehicle owner driving 12,000 miles a year will save enough money on gas to cover the increased cost of the vehicle.  After that, money saved on gas is money in the consumer’s pocket.  If a vehicle is financed using the usual five-year loan, the cost of the loan attributable to increased vehicle price is more than offset each month by the fuel savings.  These calculations assume the price of gasoline stays under $3 a gallon until 2025 – a very conservative assumption.  Higher gas prices would mean a quicker payback period or even more of an offset if the vehicle is financed.  If gas prices edge back to where they were a few years ago (approaching $4 a gallon), the payback period would be 3 years.  If the Trump administration weakens these standards, they will be taking money out of Americans' pockets to buy more gasoline and giving it to oil companies.
  • The auto industry can achieve the existing standards.  The industry can rely almost exclusively on improvements to internal combustion engines – what’s been powering most cars, SUVs and light trucks for years.  They don’t require auto makers to produce lots of hybrids or electric vehicles.  In fact, the standards are based on control technologies that are already in use on some or almost all vehicles.  The main impact of the standards will be pushing even wider use of these existing technologies so that more cars, SUVs and light trucks benefit from them.
  • The existing standards don’t force manufacturers to make vehicles smaller or build vehicles of any particular type.  Rather, each manufacturer’s standard is based on the kinds and numbers of vehicles it produces.
  • The existing GHG standards that apply to model year 2012-2016 cars, SUVs, and light trucks are already resulting in very substantial pollution reductions, while automakers in recent years have had their best sales years ever.   The years 2015 through 2017 were three of the highest sales years ever for the auto industry.15  This shows that cleaner, more efficient vehicles and higher vehicle sales can go hand in hand.  Automakers are using better fuel economy as a selling point -- as shown, for example, by advertising for Ford’s Eco Boost and Mazda’s SkyActiv technology.

California's waiver should not be revoked.

  • It's bad enough that the Trump Administration wants to play ostrich when it comes to climate change.  It is worse still that the Administration also wants to take away California's long-standing ability to reduce vehicle pollution to protect its residents and environment.  California is already experiencing catastrophic wildfires, droughts, and mudslides, all made worse by the climate change that has already occurred.  California continues to meet the legal requirements for setting its own standards.  It should be allowed to do so.  

For additional critiques of the Trump Administration proposal and its preliminary economic analysis, see the following:

Chester France, consultant for Environmental Defense Fund and former senior executive at EPA who led development of vehicle standards, "Administration Cooks the Books to Justify Rollback of the Clean Car Standards," August 7, 2018.

Natural Resources Defense Council, expert blog by Luke Tonachel, "Trump Cars Rollback Unjustified, Unprecedented and Dangerous," August 2, 2018.

Union of Concerned Scientists, "8 Ridiculous Things in the Trump Rollback of Clean Car Standards (and 1 Thing They Get Right)," by Dave Cooke, senior vehicles analyst, August 2, 2018.

Union of Concerned Scientists, "Auto Standards Rollback: Oil Companies Win, Everyone Else Loses," by Don Anair research and deputy director, clean vehicles, July 27, 2018.

There Is More That We Can Do

The upcoming November elections give us a potent opportunity to let our elected leaders know that public protections are important to us and how we vote.  Submitting comments to EPA is a good first step.  Please consider also writing to your members of Congress (your representative in the House of Representatives and your two senators).  Many of them up for reelection.

If you submit comments to EPA, you can let your members of Congress and other elected officials know what you think by sending them a copy of your comments.  A template for comments to members of Congress is on page 23 of Save EPA’s “A Practical Guide for Resisting the Trump De-Regulatory Agenda,” which is available to read or download at the following link: http://saveepaalums.info/Resistance+Guide.  The following links help you send your comments to your members:

Countable lets you identify your members of Congress based on your address and then send a message to all three members at once. Its link is https://www.countable.us/.

If you prefer to write your members of Congress separately, you can go to https://whoismyrepresentative.com/orhttps://www.usa.gov/elected-officials/ to find your members' email contact forms or snail mail addresses.

Also consider letting your state and local officials know that you are concerned about this issue by writing or calling them or speaking at town hall meetings.  In the absence of federal leadership, it is vitally important that states and local governments fill the void.

Other ways of raising the public and political profile of this rollback include:

Getting involved with local activists who are encouraging federal, state or local action.

Writing letters to the editor and even op-eds in your local papers.  Letters to the editor should be fairly brief.

Organizing or participating in campaigns to make phone calls or write letters to members of Congress. Some campaigns ask participants to make phone calls to radio stations during call-in days, or take other actions to spread the word.

Spreading the word via social media.  Tag your elected officials so they know how you feel.

Joining or organizing demonstrations.

Talking to your friends, colleagues and neighbors and encouraging them to comment and otherwise join in this effort.

VOTING!

 LINKS FOR MORE INFORMATION

For more information on the Pruitt decision to weaken the standards, see these hyperlinked stories in The New York Times and The Washington Post. 

For more information on the joint proposal for weaker standards by EPA and the National Highway Traffic Safety Administration, see these hyperlinked stories in the The New York Times and The Washington Post.

About EPA's National Vehicle and Fuel Emissions Laboratory in Ann Arbor, Michigan.

EPA/NHTSA joint notice, “Request for Comment on Reconsideration of the Final Determination of the Mid-term Evaluation of Greenhouse Gas Emissions Standards for Model Year 2022-2025 Light-duty Vehicles; Request for Comment on Model Year 2021 Greenhouse Gas Emissions Standards,” signed August 10, 2017.  https://www.epa.gov/sites/production/files/2017-08/documents/ld-ghg-mte-request-comment-reconsider-frn-2017-08-10.pdf

Natural Resources Defense Council web page on clean car standards: https://www.nrdc.org/experts/luke-tonachel/2025-clean-car-standards-are-achievable-study-shows

Union of Concerned Scientists web page on clean vehicles: http://www.ucsusa.org/clean-vehicles#.WY31J63MyCQ

EPA web page on midterm evaluation of standards: https://www.epa.gov/regulations-emissions-vehicles-and-engines/midterm-evaluation-light-duty-vehicle-greenhouse-gas

Time Magazine op-ed by Margo Oge, former director of EPA Office of Transportation and Air Quality, “Why the Trump Administration's Latest Auto Industry Move Will Fail,” August 21, 2017  http://time.com/4906656/donald-trump-auto-industy-pollution/

EPA notice announcing September 6, 2017, public hearing: Public Hearing for Reconsideration of the Final Determination of the Mid-term Evaluation of Greenhouse Gas Emissions Standards for Model Year 2022-2025 Light-duty Vehicles (PDF)

_____________________________

ENDNOTES

1 EPA web page, "Sources of Greenhouse Gas Emissions," 2016 data.  https://www.epa.gov/ghgemissions/sources-greenhouse-gas-emissions

2 EPA Federal Register notice, “2017 And Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions and Corporate Average Fuel Economy Standards,” 77 FR 62624 (October 15, 2012).   See https://www.gpo.gov/fdsys/granule/FR-2012-10-15/2012-21972

3 EPA-420-R-17-001 January 2017.  See https://www.epa.gov/regulations-emissions-vehicles-and-engines/midterm-evaluation-light-duty-vehicle-greenhouse-gas-ghg

4 National Research Council. 2011. Climate Stabilization Targets: Emissions, Concentrations, and Impacts over Decades to Millennia. Washington, DC: National Academies Press. p. 61

5 NOAA, Billion-Dollar Weather and Climate Disasters: Summary Stats, https://www.ncdc.noaa.gov/billions/summary-stats

6 U.S. Global Change Research Program, Climate Change Impacts in the United States: The Third National Climate Assessment, May 2014.  http://nca2014.globalchange.gov/report

7 Proceedings of the National Academies of Sciences, Impact of Anthropogenic Climate Change on Wildfire Across Western US Forests, October 2016. http://www.pnas.org/content/113/42/11770

8 National Interagency Fire Center, August 23, 2018. https://www.nifc.gov/fireInfo/nfn.htm

9 Source: Commentary by Jeff Alson, vehicle standards expert and former EPA employee at the agency's Ann Arbor Laboratory, published in The Hill, August 2, 2018.  http://thehill.com/opinion/energy-environment/400051-ignore-the-facts-only-way-to-justify-rollback-of-epas-greenhouse

10 The Washington Post, August 15, 2018.  https://www.washingtonpost.com/energy-environment/2018/08/15/trump-administration-said-weaker-fuel-standards-would-save-lives-epa-experts-disagree/?utm_term=.2e90c37a88aa

11 Trump Administration Fact Sheet, "MYs 2021-2026 CAFE Proposal - by the Numbers "  https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=P100V26H.pdf

12 Ibid.

13 World Resources Institute, "6 Graphs Explain the World’s Top 10 Emitters," and   25, 2014.  https://www.wri.org/blog/2014/11/6-graphs-explain-world%E2%80%99s-top-10-emitters

14 Trump Administration's Preliminary Economic Impact Analysis of proposed rule, p. 114.  https://www.nhtsa.gov/sites/nhtsa.dot.gov/files/documents/ld-cafe-co2-nhtsa-2127-al76-epa-pria-180823.pdf

15 See footnote 8; see also Statista statistics on annual U.S. light vehicle retail sales at https://www.statista.com/statistics/199983/us-vehicle-sales-since-1951/

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