Defending Climate Pollution Standards for Cars, SUVs and Light Trucks
What’s at Risk, How to Comment and Talking Points
The EPA standards at risk would control heat-trapping greenhouse gas (GHG) pollution from cars, SUVs and light trucks, which account for around 20% of climate pollution in the U.S. These vehicles are second only to electric utilities in the amount of climate pollution they emit. The transportation sector as a whole now emits more GHGs than even electric utilities.
In addition to helping to combat climate change, these standards save drivers money and promote national security by reducing the need for oil imports.
DEADLINE FOR PUBLIC COMMENT ON ROLLBACK ACTION:
OCTOBER 5, 2017 — 11:59 pm Eastern Standard Time
Submit comments and see docket information @ https://www.regulations.gov/document?D=EPA-HQ-OAR-2015-0827-6325
Docket ID #: EPA-HQ-OAR-2015-0827
EPA FINAL RULE (BEFORE PROPOSED ROLLBACK)
In 2012, EPA set GHG pollution standards for cars and light trucks for model years (MY) 2017 to 2025, in conjunction with corporate average fuel economy (or “CAFE”) standards issued by the National Highway Traffic Safety Administration (NHTSA).1 EPA set the standards after conducting a comprehensive and extensive technical analysis.
Based on that analysis, EPA found 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 make these significant GHG pollution reductions at reasonable cost, and that fuel savings over the life of the vehicles would more than make up for the increase in vehicle cost. EPA therefore set the standards at this level and projected that they would achieve very large reductions in GHGs and in oil usage, and that the total benefits of the rule far outweighed the costs. 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 under the Clean Air Act. EPA conducted an unprecedentedly 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 for these model years are in fact still appropriate.2
EPA found that the standards continue to be technically feasible at reasonable cost. 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 continue to far exceed the costs of the program.
TRUMP ADMINISTRATION ROLLBACK PROPOSAL
In March 2017, the new EPA Administrator announced that EPA would reconsider this final determination, and in August 2017 further announced the intention to reconsider the MY2021 standards. In a joint notice with NHTSA released August 10, EPA has opened a new comment period on whether the MY2021-2025 standards are appropriate under the Clean Air Act. This is the first step to consider rolling back — i.e. weakening — these GHG standards. If EPA changes its position and determines that the standards are no longer appropriate, then EPA will go through rulemaking to adopt weaker standards.
WHAT TO SAY
First, explain why you’re commenting on this notice – why the vehicle standards matter to you.
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.
SUGGESTED TALKING POINTS ABOUT THE STANDARDS
- Reconsidering the standards for controlling climate pollution from model year 2021-2025 cars, SUVs and light trucks is a waste of precious time and taxpayer dollars. EPA made its January 2017 Final Determination based on a comprehensive, detailed analysis and after considering extensive public comments. We need the standards to stay in place – or be strengthened — to combat climate change and save consumers money at the pump.
- Experts consider EPA’s greenhouse gas standards (GHG) for vehicles to be the single biggest action taken by any country to address climate change. EPA has revolutionized control of climate pollution in the transportation sector by setting GHG standards for light-duty vehicles – passenger cars, SUVs and light trucks – starting with model year 2012 and continuing through model year 2025. These GHG standards essentially double the fuel economy of the light duty vehicle fleet by 2025 to an average miles-per-gallon in the high 30s. This will save billions of gallons of gasoline and billions of dollars in fuel costs, and avoid billions of tons of GHG pollution.
- The standards also 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. (Source of information: Energy Information Agency website for OPEC import figures— about 1.1 billion barrels of OPEC oil imported in 2016; and EPA Proposed Determination table ES-3 – about 1.2 billion barrels of oil saved as a result of 2022-2025 standards).
- These 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 these 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 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 standards that apply to model year 2012 cars, SUVs, and light trucks are already resulting in very substantial pollution reductions, while automakers are having their best sales years ever. There is no evidence that adding GHG pollution controls have hurt vehicle sales. If anything, they are a selling point (as shown, for example, by advertising like for Ford’s Eco Boost and Mazda’s SkyActiv technology).
- Because the standards go so far into the future, EPA pledged to conduct a mid-term evaluation of the standards for model years 2022-2025 to update the evidence and determine whether those standards remain appropriate in light of any changed conditions since 2011.
- For this evaluation, EPA conducted the most comprehensive federal assessment of vehicle technology ever done. EPA developed a massive report reflecting years of peer-reviewed research and studies conducted by EPA and others. Consistent with National Academy of Science recommendations, EPA used a vehicle technology simulation model and technology tear-down studies to precisely estimate cost of control technologies. EPA also considered industry’s experience to date, which in many cases shows even quicker adoption of updated and advanced technologies than EPA and NHTSA had predicted in 2012. EPA invited comment from the public before making a final determination.
- In January 2017, EPA determined that the model year 2022-25 standards are still appropriate because they remain technically feasible and at lower costs than EPA initially estimated. There is also no evidence of consumer resistance to introduction of the technologies needed to achieve the reduced emissions and improved fuel economy. EPA also found that the 2022-2025 standards can be achieved using combinations of technologies which already exist and are in use, and that the standards can be achieved with only limited reliance on sales of hybrids, plug-in hybrids, or electric vehicles.
- All of the credible evidence to date points to the conclusion that the auto industry can successfully implement the model year 2022-2025 standards, and the model year 2021 standards as well, and that the standards remain appropriate under the Clean Air Act. If anything, the evidence points to strengthening the standards, not weakening them.
- Vehicle GHG controls remain a critical component of addressing the threat of 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. That means the auto industry has to do its part to control GHG pollution.
- EPA cannot cede its responsibility for setting GHG standards to NHTSA. EPA has the mission, staff expertise, laboratory capability, and proven track record of standing up to automakers to lead the way in controlling climate pollution in the transportation sector. EPA should do its job of developing standards that protect the planet.
- On a more personal note, I look forward to having an ever wider choice of fuel efficient cars, SUVs and light trucks in the future, thanks to these standards. I don’t want to spend time and money filling up my tank. I want to save the planet and drive the fuel-efficient vehicle of my dreams, too!
HOW TO SUBMIT YOUR COMMENT TO EPA
EPA and NHTSA are accepting written comments on reconsideration of the GHG and fuel economy standards through 11:59 EST October 5, 2017.
The docket link is: https://www.regulations.gov/document?D=EPA-HQ-OAR-2015-0827-6325.
If you wish to submit comments by mail, fax or other means, see directions at http://www2.epa.gov/dockets/comenting-epa-dockets.
THERE IS MORE THAT YOU CAN DO
It would be great if well-reasoned, fact-based comments were enough to win the day, but in today’s deregulatory environment, raising the political stakes of regulatory rollbacks is crucial to stopping or slowing them down. Submitting comments is a good first step. For rules that are particularly important to you, please consider taking one or more of the following steps, too.
- Write to your members of Congress and other elected officials. Let them know your concerns and ask them to weigh in with the agency proposing the rollback.
- Write letters to the editor and even op-eds in your local papers.
- Organize or participate in letter-writing campaigns.
- Join or organize demonstrations.
- Talk to your friends, colleagues and neighbors and encourage them to comment and otherwise join in this effort. Voicing your concerns on social media can be a very effective way to spread the word.
LINKS FOR MORE INFORMATION
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)
1 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
2 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