Update:  Trump Administration Proposes to Roll Back Vehicle Fuel Economy Standards

The Trump Administration on August 2, 2018, released a proposal to freeze model year vehicle greenhouse gas (GHG) and fuel economy standards at model year 2020 levels through model year 2026, while taking comment on a range of alternatives.  If finalized, the proposal would roll back the existing, stricter GHG vehicle standards for model years 2021-2025 as well as stricter fuel economy standards for model year 2021.  The existing standards cut emissions that cause climate change, reduce oil imports, and save consumers money at the pump.  For more information on the proposal and how to comment and participate in public hearings -- including suggested talking points -- see Trump Administration Proposes to Roll Back Climate Pollution and Fuel Economy Standards for Cars and Light TrucksFor additional background on fuel economy standards, see the information below.

Pre-Proposal Notice: Vehicle Fuel Economy Standards for 2022-2025

Public Comment Closed September 25, 2017

Docket ID: NHTSA-2017-0069

Link to Docket: https://www.regulations.gov/docket?D=NHTSA-2017-0069

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

The Trump Administration has opened the door to potential weakening of fuel economy and greenhouse gas (GHG) pollution standards for cars and light trucks for model years 2021-2025.  Administrator Scott Pruitt in April 2018 announced a decision to weaken the greenhouse gas standards, which the administration is looking at in tandem with new fuel economy standards. (For more, see Save EPA's web page on Defending Climate Pollution Standards for Cars and Light Trucks.)  Both sets of standards avoid energy waste, promote U.S. energy security, save consumers money at the pump, and are a main pillar of U.S. efforts to combat climate change.  Cars, SUVs and light trucks in 2015 were responsible for nearly 20% of climate-changing pollution in the United States.

Fuel Economy Standards in Place Today

Corporate Average Fuel Economy (“CAFE”) standards are developed by the National Highway Traffic Safety Administration (NHTSA), which is part of the Department of Transportation.  Standards to cut climate-changing emissions from vehicles are developed by EPA.  Separate laws require each type of standards, but the issues are related – better fuel economy and lower emissions of carbon dioxide, the most pervasive climate-changing greenhouse gas pollutant, are closely linked.

Fuel economy standards must be the “maximum feasible” considering technological feasibility, cost, the effect of other government standards relating to fuel economy, and the nation’s need for energy security.

In 2012, EPA set GHG pollution standards for cars, SUVs and light trucks for model years (MY) 2017 to 2025, in conjunction with NHTSA, which developed fuel economy standards for those same model years.  Both sets of standards were based on extensive analysis.  The NHTSA standards are  similar but not identical to the EPA greenhouse gas standards because of differences in the underlying laws passed by Congress.

Because the fuel economy law authorizes setting standards for only five model years at a time, only the 2017-2021 fuel economy standards were binding.  The 2022-2025 fuel economy standards were forecasts of standards to be established later.

Graph showing trends in vehicle fuel economy 2000-2025. Highest to lowest: European Union, Japan, China, USA.
The US already lags behind Europe, Japan and China in fuel economy, putting US automakers at a competitive disadvantage. Graph from Felix Salmon, Reuters Blog. http://blogs.reuters.com/felix-salmon/2012/09/12/why-fuel-economy-standards-make-sense/

Trump Administration Re-Evaluation and NHTSA Notice

Under the Trump Administration, NHTSA started a process to set binding fuel economy standards for 2022-2025, based on a wholly new examination of the levels feasible in those years. The agency is weighing proposal of model year 2022-2025 fuel economy standards weaker than the levels NHTSA previously determined would be warranted.   The agency is separately evaluating whether to reopen the existing 2021 standards.  NHTSA’s approaches might be used to influence the parallel EPA re-evaluation of greenhouse gas standards.

As a preparatory step, consistent with the National Environmental Policy Act NHTSA on July 26 published a “Notice of Intent to Prepare an Environmental Impact Statement for 2022-2025 Corporate Average Fuel Economy Standards.” The notice asks for comment on considerations that should be addressed, and on the range of alternative fuel economy standards that the agency should consider.

The notice correctly states that NHTSA must analyze a no-action alternative as part of its consideration of environmental implications of potential CAFE standards, and correctly includes a “No Action” alternative that assumes that model year 2021 CAFE standards stay in force in perpetuity.

The notice represented an early opportunity for the public to support strong fuel economy standards for vehicles, which could also reduce the risk of rollbacks in EPA’s vehicle GHG pollution standards.

Suggested Talking Points on this Notice

Issue 1:   2021 fuel economy standard -- NHTSA’s notice raises the possibility of reopening fuel economy standards for model year 2021.1   NHTSA should not reconsider the standards for MY 2021.  The agency previously determined those standards to be “maximum feasible,” as the law requires, based on a robust technical record.   

Issue 2:   Range of fuel economy standards to consider for 2022-20252 -- The lower-bound alternative for 2022-2025 standards should be no less stringent than the existing MY 2021 standard, which NHTSA has already found to be feasible.  The upper bound should be no less stringent than the MY 2022-2025 non-binding standards that NHTSA identified as maximum feasible in 2012.  NHTSA recently reached that same conclusion in the Draft Technical Assessment Report issued jointly by NHTSA, EPA, and California Air Resources Board in July 2016.  The report in fact shows that even more stringent standards for those years are feasible at reasonable cost, so NHTSA should analyze even more stringent standards as an upper bound alternative.

Issue 3:  Transparency – NHTSA’s notice appropriately says that its processes should be transparent and reflect peer-reviewed research.3  That is a laudable objective, but to date, NHTSA has not adequately disclosed the detailed workings of the model it uses to analyze alternative fuel economy standards.4 NHTSA should fully set out both the exact workings of the CAFE Compliance and Effect Model, and all of the inputs to it that are not confidential business information.  Nor is it clear whether the later iterations of that model have been peer-reviewed.  NHTSA should also be fully transparent on use of any other models it intends to utilize, such as any model relating to consumer acceptance of fuel economy technologies, and technology performance simulation models.

Issue 4:   Declining standards – NHTSA’s notice suggests that 2022-2025 CAFE standards might either decrease or increase in stringency from one model year to another.5   The idea of fuel economy standards that get weaker over time is at odds with any reasonable notion of maximum feasible standards.   


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.  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.


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

NHTSA web page on fuel economy standards: https://www.nhtsa.gov/laws-regulations/corporate-average-fuel-economy



1 National Highway Traffic Safety Administration, “Notice of Intent to Prepare an Environmental Impact Statement for 2022-2025 Corporate Average Fuel Economy Standards,” Federal Register July 26, 2017 (82 FR 32742).  https://www.federalregister.gov/documents/2017/07/26/2017-15701/notice-of-intent-to-prepare-an-environmental-impact-statement-for-model-year-2022-2025-corporate

2 NHTSA notice, p. 34742.

3 NHTSA notice, p. 34743

4 Each time NHTSA proposes or finalizes new corporate average fuel economy (CAFÉ) standards, the agency must consider options and estimate the impacts of each option.  For all CAFE rulemakings since 2003, NHTSA has made significant use of results produced by the CAFE Compliance and Effects Model (commonly referred to as “the CAFE model” or “the Volpe model”), developed by DOT’s Volpe National Transportation Systems Center to support NHTSA’s CAFE rulemakings. NHTSA uses the model as a tool to estimate how manufacturers could attempt to comply with a given CAFE standard by adding technology to anticipated future vehicle fleets, and to estimate impacts of that additional technology on fuel consumption, greenhouse gas emissions, and economic costs and benefits to vehicle owners and society.  NHTSA also uses the model to evaluate the sensitivity of these estimated outcomes to key analytical inputs (e.g., fuel prices), and to perform probabilistic uncertainty analysis.  Source:  NHTSA web page on CAFE: https://www.nhtsa.gov/laws-regulations/corporate-average-fuel-economy

5 NHTSA notice, p. 34743

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Save EPA has been an all-volunteer group of former EPA officials who became alarmed about the Trump agenda for EPA and joined together to fight it.

With newly-elected President-Elect Biden and VP-Elect Harris coming in January, the need to "save EPA" is much less urgent. This is not to imply all clear skies ahead - there is much re-building to do, there will be negative pressures on the new administration, and we will likely have policy differences in the future. However, we are hopeful that these differences will be discussed rationally, using science as a basis for moving forward, and keeping EPA's mission of protecting human health and the environment in the forefront.

And so, we are going back to retirement!  We're keeping our website up at http://saveepaalums.info/ , as a resource for those who want to follow and influence the restoration work. Our report on the Trump record at EPA describes the actions that need to be reversed [saveepaalums.info/Trump+era+report], and our guide to participating in the rulemaking process [http://saveepaalums.info/Resistance+Guide] can help you be part of the solution.

Thank you for your support and commitment during the past 3.5 years.  While the Trump assaults were unending, they were also frequently unsuccessful, and that was due in large part to public outrage.  Keep it up!  Although EPA will be in much better hands with a Biden administration, there is always a need for an informed and engaged public.