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In May 2022, the National Highway Traffic Safety Administration (NHTSA) finalized a rule to increase its corporate average fuel economy (CAFE) standards for passenger cars and light trucks for model years 2024–2026. A group of fuel and petrochemical manufacturers and states challenged the standards in the U.S. Court of Appeals for the D.C. Circuit, arguing primarily that the Energy Policy and Conservation Act bars NHTSA from including electric vehicles in the analytical baseline for the new standards. Our amicus brief explains that longstanding administrative guidance and case law direct agencies to develop baselines that reflect their best assessment of the real world absent any new agency action. In the context of this rulemaking, that guidance and case law required NHTSA to project how many and what kinds of vehicles—including electric (and plug-in hybrid electric) vehicles—would be built and sold if it did not issue new CAFE standards, which is what NHTSA did here. Our amicus brief also explains that NHTSA has consistently prepared baselines for prior CAFE standards in this manner.