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Comments on California’s Proposed State-Specific Vehicle Emissions Regulations

We recently submitted comments to the California Air Resource Board (CARB) on its proposal to maintain existing statewide vehicle emission regulations. In coming years, the National Highway Traffic Safety Administration and Environmental Protection Agency plan to weaken federal environmental regulations. CARB is aiming to hold California vehicle emissions at current standards to avoid the effects of weakened regulations. Our comments support the feasibility of California’s current standards and encourage CARB to improve its economic impact assessment by accounting for new federal proposals and a broader range of effects.

In an earlier stage of this proceeding, we submitted comments explaining that economic evidence supports maintaining existing vehicle emissions standards. Our latest comments reiterate our support for the proposal. We also urge CARB to update its sensitivity analysis. A recent federal proposal plans to freeze emissions and fuel economy standards at 2020 levels. CARB’s latest modeling assumes that federal emission standards will be frozen at 2021 levels, so we suggest that the agency reevaluate the California proposal using 2020 federal standards. Further, we explain why CARB should expand analysis to include indirect effects, such as vehicle safety considerations and potential emission effects in other states.