In August 2018, the Trump administration issued a proposal to dramatically weaken federal emissions standards for cars and light trucks, and to revoke the waiver that allows California to set its own standards. Federal emissions standards have been enormously successful at reducing greenhouse gas pollution and lowering fuel costs for consumers, and we recently submitted five separate sets of comments detailing the flaws with the Trump administration’s proposal.
In October 2018, we submitted the following:
- Comments explaining that EPA cannot legally withdraw the Clean Air Act preemption waiver granted to California (also available on regulations.gov) in 2013 for the greenhouse gas and zero emission vehicle requirements of its Advanced Clean Cars program (our full report on this issue is here).
- Comments explaining that the economic justifications that EPA and the National Highway Traffic Safety Administration (NHTSA) have provided for the Proposed Rule are fundamentally flawed (also available on regulations.gov).
- Comments, submitted together with several other organizations, explaining how the agencies’ analysis of the social cost of carbon in the Proposed Rule is inconsistent with best available science, best practices for economic analysis, and legal standards for rational decisionmaking (also available on regulations.gov).
- Comments, submitted together with several other organizations, explaining how NHTSA’s analysis of the social cost of carbon in the Draft Environmental Impact Statement for the Safer Affordable Fuel-Efficient Vehicles Rule for Model Year 2022-2026 Passenger Cars and Light Trucks is inconsistent with best available science, best practices for economic analysis, and legal standards for rational decisionmaking.
- Comments from our legal director, Jason Schwartz, on credit trading policy. These comments explain the benefits of price disclosure in improving market transparency and the role of a cost-benefit framework in determining compliance flexibilities (also available on regulations.gov).
In December 2018, we submitted supplemental comments rebutting an analysis that was submitted to the agencies by the Alliance of Automobile Manufacturers and NERA Economic Consulting (also available on regulations.gov). After NERA responded, in May 2019, we submitted comments responding to NERA (also available on regulations.gov).