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Comments to NHTSA on Delay of CAFE Penalties Increase

The National Highway Traffic Safety Admnistration's (NHTSA's) interim final rule delays the application of its 2016 inflation adjustment of the penalty for violating the corpoate average fuel-economcy (CAFE) standards. We submitted comments explaining that the rule is untimely under the Inflation Adjustment Act, whose deadlines to amend the intial catch-up inflation adjustment expired years ago. NHTSA also entirely disregards critical impacts following from the rule, including excess fuel consumption and environmental harm. Moreover, the agency's reliance on its prior unlawful delays and rescission to justify further delay of the 2016 Adjustment ignores the will of Congress and is not a reasonable basis for regulation. For all these reasons, NHTSA should rescind the interim final rule.