Policy Integrity submitted comments on the National Highway Traffic Safety Administration’s (“NHTSA”) proposed fuel economy standards for light-duty vehicles in model years (“MY”) 2024–2026, recommending that:
- NHTSA should focus on the persistent market failures that consumers face (rather than on alleged technology tradeoffs between fuel economy and performance).
- NHTSA should correct multiple errors in its sales model, or consider returning to its prior static fleet forecasts.
- NHTSA should account for negative safety impacts from larger vehicles.
- NHTSA has begun to make other appropriate changes to its modeling approach, but should make further adjustments in the future to more fully capture the benefits of strong standards.
- NHTSA should coordinate with EPA to address inconsistencies in the agencies’ analyses.
- NHTSA should fully value all significant upstream emissions reductions, including those occurring abroad.
- NHTSA should consider lower discount rates and, after implementing the methodological corrections recommended by these comments, recalculate costs and benefits for its policy alternatives. NHTSA should then select an alternative to increase net social welfare and achieve distributional goals.
We also submitted joint comments with a coalition of other environmental groups on NHTSA's use of the social cost of carbon (SCC) in its proposed regulation, recommending that the agency expand its justification of its discount rates and inclusion of global damages in the SCC, and affirm that the SCC is a lower bound of projected climate impacts.