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Comments on California’s Clean Cars Program

March 20, 2017

We recently submitted comments on the California Air Resource Board’s (ARB’s) Midterm Review of its Advanced Clean Cars program, which sets pollution limits and zero-emissions vehicle targets for automobiles sold in California. California is unique among the states in that the Clean Air Act allows it to seek a waiver from EPA to set its own automobile emission targets, which other states can then adopt.

The ARB adopted this program in 2012 and obtained a waiver from EPA to continue the program through 2025. Recently, Scott Pruitt, the new EPA administrator, has suggested he may begin considering whether to revoke California’s waiver. Our comments focus on the strong legal basis for ARB’s authority to enforce these standards and EPA’s lack of authority under the Clean Air Act to retract the waiver. We also discuss the importance of considering the full economic effects of these measures including the economic benefits of greenhouse gas reductions.

EPA granted the Advanced Clean Cars program a waiver in 2012, when it was determined that the program had a sound analytical foundation, and that California needed a separate set of standards given the high concentration of automobiles and evidence of poor environmental conditions in the state, among other factors. The Clean Air Act does not explicitly allow EPA or any other federal agency to revoke a waiver that has already been granted. Additionally, given that California’s standards are at least as restrictive as federal standards, EPA is required to grant a waiver in this case, as our comments show.

Before any changes are made to the program, the benefits of the current program need to be fully evaluated. From a policy perspective, reducing greenhouse gases provides significant economic benefits. The Social Cost of Carbon is a monetary estimate of the damage done by each ton of carbon that is released into the air, which will reduce the bias in favor of dirtier generation sources in economic analysis. As the program is expected to reduce greenhouse gas emissions, it will result in economic benefits which should be taken into account.

Filed under Climate Change and Energy Policy, Public Comments