EPA/NHTSA joint Notice of Intention to reconsider the final determination of the mid-term evaluation of GHG emissions standards for MY 2022–2025 light duty vehicles [press statement]

March 15, 2017—The International Council on Clean Transportation supported the U.S. Environmental Protection Agency's decision in January 2017 to keep unchanged the greenhouse gas (GHG) emissions standards for model years 2022–2025 cars and light trucks. Our support was based on the results of our own independent analyses of technology and cost trends in the industry, conducted in collaboration with nearly a dozen automotive industry suppliers. Those analyses showed that the EPA and the National Highway Traffic Safety Administration had been in fact somewhat conservative in their technology and cost projections, both at the time the regulation was drafted and during the midterm evaluation completed in 2016.

The ICCT fully expects that reopening the midterm evaluation, as today's announcement that EPA will reconsider the January 2017 final determination does, will ultimately lead again to the same conclusion: that the 2025 standards are appropriate and feasible. The Technical Assessment Report performed by the agencies for the midterm evaluation in 2016, on which the final determination was based, represents a comprehensive, objective, analytically rigorous assessment of the technology and cost trends in the auto industry. This level of technical scrutiny of a vehicle regulation is unprecedented, both in the United States and worldwide, and the transparency of the process is unexcelled. As we have already noted, our own independent analyses suggest that the TAR was prudently cautious in its conclusions; efficiency technology innovation in the industry has been so dynamic, and manufacturing costs so well contained, that a strong argument could in fact be constructed for making the 2022–2025 efficiency standards even more advanced. In fact, the pace of technology development is so rapid that we expect additional technologies will come into production during the reopened review process, further reducing the cost to comply with the standards.

Compelling independent evidence attests to the immense benefits consumers stand to gain from the 2025 standards. Even in the unlikely event that gas prices remain at their current low levels, consumer savings on fuel purchases will be at least two to three times the increase in purchase price, putting money in consumers' pockets and leading to economy-wide benefits and jobs. The environmental need for those standards is vital and unquestioned. The transportation sector is now the largest source of carbon emissions in the United States, and light-duty vehicles contribute the largest share. And the impetus the standards provide to continued technological innovation in the industry—with the consequent benefits to employment not only among auto manufacturers but in the vast network of suppliers—is critical.

Not only the automakers but also hundreds of suppliers and other companies have invested in research, development, and deployment of efficiency technologies, in reaction not only to US fuel-efficiency standards but also to those in Europe, China—indeed, the majority of the world's major auto markets. About 80% of global automobile sales now occur in markets with fuel-efficiency standards that approach and sometimes even exceed the US 2025 GHG targets. The most important of those markets, Europe and China, are actively considering ways to push efficiency further. In the ICCT's assessment, anything that puts the US 2025 standards at risk carries with it the risk that the U.S. could once again become a relative technology laggard in the industry, with clear implications for U.S.-based companies' competitive position.


Drew Kodjak, Executive Director,

John German, US program co-lead,

Nic Lutsey, US program co-lead,


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