Comments on the Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule for Model Years 2021-2026 Passenger Cars and Light Trucks

On August 2nd, 2018 the U.S. Department of Transportation’s National Highway Traffic Safety Administration (NHTSA) and the U.S. Environmental Protection Agency (EPA) issued a notice of proposed rulemaking for fuel economy and greenhouse gas emissions standards for passenger cars and light trucks.

The proposal would essentially hold the 2020 standards for new vehicles in place indefinitely. According to official federal analyses, the rollback will result in 73 billion gallons more gasoline bought by U.S. drivers and 800 million tons more carbon dioxide emissions. In contrast, the final rule adopted under the Obama Administration requires a 3%-4% increase in efficiency and reduction in greenhouse gas emissions per mile per year through 2025.

On October 25th, 2018 the International Council on Clean Transportation submitted its official comments in response to the proposed rollback. Our comments below summarize our deep analysis of the rule and its associated data files and analysis. Our findings indicate that the proposed regulation is deeply flawed in terms of the information upon which it is based, the novel and unfounded methods used to prop up costs and reduce benefits, and the conclusions the agencies have drawn.

Contrary to the agencies’ suggested path, the agencies’ own abundant technical evidence ;demonstrates that the standards could be cost-effectively made more stringent. Nevertheless, in the interest of maintaining regulatory certainty for industry investments, we believe that maintaining existing adopted GHG standards for 2022-2025 is appropriate. We strongly urge NHTSA to finalize& its Augural 2022-2025 standards to ensure alignment with the adopted EPA and California 2022-2025 standards. We also recommend the agencies do not revoke the California waiver and take no action toward removing state-level regulatory authority.

ICCT Public Comments NHTSA2026 NPRM 25oct2018 by The International Council on Clean Transportation on Scribd