On Thursday, October 5, the Competitive Enterprise Institute submitted comments to the Environmental Protection Agency (EPA) regarding its Final Mid-Term Evaluation (MTE) of greenhouse gas emission standards for model year 2022-2025 light duty vehicles Docket ID No. EPA–HQ–OAR–2015–0827).
In the comments, we address four topics on which the EPA and the National Highway Traffic Safety Administration (NHTSA) have requested public comment:
- The impact of the greenhouse gas emission standards on the Corporate Average Fuel Economy (CAFE) standards and a national harmonized program.
- The impact of the standards on reduction of emissions, oil conservation, energy security, and fuel savings by consumers.
- The extent to which consumers value fuel savings from greater efficiency of vehicles.
- The impacts of the standards on automobile safety.
They note that the Obama EPA’s final Mid-Term Evaluation is arbitrary and, capricious, and an overreach of agency discretion. Therefore, the agency should reconsider the MTE to repair the damage to what should be a harmonized, national program.
However, a more fundamental fix is required for the underlying problem. U.S. automakers are subject to three sets of fuel economy standards by three agencies operating under three statutes. The solution is to return to the statutory scheme.
Congress provided no authority for the EPA to regulate fuel economy and specifically preempted states, such as California, from adopting laws or regulations “related to” fuel economy.
Moreover, fuel economy standards are a costly and inefficient means of reducing greenhouse gas emissions.
Worst of all, CAFE impairs vehicle safety due to its downsizing effect on cars. Before the agencies impose any new standards, they should first do a full accounting of the adverse impacts of existing standards on the number of traffic deaths.
Finally, the claim that fuel economy standards are necessary because consumers fail to pursue their own best interests is the height of bureaucratic arrogance. Washington regulators should step out of the way and not hinder consumer choice.
Read the full comments here.