Ms. Heidi King
National Highway Traffic Safety Administration
1200 New Jersey Avenue SE
Washington, DC 20590
Deputy Administrator King:
Our organizations endorse good governance through policies that promote free markets and enable consumer choice. In that light, we write today in support of the National Highway Traffic Safety Administration’s (NHTSA) issuance of a notice of proposed rulemaking (NPRM) for model year 2022-2025 Corporate Average Fuel Economy (CAFE) standards for light-duty vehicles.
The CAFE program was established in 1975 during a time of grave national concern over fuel scarcity and American reliance on imported energy. When Congress enacted the Energy Policy and Conservation Act of 1975, it certainly could not have foretold the tremendous technological innovations that have led, barely four decades later, to the United States being poised to become the largest producer of oil in the world. The narrative of scarcity has been overwhelmed by the reality of abundance, which has created tremendous opportunities for our nation’s economy.
Congress certainly could not have envisioned, either, that three separate agencies – two Federal, and one at the State level – would be placed in charge of determining our national fuel economy standards. Under EPCA, Congress delegated the authority to establish Federal fuel economy standards solely to the Department of Transportation. In fact, while so doing, Congress expressly prohibited States from adopting or enforcing “a law or regulation related to fuel economy standards or average fuel economy standards” while a Federal standard exists.
When the current CAFE and light-duty vehicle GHG standards were finalized in 2012, there was acknowledgment – in keeping with DOT’s authority to set fuel economy standards only five years at a time – that a mid-term review was a necessary and fundamental component of the policy. This ability to review and, as befitting the best and most currently available data, revisit the standards represents a critical element of protection for American consumers and manufacturers.
Reconsideration of the model year 2022-2025 standards will allow NHTSA and EPA to better determine whether those standards represent what is best for all stakeholders involved – including the millions of American families whose vehicle purchasing options will be determined by CAFE regulations. Reconsideration will also ensure that these agencies are able to more fully evaluate whether the standards are in harmony with NHTSA’s core value of “achieving the highest standards of excellence in motor vehicle and highway safety.”
Given widespread concerns regarding the potential of the existing fuel economy standards to increase consumer costs and decrease consumer choice, we applaud NHTSA for taking the important step of beginning the reconsideration process of the model year 2022-2025 CAFE standards. Full consideration of the views of all stakeholders – including American motorists – will ensure a balanced policy that promotes consumer choice while protecting our national economic interests.
Thank you for your continued leadership on this important issue.
Thomas J. Pyle, American Energy Alliance
David T. Stevenson, Caesar Rodney Institute
Myron Ebell, Competitive Enterprise Institute
Phil Kerpen, American Commitment
Grover Norquist, Americans for Tax Reform
David Williams, Taxpayers Protection Alliance
Rick Manning, Americans for Limited Government
Craig Richardson, E&E Legal
Adam Brandon, FreedomWorks
Tim Huelskamp, Heartland Institute
Amy Oliver Cooke, Independence Institute
Andrew Langer, Institute for Liberty
Jon Sanders, John Locke Foundation
Harry Alford, National Black Chamber of Commerce
Paul Gessing, Rio Grande Foundation