Comment Letter on Phase 2 EPA NHSTA Greenhouse Gas Economy Rule
The Environmental Protection Agency (EPA) and National Highway Traffic Safety Administration’s (NHTSA’s) proposed Phase 2 greenhouse gas/fuel economy standards for heavy-duty vehicles endanger the economic viability of small-business truckers.
The rule’s putative energy-security and climate benefits are entirely speculative and vanishingly small at best. The agencies fail to demonstrate that, absent regulation, truckers won’t make cost-effective investments in fuel-saving technology.
If EPA wants to know why heavy trucks don’t get better mileage than they do today, it should look itself in the mirror. During the 2000s, EPA’s diesel-truck emission standards, both by directly reducing the fuel-efficiency of diesel engines, and by crowding out fuel economy-related R&D and consumer spending, created the problem the agencies purport to solve via additional regulation.