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CEI Comments on EPA & NHTSA Reconsideration of Fuel Economy Standards

Regulatory Comments and Testimony

Title

CEI Comments on EPA & NHTSA Reconsideration of Fuel Economy Standards

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The Obama EPA’s final Mid-Term Evaluation (MTE) is arbitrary, capricious, and an abuse of discretion. Reconsideration is necessary to restore regular order and repair the damage to what should be a harmonized, national program. However, a more fundamental fix is required for the underlying malady—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 enacted. Congress provided no authority for 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 and oil consumption even if one assumes such goals are desirable. The claim that fuel economy standards are necessary because consumers fail to grasp or refuse to pursue their best interests is bureaucratic pretension. Worst of all, it is clear that fuel economy standards have impaired and continue to limit vehicle safety by constraining vehicle size and weight. Before the agencies impose any new standards whatsoever, they should first do a full accounting of the adverse impacts of previous standards on traffic deaths.

  1. MTE’s Detrimental Impacts on National Harmonized Program

  2. MTE’s Costly and Inefficient Reductions in Emissions and Oil Consumption

  3. Agencies Are Not Qualified to Determine Whether Consumers Correctly Value Fuel Economy

  4. Inadequate Consideration of the Standards’ Impact on Vehicle Safety

Read the full comments here.