On behalf of the Competitive Enterprise Institute (CEI), a non-profit public policy group specializing in regulatory issues, I respectfully submit this comment letter on EPA and NHTSA’s proposed rule, Greenhouse Gas Emissions Standards and Fuel Efficiency standards for Medium- and Heavy-Duty Engines and Vehicles.
This comment letter develops the following points:
1. Although the ostensible purpose of the rule is to reduce greenhouse gas emissions and oil imports, the overwhelming lion’s share of the claimed benefits – fuel savings for truckers – have nothing to do with either climate change or energy security.
2. EPA and NHTSA provide no solid evidence that the trucking industry’s alleged “under-investment” in fuel-saving technology is due to market failure. In fact, two of the agencies’ five “potential hypotheses” suggest that truckers are simply behaving like prudent buyers.
3. EPA and NHTSA ignore a more credible and obvious explanation of lagging heavy-truck fuel economy. EPA’s diesel-engine emission standards, both by directly reducing the fuel efficiency of diesel engines, and by crowding out fuel economy-related R&D investment and consumer spending, created the problem the agencies now seek more power over industry to solve.