Comment Letter Supporting EPA’s Corporate Average Fuel Economy Preemption Rule

June 10, 2021

On June 10, 2021, ten Emmett Institute faculty members submitted comments to EPA supporting the Corporate Average Fuel Economy Preemption rule, which would repeal the Safer Affordable Fuel-Efficient Vehicles Rule Part One: One National Program rule (2019 Rule). The comment letter argues the 2019 Rule contravened Congress’ intent in enacting the Energy Policy and Conservation Act and its subsequent amendments, relied on dubious legal authority to adopt a preemption determination, and failed to adhere to bedrock principles of administrative procedure. The comment letter supports repealing the 2019 Rule in its entirety.

Download PDF

News
See All
Dec 01, 2023

Advancing Methane Regulation: Implications of New Monitoring Technologies

Read More
Nov 13, 2023

A Heavy Lift: Policy Solutions to Accelerate Deployment of Zero-Emission Cargo Handling Equipment at the Ports of Long Beach and Los Angeles and Beyond

Read More