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