Comment Letter on EPA and NHTSA Proposed SAFE Rule


On October 25, 2018, Emmett Institute faculty members submitted comments on the proposed Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule.

October 25, 2018
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Julia Stein, Ann Carlson, Cara Horowitz, Sean Hecht, Meredith Hankins

On October 25, 2018, Emmett Institute faculty members Julia Stein, Ann Carlson, Cara Horowitz, Sean Hecht, and Meredith Hankins submitted comments on the proposed Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule for Model Years 2012-2026 Passenger Cars and Light Trucks.

The authors express concern over EPA and NHTSA’s joint proposal to freeze federal fuel economy standards for passenger cars and light trucks at model year 2020 levels and to revoke the waiver for the California Advanced Clean Cars (“ACC”) program and Zero-Emission Vehicle (“ZEV”) requirements appropriately granted to California in 2013 pursuant to the Clean Air Act.

The authors conclude that EPA’s proposed revocation of California’s ACC/ZEV waiver is inconsistent with its statutory authority and with Congress’s intent in enacting the Clean Air Act. The authors argue that revocation of the ACC/ZEV waiver would be both unlawful and inappropriate and urge EPA to withdraw the proposed rule and leave California’s waiver intact.

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