"Regulations are built on a host of assumptions, especially when the rulemaking reaches 13 years into the future. A strong mid-term review, coupled with regular check-ups, will show if assumptions about consumer buying patterns, for instance, are becoming reality.
"The Alliance supports the proposal to include an in-depth mid-term evaluation process that will allow the agencies to review a broad range of factors and make appropriate adjustments. This process will provide better data and insight on a range of issues relevant to the appropriateness of the MY 2022-2025 standards, including consumers' willingness to buy the vehicles that are required to comply with the standards; future fuel pricing; and technology and raw materials costs. The Alliance comments on the mid-term evaluation include additional topics that the agencies should review. We recommend that, in addition to the proposed formal mid-term evaluation, the agencies continue their open dialogue and also conduct a series of smaller, focused technical evaluations - or "check-ins" - on the key assumptions of the proposal. The Alliance also requests a more specific description of the mid-term evaluation process and the specifics to be reviewed, including the timeline and procedures for assuring that the studies relied upon by the agencies are appropriately peer reviewed.
"To increase energy independence, we need to use all the tools available, including innovative, proven ways to reduce fuel use and greenhouse gas emissions (GHGs). These approaches should be recognized by the government, starting right away with the current standards for MYs 2012-16.
"The objective of the CAFE and GHG standards is to reduce actual fuel consumption and actual GHG emissions from vehicles driven on American roads. In some cases, however, the laboratory testing used by the agencies to measure fuel economy and GHG emissions may not fully reflect the improvements built into a vehicle by the manufacturer, due to limitations of laboratory-based tests. For instance, improvements that reduce refrigerant loss from air conditioning systems can reduce GHG emissions from vehicles while having little or no impact on fuel economy. It is important for the rules to properly account for such factors. Otherwise, manufacturers would be encouraged to focus solely on the test procedures, and opportunities for real-world GHG reduction and fuel economy improvement would be lost. The Alliance believes that the various credit provisions proposed by EPA and NHTSA are essential elements of the rulemaking package. And, recognition of the real-world improvements provided by these innovations should begin with the very first vehicle employing approved technologies, and there should be no ceiling on the deployment of these effective technologies.
"Automakers should not be required to account for utility GHG emissions. The proposed rule indicates that the agencies expect electric vehicles to become an increasingly large part of the car park. Yet the rule leaves open the possibility of requiring manufacturers to account for upstream emissions from electricity generation in the event that the Administration is unable to control these emissions through other channels. In other words, automakers may now be called on to not only make an unprecedented investment into vehicles with lower GHG emissions, but to also fill the void between this rulemaking and a comprehensive national energy policy. If Americans agree that programs to address upstream GHG emissions are appropriate, then such programs should be put in place through appropriate regulation of electricity generators, not by imposing additional burdens on vehicle manufacturers."
Access a release from the Auto Alliance (click here). Access complete information on the EPA/NHTSA proposal (click here). Access the docket for this action (click here). [#Energy/CAFE, #Climate, #Air]
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