The Alliance of Automobile Manufacturers has filed comments in response to the Notice of Intent (NOI) and Technical Assessment Report (TAR) for MY2017-2025 light-duty vehicle fuel economy/greenhouse gas regulations released last month by Environmental Protection Agency (EPA) and the National Highway Traffic Safety Administration (NHTSA) (earlier post).
In the comments, the Alliance outlined four specific concerns with the NOI and the accompanying Technical Assessment Report:
- The agencies should consider the critical role of fuel prices in ensuring public acceptance of more costly high-fuel economy vehicles.
- The Administration should establish a process by which an independent panel of experts periodically considers whether assumptions made in the standard setting process are still valid. To make this workable, the Alliance recommends that the 2017-2025 time frame be broken into segments of three or four years, and that this independent review take place prior to the agencies issuing a final rulemaking for each increment.
- The agencies should review the cost and technology assumptions in the Technical Assessment Report that were used to set the targets in the NOI.
- Additional analysis and discussion should take place on the potential effects of significant mass reductions on vehicle safety performance. Failure to undertake and complete these mandatory safety studies may render any final rule legally vulnerable, the Alliance suggested.
Automakers remain committed to the goals of the national program: a single, coordinated standard that promotes clean innovative vehicles, lowers greenhouse gas emissions, reduces dependence on foreign oil, and creates jobs. While the NOI and TAR represent a good start, it is clear that much work remains before new standards are proposed. The NOI references numerous additional analyses that EPA and NHTSA are working with the California Air Resources Board (CARB) to complete. We look forward to reviewing those studies.—Alliance President and CEO, Dave McCurdy