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Global Automakers calls on EPA to withdraw proposed determination on MY 2022-2025 GHG standards, get back in alignment with NHTSA, provide more time

Global Automakers, the trade association representing the US divisions of 12 international automakers (Aston Martin, Ferrari, Honda, Hyundai, Isuzu, Kia, Maserati, McLaren, Nissan, Subaru, Suzuki and Toyota), has called on the EPA either to withdraw its proposed determination on MY 2022-2025 light duty vehicle greenhouse gas standards or to extend the comment period. On 30 November, EPA proposed leaving the greenhouse gas (GHG) emissions standards for those model years in place, based on its technical analysis that shows automakers are well positioned to meet the targets, and proposed a 30-day comment period. (Earlier post.)

The final standards are projected to result in an average industry fleet-wide level of 163 grams/mile of CO2 in model year 2025, which is equivalent to 54.5 mpg (4.31 l/100 km), if achieved exclusively through fuel economy improvements.

The Environmental Protection Agency’s (EPA) decision to rush forward with its Midterm Evaluation and issue a Proposed Determination on MY 2022-2025 greenhouse gas (GHG) emission standards undermines the important process the regulators and automakers agreed to in 2012 for establishing one harmonized national program for regulating GHG and fuel economy. Global Automakers and its members remain committed to the goals of one national program and therefore are asking the EPA to withdraw its Proposed Determination, or at the very least grant an extension of the current 30-day comment period.

Emissions standards going forward were to be based on a data-driven and objective review in which the EPA, the National Highway Traffic Administration (NHTSA) and the California Air Resources Board (CARB) are aligned every step of the way. The hasty decision to accelerate the EPA process, taken in the waning days of an Administration, raises serious concerns about the objectivity and factual foundation of their action.

We look forward to working with EPA, NHTSA and CARB on harmonized standards that are achievable, cost-effective, and most importantly account for the needs of customers.

—John Bozzella, President and CEO, Global Automakers

In a letter addressed to EPA Administrator Gina McCarthy, Global Automakers observed that determining the appropriate standards for MY 2022-2025 was to be based on a data-driven and objective review process in which the EPA, National Highway Traffic Administration (NHTSA) and California Air Resources Board (CARB) were aligned every step of the way. In other words, the processes of the two federal agencies were intended to be aligned along the entire process.

EPA and NHTSA had, up until recently, been consistently transparent about the timeline for joint midterm evaluation: a proposed rule and proposed determination expected in summer 2017, with a final NHTSA and EPA rule by 1 April 2018.

Seemingly inexplicably, the EPA has changed course dramatically, and has issued its Proposed Determination: (a) far ahead of the previously-established schedule, (b) separately from NHTSA’s fuel economy rulemaking, and (c) with a truncated, less than 30-day comment period following publication in the Federal Register. In doing so, the agency has seriously prejudiced our ability to provide meaningful input on the Proposed Determination.

Global Automakers believes that the EPA’s acceleration of its proposed determination process so that it no longer aligns with NHTSA’s rulemaking was improper and contrary to the spirit and intent of the joint national fuel economy/GHG program. The EPA should issue its proposed determination at the same time that NHTSA releases its notice of proposed rulemaking on the MY2022-2025 CAFE standards (which we expect in the summer of 2017), and the two agencies should then jointly issue the final rule/determination. Doing so will ensure that the actions of both agencies are coordinated and harmonized to the greatest extent possible. Divorcing the rulemaking processes of the two agencies (as the EPA has done) raises the risk that each will come to different conclusions concerning the appropriate stringency of the standards and the specific compliance mechanisms automakers can employ to achieve the standards.

—Global Automakers letter to EPA

Procedural issues aside, the trade association said that the sheer volume of the material presented in the proposed determination and supporting technical document will make it difficult to provide substantive comment with the 30-day period.

We note that the 30-day comment period provided in the Proposed Determination is unprecedented in a regulatory action of this significance. For example, the proposed rule on the original joint fuel economy/greenhouse gas emission regulations promulgated by the EPA and NHTSA in 2009 provided for a 60-day comment period, which commenced after publication in the Federal Register (which was 2 weeks after the notice of proposed rulemaking was signed). The 2012 rulemaking also followed a 60-day comment period after publication in the Federal Register. EPA’s determination on the MY2022-2025 GHG emission standards is just as complex and significant as the prior rulemakings (if not more so), and there is no reason at all for such an abbreviated comment period.

—Letter to EPA


Account Deleted

The old auto industry is still behaving the same way. They have not learnt anything. They give a dam about the health of ordinary people and about the habitability of the planet in the future. As long as they can make more money for themselves now to hell with future generations and to hell with current air pollution. Wealthy people can get filters on their houses and escape unhealthy air. They have no empathy. Shame on them.


It's not as you depict. First, business will always build product the sells. If consumers wanted and would pay for all that you post, the car companies would have been eager to provide the product. Note: the petroleum industry should not be included in this, because gov't did not support competing fuel markets and let the industry monopolies a critical life giving commodity. The first priority of gov't should be to maximize the mature marketplace with competition forces and lean to empowering private citizen's enjoyment and small business strength.

I do think there is a disconnect with citizens understanding or education of such matters. In simplistic terms one could say cleaner is better and shame on anyone who opposes EPA efforts to regulate everything. But within reality it's not that simple. Always a trade off or compromise. I do think it is a mistake to utilize regulations that fisticuff an entire industry to some unelected bureaucrat wishes. However, it would be good if the agency were to continue to publish data on progress and problems.

I do think it's a mistake to regulate international corporations without international agreements. California, for example, has an especially wasteful go it alone regs. If they cooperated with feds and states a better coordinated plan of action would ensue. Same with standardizing regs across the pond.

Their is a principle studied and somewhat proven that typically 30% of the control effects 70% of the value. That our human nature once given the power can't simplify and that over time we construct monsters that can't self correct, simplify, lower cost, etc. The tax code, legal system, gov't in general, and regulations fit squarely within this problem. Citizenry has even been educated that if seeing a problem we need to run to our representatives to pass a new law. Actually, being an Industrial Engineer I've experience the cost of bureaucracy and improvements to be made by effecting simpler and lower decision making methods. People are not evil in general and if having a moral code quite capable of improving their own job. Automakers, probably lay within the best position to make value decisions that would improve the environment. Meaning, Law Makers may only need to scribe a time line and basic guidelines of improvement and leave the rest to the industry. If a proven trouble maker (violator) is found to be the mix, yes, they should be held to criminal law just like a bank thief.

Account Deleted

I hear you on simplification. EPA could do a better job by using sustainability mandates instead of complicated and very costly to monitor regulations on emissions. The goal is 100% sustainable products. So use sustainability mandates starting with 5% of all vehicles sold to be zero emission and growing to 100% of all vehicles sold to be zero emission by 2030. That is most achievable.

After that date no more new gasser or dirty diesel engines. Fine non-compliance with 10,000 USD for each car sold in non-compliance and allow trading of compliance credits among automakers so that automakers in over compliance like Tesla can sell their credits to the highest bidder. You can skip all the co2 regulation on that one. Also do it for the electric generation industry. By 2035 all power plants must be 100% emission free or they will have to pay, say 10 cents, per kwh produced that come from non-zero emission plants.

EPA will have to maintain its air pollution regulation and tighten it further. Without it we will all die many years prematurely from air pollution like they do in China and India on a massive scale. With the sustainability mandates 100% effective after year 2035 all non sustainable products will be banned out of the market. No more air-pollution and that legislation could go away also with regard to power plants and vehicles. Very simple very cost efficient.

Dr. Strange Love

Ban all Electric Utilities that generate Dirty Electricity.

Bio-Fuels are the Future. Amen.

When CARB and Ninnies have nothing more to Whine about in our clean fuels future, they will Re-Direct their attention to Fungus and Mold.

Account Deleted

Trump has a vision about making America great again and who can argue with that. However, the way to do it is to replace oil, gas and coal with renewables and fusion nuclear and to end the use of all unsustainable products like gassers, dirty diesels and fossil fuel power plants. Without such a strategy America will end up like a polluted and backward dump where nobody wants to spend their life.

There are a lot of jobs in a sustainability strategy. Tesla has created about 35,000 new and mostly US jobs producing sustainable products and Tesla is growing fast employing about 1000 additional people every month. And Tesla is barely getting started.

We need more companies like Tesla on this planet and this is why it is very important to tell the old auto industry that they need to change in a big way because what they currently do and lobby for is morally wrong and is hurting and killing millions of people prematurely every year. Moreover, left uncontrolled the old auto industry’s unsustainable products will cause a massive and extremely dangerous out of control warming of the planet that could raise see levels by as much as 70 meters (216 feet) if both poles melt completely. Not to speak of a nearly complete extinction of all the plants and animals we know today. We are unfortunate on a course to make the entire planet a nearly lifeless wasteland for future generations. To stop that from happening is a case worth fighting for and that is why we need to push every day for the old auto industry to wake up and admit their moral duty to make sustainable products.



Trump's appointment to the EPA thinks environmental issues should be at the state level. I am looking forward to seeing the Cuyahoga river burning again. Bring back the good old days.


"EPA will have to maintain its air pollution regulation"
An Oklahoma guy has been selected to run EPA who sued EPA.
He is a Global Warming denier, this is an IN YOUR FACE insult.
If people wondered about taking it literally, here you ARE.

Account Deleted

I know he is a pollution lunatic and Trump’s worst decision / pick to date. He denies the scientific consensus because he probably believes he got his point of view directly from the almighty divine himself. He risks polarizing the US so much that some states will go for independence.

On the other hand, much more pollution will result in more protest and higher demand for Tesla’s solar roof. The less the government do the more many private people will feel they need to do to even it out. Tesla will start sales of their new solar roofs this coming summer. Also if the federal tax benefits for EVs ends is terminated it will only benefit Tesla as they are soon running out of this subsidy that is limited to 200,000 cars per manufacture. Only Tesla’s competitors are getting it on their lousy compliance EVs.

Dr. Strange Love

Time will tell. Mother Nature can get real mad. Trump's pick to head the EPA understands this.


Good post, SJC.

Time may tell, Dr. Strange, but often only after it's too late and the damage has been done. Smart people anticipate and head off crisis' before having to deal with the catastrophic consequences.

What goves you any confidence that Scott Pruitt will be an effective advocate for environmental integrity and quality?


We can not wait for the damage to be done,
it must be fought hard from the first day onward.


The effective remedy is not to max out the EPA power. This is backwards thinking. Citizens are the power for change if and when they think it is in their best interest. Business employees and managers are citizens. They decide and work the same as us. They are intelligent and not the evil profiteers as some would portray.

So, in general our country needs solutions. We need good engineering skills and not just more political mojo to force gov't to our thinking or desires. Meaning in general we are the least qualified to know or understand what the compromises should be or the path to take. At best we can just motivate the masses to be more concerned and urge them to spend more of their money on such solutions. Every time I read a simplistic article of "free" wind or solar power I cringe. Same with those that claim battery power is the solution. It is never that easy of a solution and it isn't just a matter of forcing your will upon politics. It is a sleeve roll up of heavy lifting, education, financing, and engineering skills. The proletariat class has many a thought, but we have to be careful to value the worthiness. "Off with their heads".

Dr. Strange Love

ECI. I have No Confidence in Trump's EPA Head. Just saying he is Not stupid. He is a Crony of the Oil Industry. He has only one faith, and that is the "All Mighty Dollar".

I agree that we cannot wait, and we must all act responsibly. We cannot be blind to the Facts about the Cleaniness of All energy sources, including "Grid Energy". Facts are Facts.

Drive as Little as Possible, Air Dry your Cloths if Possible, etc., etc. .... Be a good steward of what Mother Earth gives us.


Our best, and only, firewall to all of this right now is CARB. They have their special status outside the EPA and can do what they want.

The car companies are fooling themselves because they still have to deal with California plus the other states who follow their lead...which includes New York among others. They control a huge part of the market for new cars in America and the auto makers have to deal with them. And other countries have similar standards coming so they have to deal with that.

And at the end of the day, there's a good chance that Trump won't make it past 4 years. If a Democrat comes into power in 2020, they'll be screwed royally trying to recover if they change plans now.

Of course, these morons have proven time and again that they are stupid. It takes 4-5 years to bring a new car to market. If they design now for a car coming out in 2020 or 2021 that will have to fight CARB/New York regulations AND a new President eager to reverse Trumps disasters....yeah, they'll still try it and be screwed later. Sigh.


This sounds familiar. In the 1970, I was convinced that Detroit spent more money on lobbying against emission standards than they did on engineering to meet the standards. In the end, they met all of the requirements....but because of their foot-dragging and focus on applying political pressure, they produced lousy, almost undrivable cars. In the meantime, the Japanese met all the requirements and scoop up major market share from the Detroit boys. Here we go again?


You called it, Fasteddie.

DaveD, I have held fast to the same thought - CA/section 177 states will hold the line and represent 33% of US sales, too much to feed with gimped compliance cars as the ZEV mandate ratchets up and the pendulum threatens to swing again in 2020.

I share you ur optimism that DJT won't make it though his first term. "Temperamentally unfit" does not begin to describe the yawning chasm that is his lack of fitness for duty.

Dr Strange, thanks for the clarification.

Account Deleted

DLS there is no need for an ascetic lifestyle if we only produce sustainable products like Tesla. In that case we can spend as much as we desire without destroying anything. The problem is only solved if the non-sustainable products are removed from the market by sustainability mandates. Using less non-sustainable products, like burning half as much fossil fuel, will only delay the global warming destruction of the planet. It will not stop it from happening.

Also biofuels are not sustainable or scalable. They create air pollution but they at least can be made co2 neutral. Also growing biomass in volume requires large natural and bio diverse habitats to be destroyed. This is obviously not sustainable either. Tesla is making it more clear every year that there are feasible alternatives that are cost effective and that does not pollute and that are sustainable. We just need more and bigger Teslas and this planet we be just fine.


More and bigger TESLAs are growing fast in China, Japan, So-Korea and EU. Many more, better, BEVs, lower cost batteries, FCs, Electrolysers, e-motors, controllers etc will be built in the above stated countries than by TESLA in the next 10 years.

The race to practical ADVs is far from being over. TESLA is not the only leader. Many other EU, Japan, China and So-Korea manufacturers with deep pockets will soon have their own ADVs.


"First, business will always build product the sells."

Flat out false. Businesses sell what they can get people to buy.

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