If you are concerned about climate change and air pollution, here is your chance to support the U.S. Environmental Protection Agency (“EPA”) in their effort to reduce the emissions of Greenhouse Gases (“GHGs”) from cars.

EPA is trying to move fast to finalize a rule mandating a pretty dramatic increase in the corporate average fuel economy (“CAFE”) standards for automobiles and light duty trucks (e.g., cars, SUVs, regular size pick-up trucks, etc.) The fear is that if the rule isn’t finalized before Trump takes office, it will never be finalized.

So after Trump won the election, EPA accelerated their schedule for finalizing the proposal they first came up with in 2012.

Industry will sue EPA over this rule. Congress will pressure them to withdraw the rule. The only hope that EPA has to preserve the rule is to show that the public supports the rule.

You can submit a comment on the rule to EPA’s Docket. It does not have to be technical. There is some suggested language here. But frankly, using your own words will be just fine.

If you are interested in the more technical aspects of the rule and the GHGs that will be reduced, I have provided some background below.



CAFE standards were enacted by Congress in 1975 to reduce energy consumption by setting increasing standards for fuel economy by cars and trucks. The standards were initially increased up through about 1990, but were then stagnant until President Obama came into office.

Under President Obama, EPA proposed dramatic increases in CAFE standards as well as dramatic reductions in GHG emissions. In the 2012 rulemaking, EPA agreed to a ‘mid-term’ evaluation of the proposed standards. That mid-term evaluation was to take place by 2017. Rather than wait and allow the Trump administration to withdraw the rules, EPA is finalizing them.

These rules will double fuel economy and cut GHG emissions in half by 2025. This is a reduction of 6 Billion tonnes of CO2 and 12 Billion barrels of oil.

The automobile industry worked with EPA on the development of these standards based on the information they had in 2012. And in 2012 they knew they could meet these new standards. Nothing has changed to make it more difficult for the auto industry to meet these standards and therefore they should be finalized.

In fact, if anything, there are a wider range of technologies available to meet the 2022-2025 standards. Advanced technologies are expected to continue to be developed to assist companies in meeting the standards. The standards were developed with consumer preference in mind and thus the mix of cars and trucks has been taken into account in the development of the standards.





Up until Obama, the CAFE standards had been stagnant for years.





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