December 27 2016

Honorable Gina McCarthy
Administrator, U.S. Environmental Protection Agency
USEPA Headquarters
William Jefferson Clinton Building
1200 Pennsylvania Avenue, N. W.
Mail Code: 1101A
Washington, DC 20460

 EPA DOCKET ID No. EPA-HQ-OAR-2015-0827 (via

SUBJECT:    Comments on EPA’s Proposed Determination on the Appropriateness of the Model Year 2022-2025 Light-duty Vehicle Greenhouse Gas Emissions Standards under the Midterm Evaluation as Noticed in the December 6, 2016 Federal Register (81 Fed. Reg. 87927)

Please accept these comments and place them in EPA DOCKET ID No. EPA-HQ-OAR-2015-0827 regarding my support for EPA’s “Proposed Determination on the Appropriateness of the Model Year 2022-2025 Light-duty Vehicle Greenhouse Gas Emissions Standards under the Midterm Evaluation”.

Climate change is one of the biggest challenges we face today. Record levels of carbon dioxide (“CO2”) and other greenhouse gases (“GHGs”) are being emitted through the combustion of fossil fuels. To make matters worse, natural systems such as rainforests that might otherwise absorb some of the increase in CO2 are being decimated every day. According to EPA, CO2 emissions from transportation account for over a third of the total CO2 emissions from the U.S. Of those emissions, 60% are from light duty cars and trucks. Hence, reducing emissions from these vehicles is critical to reducing anthropogenic emissions of CO2 from the U.S. (See Figure 1.)

In 2012, EPA worked with industry, academic, and regulatory experts to establish the proposed CAFE standards for Model Year (“MY”) 2022-2025. EPA committed to reviewing the proposed standards by 2017. The assumptions used, the technologies considered, the economics, effectiveness, efficiencies, and consumer preferences were all properly considered by EPA. Following a detailed assessment and evaluation, EPA has correctly determined that the MY 2022-2025 standards are technically feasible and economically achievable and thus the determination of CAFÉ standards should stand.

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.According to EPA, 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. I support the EPA in their efforts to increase CAFÉ standards and to reduce emissions of CO2 and other GHGs.





The Professing Professor


C:        Christopher Lieske,

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