October 20, 2023 Energy and Environment

Comments to NHTSA - MY 2027-2032 CAFE Proposal

We submitted written comments to NHTSA on its proposed Corporate Average Fuel Economy standards for passenger cars and light trucks (model years 2027-2032).

We made these points:

  • The best policy to sustain an EV transition would be a return to a single national standard to reduce carbon in transportation. The U.S. has one vehicle fleet and should have one national standard.
  • Conflicting and overlapping rules are complex and increase costs without corresponding benefits. Manufacturers need aligned standards between the three federal agencies and the state agency regulating vehicle tailpipes.
  • We’re concerned NHTSA’s consideration of battery electric vehicles in developing its proposed standards, despite statutory prohibitions, combined with the Department of Energy’s proposal to devalue the fuel economy of electric vehicles by 72 percent, will result in serious misalignment, distracting manufacturers’ attention and resources from the EV transition.

That this proposal will also result in record civil penalties for non-compliance is a tacit admission by the administration that the standards aren’t achievable.