Motor Vehicle Fuel Efficiency

Consumer Group Asks California to Stay the Course on Clean Car Standards

Testimony and Comments Delivered at Hearing Cites Consumer Support, Benefits, Longstanding States’ Rights and an Extensive Record of Evidence

Riverside, CA – At the California Air Resources Board (CARB) hearing today, a representative for the Consumer Federation of America (CFA) testifies in support of staying the course on advanced clean cars standards that benefit the lungs and pocketbooks of 113 million Americans:

Excerpt from testimony as prepared and delivered:

“California’s current standards are anchored in a joint agreement reached by automakers, Washington and Sacramento. And CFA urges CARB to stay the course. Because 12 other states and the District of Columbia have adopted California’s standards, your decision today will affect whether 113 million Americans will be able to buy cleaner cars, save money at the pump and breathe cleaner air.

Most importantly, consumers strongly support what the CARB has been able to accomplish. At CFA, our polling consistently shows that the overwhelming majority of Americans—Republicans and Democrats, from the nation’s heartland to the coasts—supports making cars and trucks run on less gas because it saves drivers money.  

Under the Clean Air Act, California and the other clean-car states have the right to set their own standards and protect their own air quality. This important right has been recognized for decades and has been protecting both pocketbooks and lungs ever since. 

The leadership of the Clean Cars states not only led the U.S. to standards that will enable automakers to compete in the global market, it opened the door to a whole new technology (hybrids).  The ZEV states are providing exactly the same function for electric vehicles.  It would be a huge mistake to roll back the standards or undermine this process, Which represents American Federalism at its best.”

In extensive written comments, CFA highlights the extensive evidence that supports pollution and fuel economy standards at the state and Federal levels:

“EPA’s Technology Analysis Report and Final Determination combined with the CARB’s Midterm Review, placed atop the massive original analyses in the National Program, constitute one of the most thorough examinations of automotive technology and market conditions ever conducted in a regulatory proceeding in the United States. Both these mid-term reviews arrive at the same conclusion, the current standards for 2022-2025 are technically feasible and economically beneficial. The standards will result in significant reductions in emissions of pollutants, including greenhouse gases and huge consumer savings. We fully support their conclusion.

The CARB Mid-Term Review attests to the coordination between it and the Federal agencies.  There is nothing surprising or nefarious in the three agencies with three different statutory obligation reaching conclusions at different times. 

The CARB was required to issue its report by the end of 2016. 

EPA had discretion as to when to reach its conclusion.   The record was voluminous and complete, so it moved forward with its determination.  By making its determination a full four years in advance, it was giving most of a redesign cycle, the time that the industry has always demanded.   EPA should not have re-opened the review. 

NHTSA was required to engage in another rulemaking, which would certainly consumer substantial time.  NHTSA will consume (waste) a substantial amount of lead time. 

Thus the fact that the three agencies acted on different schedules is not an indication of a failure to coordinate, particularly given the extensive cooperation that went into the preparation of two massive analyses.  Given the massive amount of analysis that led two of the three agencies to a conclusion strongly supported by the evidence, NHTSA bears a heavy burden of proof to arrive at a different conclusion.” 

Contact: Jack Gillis, 202-737-0766


The Consumer Federation of America is an association of more than 250 non-profit consumer groups that, since 1968, has sought to advance the consumer interest through research, education, and advocacy.