The Consumer Federation of America CFA submitted comments in response to the National Highway Traffic Safety Administration’s (NHTSA) on its proposed corporate average fuel economy (CAFE) standards for light-duty vehicles. NHTSA’s proposal is in keeping with President Biden’s commitment to revisit the previous administration’s rollback of clean car standards. While this proposal improves on the Trump Administration’s gutting of the Obama-era vehicle standards, it contains several flaws in its analysis of the most stringent option, referred to as Alternative 3. By correcting these flaws, CFA contends in its comments, consumers could save an additional $28 billion.