Motor Vehicle Fuel Efficiency

CFA Offers Comments to EPA Supporting the Proposed “Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards” Rule

In comments to the Environmental Protection Agency, CFA has outlined the evidence for generally supporting the agency’s proposed revision to 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards.

Below is a summary of our comments which provide our analysis of key aspects and reasons for supporting the EPA’s proposed revisions to the SAFE 2 rule:

  • The Trump administration, reintroduced over two dozen (28) errors in its SAFE 2 rule which had previously been corrected. By reintroducing these errors into the rule, the benefit-cost ratio calculated by CFA of the standard in place before SAFE 2 to be 5-to-1, but subsequently has been reduced to a mere 1.1-to-1.  By reversing many of these errors through this proposed rulemaking and taking into account key changes, the benefit ratio has risen to 2.2-to-1.
  • The Trump administration unjustly rolled back the previous 2011 standard, which was in good compliance with both the Administrative Procedures Act principles and required by Congressional statute. In fact, the continuous advancement of standards, which the Trump administration rejected, was mandated by the statutes.
  • In the EPA’s proposed revision to the SAFE 2 rule, it has corrected numerous errors made by the Trump administration. These corrections include fixing the valuation of greenhouse gases and other pollutants, returning the rebound rate to 10 percent, lowering the discount rate and updating the availability of technologies.
  • One of the largest changes from the current SAFE 2 rule involves vehicle safety. By irrationally doubling the rebound rate, the Trump administration projected increased fatalities by 75 lives. The Administration also underestimated the increasing crashworthiness of vehicles.  While the proposed SAFE 2 rule revisions do correctly establish that vehicles are becoming lighter to meet the standards, the rule rightly points out that vehicles are more crashworthy compared to just a decade ago when the standards went into effect.

While the EPA’s proposed rule has made strides in correcting the dozens of fundamental errors made by the Trump administration, CFA urges the current administration to vigorously support the transition to electric vehicles (EVs). Given the current trajectory of fuel economy standards, over 100 million gasoline vehicles will still be sold before the full transition to EV’s. Stronger fuel economy standards are just one way to help spur the transition, as setting high standards on the gasoline part of the fleet will speed the adoption of electric vehicles. Additionally, with a significant amount of the gain in efficiency seen in traditional internal combustion (ICE) vehicles – both in vehicle design and operation – these may be applicable to the electric portion of the fleet as well.

Second, it is critical to close the remaining loopholes, especially those that could allow the automakers to “use” the electric vehicle part of their fleet to “relax” the efficiency of the gasoline-powered part. This trade-off must not be allowed.

Establishing a national goal of transitioning to an all-electric fleet while simultaneously accelerating the transition of the electrical grid to cleaner renewable sources is essential.  It is clear the current administration has recognized this and is working hard to move the country in this direction.

As our economic analysis shows, and the agency seems to agree, that these additional changes can be made with a net positive benefit-cost ratio.  The total cost of driving for consumers will go down, measured by the pocketbook savings.  Public health and environmental benefits will further increase an already positive benefit-cost ratio.  By fully embracing the transition to EVs, Americans of all income levels will be better off at the end of the changeover.

[1] The CFA website ( provides links to 140 pieces of testimony and reports published in the past ten years dealing with the efficiency of energy-using consumer durables divided roughly equally between appliances and vehicles.

[2]  Adding in fuel economy standards, which are governed by a structure of legal authority and administrative rules similar to that affecting appliances doubles the level of household expenditures and makes regulatory reform one of the largest consumer pocketbook issues for the Trump or any administration.

[i] Environmental Protection Agency, In the Matter of Proposed Rule to Revise Existing National GHG Emissions Standards for Passenger Cars and Light Trucks Through Model Year 2026 EPA-HQ-OAR-2021-0208.