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Penn Environmental Law Project Comment Cited in Historic Auto Emissions Rule

April 02, 2010

Of the more than 130,000 comments submitted on the greenhouse gas auto emissions rule, the University of Pennsylvania Law School Environmental Law Project’s* comment was singled out and discussed several times in yesterday’s final rule document, issued jointly by the National Highway Traffic Safety Administration (NHTSA) and the EPA. The rule sets the first-ever national greenhouse gas emission and fuel economy standards for all new passenger cars and light trucks sold in the United States. It is a key piece of the Obama Administration’s climate and energy agenda.

The Environmental Law Project’s comment explained the proposed rule and evaluated its relative costs and benefits, concluding:
It is critically important that the United States adopt policies that address global climate change and reduce its oil consumption. These proposed rules constitute a strong and coordinated federal fuel economy and GHG program for passenger cars and light trucks. Since the proposed rules will provide regulatory certainty and consistency for the automobile industry while reducing greenhouse gas emissions based on technologies that can be incorporated at reasonable cost, the proposal represents an important effort to improve fuel economy and reduce greenhouse gas emissions.
 
However, the proposal is not without its flaws. Namely, the proposal fails to gradually reduce the disparity between efficiency requirements for 2012 and 2016 MYs. Additionally, the policy does not create mechanisms whereby minimum reductions are ensured, nor does it address the fiction of “zero emissions” electric vehicles. Finally, the proposal fails to make a complete lifecycle impact analysis, and therefore may overlook deleterious consequences of its implementation. Thus, the proposal, while timely, would benefit from an enhanced discussion of these among other potentially problematic omissions.

Read the entire comment at regulations.gov. 

*The Environmental Law Project is a voluntary group of law students at the University of Pennsylvania Law School. The views expressed in the Project’s comment are neither endorsed by nor submitted on behalf of Penn Law or the University of Pennsylvania.