NACAA Comments on EPA-NHTSA Proposed SAFE Vehicles Rule

October 26, 2018 - NACAA submitted comments to EPA and the National Highway Traffic Safety Administration (NHTSA) on the agencies’ joint proposed SAFE Vehicles Rule.  In the comments, NACAA tells the two agencies that it “opposes this deeply flawed proposed rule” and articulates the association’s concerns and disagreements, particularly as they relate to 1) EPA and NHTSA’s proposed conclusion that the greenhouse gas (GHG) emission standards for Model Years (MY) 2021-2025 and augural Corporate Average Fuel Economy standards for MYs 2022-2024 included in EPA’s and NHTSA’s joint 2012 rule are no longer appropriate, 2) EPA and NHTSA’s proposal to preempt California’s authority under Section 209 of the Clean Air Act (CAA) and other states’ rights under Section 177 of the CAA by withdrawing California’s waivers for the GHG and Zero Emission Vehicle components of the state’s Advanced Clean Car program and prohibiting other states that adopted those standards from enforcing them, 3) the analyses that underlie the proposal, which were conducted by NHTSA including for the portions of the rule that are strictly under the purview of EPA and 4) provisions that would eliminate credit flexibilities.