NACAA Comments on Proposed Determination for MTE

December 23, 2016 – NACAA submitted comments to EPA Administrator Gina McCarthy on her November 30, 2016 Proposed Determination that existing greenhouse gas (GHG) emission standards for Model Year (MY) 2022-2025 light-duty vehicles (LDV) remain appropriate.  The Administrator’s Proposed Determination follows a comprehensive Midterm Evaluation (MTE) required under a 2012 EPA-NHTSA rulemaking establishing GHG and fuel economy standards for LDVs to assess whether the “out-year” GHG standards included in the rule (those for MYs 2022-2025) are still appropriate based on the latest data and information or whether they should be more stringent or less stringent.  In the comments, NACAA supports the Proposed Determination that the emission standards currently in place for MYs 2022-2025 remain appropriate under section 202(a)(1) of the Clean Air Act.  The association “applauds the robust technical analysis behind the Proposed Determination” as well as EPA’s thoughtful and deliberative consideration of, and response to, public comments on the draft Technical Assessment Report released earlier this year.  NACAA also commends EPA for the comprehensive explanation of the basis of the Proposed Determination including the thorough presentation of the updates made to the previous analyses, which NACAA believes “makes an exceptionally clear and strong case that the MYs 2022-2025 standards remain appropriate.”  Further, NACAA concurs with EPA’s statements that the MY 2022-2025 standards are feasible and cost effective and that the auto industry is thriving and meeting the standards more quickly than required, as well as with the conclusion that the design of the national program, as established in the 2012 rule, provides flexibility to allow consumers to purchase the vehicles of their choice while ensuring substantial environmental benefits from all vehicle classes and weights.  In addition, NACAA notes EPA’s conclusion that the net benefits of the program far exceed the costs.