Keep working on Kavanaugh here.
Action #1 – Stop the proposed rollback of CA Clean Car Standards
The Trump-controlled EPA announced that they will be abandoning the long-term fuel economy standards for passenger cars and light trucks for 2022-2025, freezing everything at 2020 levels. Worse, but not unexpected, they are trying to revoke California’s Clean Air Act Waiver that allows us to set our own air quality standards along with our own fuel economy standards. That would force us, along with 13 states (and DC) that follow our lead on fuel economy, to use less stringent federal standards for polluting emissions and fuel efficiency. Both proposed provisions would significantly undermine our efforts to control automobile emissions, protect our citizens’ health and slow dangerous climate change.
Oppose the rollback of key federal clean car standards and the elimination of California’s ability to set more stringent standards.
- Comment here by Due Oct 23 2018, at 11:59 PM ET
- Read the rule here.
- Read comments here for inspiration. Borrow what you like but try to adjust to use your own voice. Samples are included at the bottom of this post.
- Go to the hearing! The closest is September 24th, 2018 at The Grand, 1401 Fulton Street, Fresno, California 93721. The hearing will start at 10 a.m. local time and continue until 5:00 p.m. or until everyone has had a chance to speak. If you would like to present oral testimony at one of these public hearings, please contact Kil-Jae Hong at NHTSA at least ten days before the hearing.
Action #2 – Copy your comment to your legislators!
The transportation sector is now the largest greenhouse gas emitter in the United States. That’s why enforcing strict fuel economy standards would be a particularly effective method to reduce our contribution to global climate change. Vehicles are also the largest source of air pollution. Particulate matter is singlehandedly responsible for up to 30,000 premature deaths each year, so reducing what comes out of tailpipes would save lives.
So, like all good murder mysteries, who’ll profit the most if this important regulatory protection is killed off?
Here’s a hint:
“…large corporations are…engaging in increasingly environmentally exploitative behaviour by obscuring the link between endless economic growth and worsening environmental destruction.” (forbes)
For those who always flip to the last page of a mystery, the answer is “oil and gas companies!” (In the graph below, CAFE stands for Corporate Average Fuel Economy.) “Under Obama-era standards, fleetwide fuel economy rises from 32 mpg today to between 44 and 46 mpg in 2025, depending on the price of oil. Without updated standards after 2025, fuel economy improvements level off at lower oil prices and grow modestly at higher oil prices. If the Administration proceeds to freeze CAFE standards at 2020 levels, the fleetwide average reaches only about 38 mpg in 2025 under AEO 2018 reference oil prices, 36 mpg in a low oil price environment and 42 mpg under high oil prices.” (Rhodium Group)
The original EPA program would save more than 3 million barrels of oil a day, equivalent to the U.S. imports from both the Persian Gulf and Venezuela combined. The current EPA, stuffed full of gas and oil industry insiders, will certainly get this “problem” fixed.
If you guessed the car industry, well, they started it. And it will help the dirtiest ones limp along, but not for long. Overall, America is already behind Japan, Korea, the European Union, and China on creating efficient fleets, taking a lazy slide into international uncompetitiveness. These are the conditions that led to the original auto industry crises bail-out by Obama and their subsequent vows to make more efficient cars. However, carmakers, such as Tesla, Honda and Toyota, who’ve already created efficient products, have sold credits based on beating the current emission standards. These will become less valuable under this new regime, penalizing them for doing the right thing. Good read on the industry’s machinations here.
If the oil, gas and car companies are the murderers of this story, who are the victims?
Our wallets: Like all regressive taxes, the Trump administration’s attempted repeal of fuel efficiency standards are a direct attack on the poor and middle class. Debbie Sease of the Sierra Club speaks out in this great short video. According to Margo Oge, the former head of the EPA’s Office of Transportation and Air Quality, the fuel savings alone, if the EPA stays on its original course through 2025, would add up to $1.7 trillion back in the pockets of consumers and $140 billion in 2030.
Word problem example: Under the original rule, by 2025, the average vehicle would use roughly 401 gallons of gasoline to drive a typical distance of 15,000 miles in one year. Under the Trump proposal freezing 2020 standards in place, efficiency would decrease and the car would require 507 gallons for the same distance. Assuming a gasoline price of $3 per gallon, how much more would we have to pay annually under Trump’s plan? (Answer – $318).
Adding together our direct costs and fuel costs passed on by companies, the lowest-income families benefit the most from the original standards, saving 2% of their estimated annual income, while middle-to-high-income families already save up to $1000 per year. This is literally theft from us to pay off the producers of gas and oil and car manufacturers.
Our environment: The Union of Concerned Scientists estimates that the Obama-era standards would avert 570 million metric tons of greenhouse gas emissions by 2030, equivalent to stopping 140 typical coal-fired power plants for a year. In contrast, the Rhodium Group , in the graph below, shows their estimates of the emissions that will result from freezing the EPA program.
The Trump-EPA’s rush to prop up markets for gas and oil with inefficient cars will also harm our land and water resources.
Our economy: A June 2012 study by the Blue Green Alliance finds that the 2017-2025 standards alone would create an estimated 570,000 jobs (full-time equivalent) throughout the U.S. economy by 2030, including 50,000 in light-duty vehicle manufacturing (parts and vehicle assembly). Also, most companies want to see continued advancement in fuel efficiency to help their own bottom line. Corporations like FedEx and UPS spend literally billions of dollars on fuel, so they care deeply about using new technologies and improving fleet efficiency. In fact, the entire economy depends on increasingly efficient movement of goods and people. CEOs from some of the biggest food businesses have spoken out about threats to their supply chains from volatile energy prices and a changing climate. The EPA analysis pegs the net benefits to society of the higher standards at $100 billion.
Our kids and vulnerable populations: 30,000 people die prematurely every year from diseases caused or exacerbated by particulate pollution, such as asthma, lung and bladder cancer, and heart disease. That’s approximately ten 9/11 attacks, every year. In addition, kids are being harmed, permanently, from the air they breathe. California’s aggressive efforts to reduce air pollution have had measurable effects, but there’s a lot more to be done.
In a landmark research paper published in southern CA, scientist reported that kids from the region are breathing better than they did in in 1994, and the percentage of kids with abnormally poor lung funtion dropped by more than half.
Anyone who wants to avoid dementia: There’s a growing body of evidence suggests that exposure to air pollution can also harm the brain, accelerating cognitive aging, and may even increase risk of Alzheimer’s disease and other forms of dementia. In a new paper, Arizona State University researchers discovered that incremental exposure to fine particle pollution over the course of a decade leads to an increase in the chance that a person will be diagnosed with dementia. These devastating diseases costs Americans over $277 BILLION a year.
Common sense: Just ignore the Trump-EPA’s whole cost/safety concerns. It’s such nonsense, they have trouble keeping their own story straight. Trump’s EPA originally claimed that people will hold onto older cars longer because new, safer, complying cars would be more expensive. They also claimed that making cars more efficient will cause us to drive many more miles in lighter cars, so slowing down compliance will save a 1000 lives a year. However, later emails showed that their proposed regulation changes would actually INCREASE highway deaths by 17 people annually.
We’re fighting back.
We need to pay attention to these regulation sites and comment like crazy. Public shaming is really the only thing that seems to stop them. However, we are not fighting alone.
A coalition of 17 states and DC filed suit against the administration in May when it first announced its intentions to roll back the standards. They charge that it is acting arbitrarily and capriciously in tossing out Obama’s standards, which were the result of years of research, stakeholder meetings, and public engagement.
Great references for comments:
Stop the rollback of clean car standards and CA’s unique authority (indivisible Berkeley)
- New York Times
- Auto Safety (NYT)
- Washington Post
- Vox – Trump is freezing Obama’s fuel economy standards. Here’s what that could do.
- Vox – The EPA refuted its own bizarre justification for rolling back fuel efficiency standards
- Inside Climate News
- Union of Concerned Scientists – 8 Ridiculous Things in the Trump Rollback of Clean Car Standards
- Legal Planet
- Environmental Law at Harvard
- Washington Post – The Trump administration said weaker fuel standards would save lives. EPA experts disagree.
Sample Written Scripts:
Comment: I completely disagree with this rule change. We need much stronger and more aggressive fuel economy standards to address climate change, for the sake of future genrations!
Comment: This is a dangerous and irresponsible roll-back of stricter emissions standards. We need to address the impact of greenhouse gas pollution on future of Earth as well as on health and safety of people today. Do not pass this regulation!
Comment: I am deeply disappointed that these Trump administration had chosen to put short term profit for the oil industry over the long term health of the planet. We are walking on the edge of a knife with our environment already, and careless decisions like this endanger future generations. Climate change is real PERIOD. Reconsider this, please. This shouldn’t be a political decision; it’s just common sense.
Comment My grandson has asthma and we live in fear of his attacks. We all know, asthma continues to rise in our kids, the medicine they take is expensive with many side affects. I now have asthma at age 55. Is it worth the health of our country and world to line the pockets of Big Oil? Reprehensible. Money over people is not the way. Do not do this to our children, theyve yet to have a chance to live.
Comment: Climate change is real. We need to reduce our use of fossil fuels.
Very few people are going to want cars that not only pollute, but that also have lower fuel standards and get less gas mileage. (and cost MORE!) The automobile industry needs a goal to work toward. Its in no ones interest to move the goalposts.
Clean air is important for public health. Clean air is important for everyone.
PEOPLE OVER PROFITS! PROTECT THE ENVIRONMENT! CLIMATE CHANGE IS REAL!
Comment: Reduction in emissions should be a top priority for a cleaner environment and lower emissions vehicles greatly increase mileage per gallon, which is attractive for consumers and reduces our dependence on fossil fuels. This policy is absurd and shameful that the EPA is supporting and shows a clear disconnect with the scientific community. Science is not something that should be in the political realm and the original standards should be adopted and adhered to with strong conviction and not pushed aside with nonsensical safety concerns and scare tactics.
Comment: This country should be looking forward, not backward. I was born in coastal Massachusetts and live in NYC. Both places have been disproportionately affected by weather events that are likely related to climate change. The taxpayers foot the bill for these disasters. The science of climate change is undeniable; we have to take steps to address this phenomenon, including by decreasing our use of fossil fuels. Car efficiency standards in the United States have been slow to improve. A roll back would introduce volatility in the car market (even car manufacturers are opposed!) and threaten the future of my child and millions of children around the world.
Comment: I live in California and strongly oppose the proposed withdrawal of California’s ability to set pollution standards that are more stringent than federal standards. This ability has been in effect for 48 years, has never been withdrawn before. The state’s unique pollution problems are the result of geography and the movement of goods from California’s ports through the state by truck and rail to consumers across the country. It is not unreasonable for the rest of the country to support the previously issued standards which take California’s needs into account, since the country benefits from receiving the goods transported through the state.
The US transportation sector is the largest contributor of greenhouse gas (GHG) emissions in the country, and vehicles are the largest source of air pollution. EPA’s duty to protect public health and welfare means taking urgent steps to reduce vehicle emissions, including GHGs, to the greatest extent possible. Failing to take the strongest possible action now will ensure escalated global warming and major loss of life and health. Global warming has already set in motion changes that will further accelerate warming. Increasing emissions cannot be justified based on science, cost, or available technology.
Comment: I do not support the proposed changes that DOT and EPA are proposing in the “Safe Affordable Fuel-Efficient Vehicles Rule.”
Why wouldn’t we want to continuously seek improvement in fuel efficiency and a decrease in emissions? Transportation is our country’s greatest source of greenhouse gas emissions. These emissions are driving climate change. Climate change is affecting weather patterns, food production, availability of water, and temperature to name just a few of the impacts it is having. These in turn directly impact the health of human species and other species. The actions we take in this country to affect climate change will either help or hurt both locally and globally. These statements have been proven by science. Failing to leave in place the current requirements for greater fleet average fuel efficiency at 47 MPG by 2025 will have more detrimental effects upon health and longevity than the unsubstantiated claim in the rule proposal that greater fuel efficiency will lead to more deaths.
The federal government should continue to allow California and other states that choose to do so the right to establish higher standards for fuel efficiency and controls on conventional air pollution. States should not be allowed to go below the minimum standards established by the federal government. States, in this case, face unique aspects of geology and weather patterns which may worsen the effect of air pollutants on the inhabitants of that state. Not allowing a state to take the stronger measures required to help protect the health of the people in that state is contradictory to the title of this proposed rule. Do not remove the waiver the federal government has recognized for California for many decades – leave it in place as it makes sense.
Bottom line – do not go backwards – it will hurt us.
Comment: The transportation sector is the largest contributor of greenhouse gas (GHG) emissions in the United States, and vehicles are the largest source of air pollution. EPAs duty to protect public health and welfare means taking urgent steps to reduce vehicle emissions, including GHGs, to the greatest extent possible. The current proposal will increase emissions. Failing to take the strongest possible action now will ensure escalated global warming and major loss of life and health. Maintaining the standards developed and agreed to by the U.S. government, auto makers and the state of California in 2012 for model years 2021-2026 (previously issued standards) is justified by thorough analysis and public input. Global warming has already set in motion changes that will further accelerate warming. Increasing emissions cannot be justified based on science, cost or available technology.
The agencies current proposal appears to substitute assumptions about consumer behavior – that consumers will keep their older, less safe cars longer – and manufacturers good faith – they will over-comply with less stringent standards – for scientific and analytical rigor. It is not clear that consumer behavior is a legally defensible criterion for determining health-based pollution standards, and it is clear that manufacturers have never increased fuel efficiency or reduced pollutants without regulation. The proposal asserts that consumers want bigger cars, yet the government does not allow unrestricted sales of opioids just because many consumers want them. Public health and welfare are the most important criteria. Furthermore, consumers desire for more fuel efficient vehicles that save money at the pump was not sufficiently considered, and the new estimates of fuel efficient vehicle costs are not substantiated.
The proposal does not take into account EPAs internal analysis showing that the rollback would cost jobs and have a net negative economic impact.
While the consumer-based analysis of the National Highway Traffic Safety Administration states that maintaining the current standards will prevent vehicle accident deaths, EPAs experts, according to information in the docket, conclude that there will be more accident deaths if the proposal goes into effect. Even if the proposals unsubstantiated analysis were correct, air pollution causes far more deaths, and the long-term analysis of the deaths and illness caused by storms, fire, flooding, heat and drought resulting from climate change, along with lives saved by reducing other tailpipe pollutants must be weighed more thoroughly.
I live in California and strongly oppose the proposed withdrawal of Californias ability to set pollution standards that are more stringent than federal standards. This ability has been in effect for 48 years, has never been withdrawn before, and will be legally challenged. Withdrawal would create an unnecessarily uncertain future for auto manufacturers. The states unique pollution problems are the result of geography and the movement of goods from Californias ports through the state by truck and rail to consumers across the country. It is not unreasonable for the rest of the country to support the previously issued standards which take Californias needs into account, since the country benefits from receiving the goods transported through the state.
California will be legally justified in defending its waiver. The court has previously allowed EPA to identify GHGs as pollutants that may be regulated under the Clean Air Act (CAA). California clearly meets the compelling and extraordinary criterion for allowing the waiver. As a coastal state with desert ecosystems it is on the front lines of climate changes impacts: sea level rise and worsening drought, heatwaves and wildfires. Limiting GHGs also reduces other harmful pollutants, which is a clear purpose of the CAA. The proposals assertion that the Energy Policy and Conservation Act (related to fuel economy) preempts Californias ability to set stringent auto emissions or fleet requirements for zero emission vehicles is not supported by Acts text and has already failed in court.
The auto makers that were bailed out with government (taxpayer) funds during the recession are the same companies that have the lowest average fuel economy. The proposal would unfairly benefit them and penalize companies that have invested in electric vehicles. It is unfair for them to ask for regulatory relief now, when reducing pollutants including GHG is more urgent than ever. Science and technology both show that it is possible to comply with the previously issued standards.