Tues – 10/23: They’re coming for our air. Deadline – Oct. 26.

LOS ANGELES: Downtown highrise buildings are shown cloaked in dirty air shortly after sunrise September 11, 2002 in Los Angeles, California. Although air quality in Los Angeles has improved in recent decades, smog levels remain among the nation’s worst. Numerous wildfires in the region have also contributed to Los Angeles’ air pollution problem. (Photo by David McNew/Getty Images)

While Congress is out, the lights are off in D.C., and our president is distracting us before the election with “scary migrants” and imaginary “middle-class tax cuts”…one type of GOP destruction is continuing to roll off the chutes with machine-like efficiency – the removal of rules protecting us and our environment from the rapacious greed of his new regime.

Action – Stop Trump’s proposed rollback of CA Clean Car Standards – Deadline Oct. 26, (this Friday)  11:59 ET

“There is no safe level of air pollution.” (Newsweek) (BusinessInsider) (LATimes)

“Air pollution is still killing people in the United States”  (time)

“…a growing body of evidence suggests that exposure can also harm the brain, accelerating cognitive aging, and may even increase risk of Alzheimer’s disease and other forms of dementia.” (Sciencemag)

We can’t stay on the sidelines as the administration tries to send us backward in time, before “climate change” was a household word, and the effects of air pollution on the human body were well known. Our state still has the “highest ozone levels” and “worst smog levels” in the country and the CA Clean Car Standards we enacted in defense have already had profoundly positive effects on the health of our children.

We are not going back. We’re not slowing down. 

New line of battle: Please submit a comment directly to the EPA, to oppose the rollback of key federal clean car standards and the elimination of California’s ability to set more stringent standards. Example scripts below. Background material at bottom.

Example scripts:

(Check here for more inspiration. Make sure you mix your comment up to match your voice. Exact copies will be culled.)

Comment: The proposal does not take into account EPA’s internal analysis showing that the rollback would cost jobs and have a net negative economic impact.

Comment: Rolling back EPA fuel mileage standards will cause increases in green house gas emissions, more deaths from increased pollution, and business uncertainty due to litigation that will be initiated by States that have stricter mileage requirements than the Federal Government. Please keep the standards as they are existing and allow States rights to protect their citizens even if the EPA does not fulfill its mission as environmental protection.

Comment: This just might be the most blatant example of bureaucratic chutzpah I have ever encountered. Climate change deniers have for decades blocked regulations to limit carbon emissions. Now that they are in charge of the EPA they think it’s time to admit that climate change is human-caused and will lead to catastrophic conditions by 2100, so the solution is to scrap any attempt to save the world because it’s now too late?! It’s time to double down, not abandon all hope. Giving up so that energy companies can make more profits is defeatism in the cause of greed.

Comment: Pollution kills. It damages the health of children, and reduces their intelligence. There is no reason to roll back car standards, and there are many reasons to strengthen them I strongly oppose the proposal to roll back clean car standards and infringe on the longstanding authority of states to protect their citizens from air pollution. Undermining these achievable, successful, and commonsense standards will allow automakers to manufacture dirtier cars that pollute the air and harm our health. History has shown that we can simultaneously reduce tailpipe emissions of air pollutants and make our cars more fuel-efficient, safer and cheaper. Much of that leadership has come from the states. Rolling back federal vehicle standards while taking away states authority to protect their residents is inconsistent with federal environmental and energy conservation goals. Americans deserve clean air. We shouldnt be rolling back the standards and safeguards that protect them.

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. EPA’s 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.

Comment: I strongly oppose the proposal to roll back clean car standards and infringe on the longstanding authority of states to protect their citizens from air pollution. Undermining these achievable, successful, and commonsense standards will allow automakers to manufacture dirtier cars that pollute the air and harm our health. History has shown that we can simultaneously reduce tailpipe emissions of air pollutants and make our cars more fuel-efficient, safer and cheaper. Much of that leadership has come from the states. Rolling back federal vehicle standards while taking away states authority to protect their residents is inconsistent with federal environmental and energy conservation goals. Americans deserve clean air. We shouldnt be rolling back the standards and safeguards that protect them.
The clean air standards were based on sound science and were written in conjunction with and and agreed to by the automotive industry. Nobody voted for a republican official because they wanted to get sick and die. Our health should not be sacrificed for political gain.

Comment: 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.

Comment: While the consumer-based analysis of the National Highway Traffic Safety Administration states that maintaining the current standards will prevent vehicle accident deaths, EPA’s experts, according to information in the docket, conclude that there will be more accident deaths if the proposal goes into effect. Even if the proposal’s 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.

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, and will be legally challenged. Withdrawal would create an unnecessarily uncertain future for auto manufacturers. 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.

Comment: 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 change’s 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 proposal’s assertion that the Energy Policy and Conservation Act (related to fuel economy) preempts California’s ability to set stringent auto emissions or fleet requirements for zero emission vehicles is not supported by Act’s text and has already failed in court.

Comment: 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.

Comment: With the United States as a top contender for greenhouse gas emissions, we are responsible for several of the environments misfortunes. We are responsible for neglecting and abusing the Earth and our presidential administration refuses to coincide with society and agree with that fact. The Environmental Protection and Agency (EPA) and the National Highway Traffic Safety Administration (NHTSA) have begun to establish the Safer Affordable Fuel-Efficient Act which would deplete set CO2 emissions standards from car models of 2021-2026. The government is regulating and interfering with laws and admins that have been set to assist the Earth with climate change and are planning to change the goals dramatically. This potential law enables car manufactures the ability to allow their cars to emit more CO2 to help save money for their cause.

In 1969, the Cuyahoga River in Cleveland, Ohio was set on fire. From one side of the bank to the other, the entire river was set on fire. But what was on fire was not actually the river, instead it was the thick layers of trash, chemicals, and waste that had been dumped by local residents on the river. Several different species and organisms were affected dearly, and the entire scene was dreadful. However, 3 years later the Clean Water Act was instated in the United States of America which set regulations, laws, and obligations we as a nation have to abide by to help preserve this planet. This act and including the Clean Air Act instituted in 1962 were both excellent administrative laws that are still used today. But instead of preservation and peace, our administration today feels that industry and economy come above all else. President Trump claimed, If the standards threatened auto jobs, then commonsense changes would be made in order to protect the economic viability of the U.S. automotive industryclearly proving his point on regards to environmental policies.

The disruption of the 2021-2026 fuel-efficient standards set by the EPA would be detrimental to the planet. Scientists are concerned that if this ratification is successful, we are near a much larger scare of environmental collapse that we wouldve ever seen possible. The United Nations Intergovernmental Panel on Climate Change just released their status on the fast-tracking of climate change and are concerned for the future. With the regulations of CO2 emissions from car being set back, their concerns may become reality. With this reality coming fast, it is imperative that climate change be the set focus of new administration in the future. The government has to enforce pro-climate change laws to reset the damage we have done, hoping to balance the scales we have already tipped over.

Due to our massive role as a greenhouse gas provider, it is important we mandate and conform regulations that slow the tide of climate change. Hurricanes, forest fires, coral depletion and many more examples of environmental catastrophes will get worse as time goes. The only way to slow down the rush, is to stand tall and fight back.

Background

(from Indivisible Berkeley) The National Highway Traffic Safety Administration (NHTSA) has authority to set vehicle fuel economy standards (how many miles per gallon automakers’ fleets must meet) – also known as Corporate Average Fuel Economy (CAFE) standards under the Energy Policy and Conservation Act. The Environmental Protection Agency (EPA) has authority to set emissions standards for pollutants, including carbon dioxide (CO2), the major greenhouse gas (GHG) contributing to global warming. The two agencies coordinate so that fuel economy standards harmonize with the standards for protecting human health. Fuel economy and pollution emission standards are related and intertwine because reducing fuel use by raising fuel economy standards (mpg) also reduces tailpipe emissions.

California (CA) has unique air quality issues due primarily to the geographic features of its worst air quality areas and because goods coming into CA’s ports must be transported through these same areas by diesel truck or rail to the rest of the country. As a result, for 48 years, the state has received permission, called a Clean Air Act “waiver,” from the EPA in order set emission standards that are more stringent than the national standards. Thirteen other states have also adopted CA’s standards. They include limits on CO2 and allow CA’s zero emission vehicle program, which requires automakers to make 25% of their fleets zero emission by 2025.

In 2012 the Obama administration reached an unprecedented agreement among the state of CA, automakers and the federal government to establish harmonized national fuel economy standards that took into account CA’s pollution reduction needs and provided a multi-year timespan for automakers to gradually meet the requirements. The agreement gave auto makers the regulatory certainty and national solution they desired. The agreement was developed over three years of negotiations. General Motors and Chrysler had been bailed out by the federal government due to the 2008 recession and were concerned about have two sets of standards (CA and federal) with which to comply. It is notable that these are the two automakers who currently rank lowest in average fuel economy.

In the current action, EPA and the NHTSA propose to reduce the stringency of the standards agreed to for vehicle model years 2021-2026 and freeze them at the 2020 level. They also propose to revoke CA’s waiver, which has never been done before and will also affect the other states that have adopted CA’s standards.

The standards set by the Obama administration would avert 570 million metric tons of greenhouse gas emissions by 2030, equivalent to stopping 140 typical coal-fired power plants for a year, according to the Union of Concerned Scientists.

In developing the Obama era standards, EPA compiled an enormous amount of information and data, had numerous meetings with industry and allowed robust opportunities for public input. The record of their decision is impeccable. They were also required to conduct a mid-term evaluation, which they completed in early 2017. The evaluation confirmed that with the latest information, the standards that had been set remained necessary, cost effective and achievable with existing technology. Regardless, the Trump administration has done a new evaluation and reached a conclusion that the standards should be weakened.

One of the “selling points” of the new proposal is that weakening the standards would result in fewer vehicle accident deaths. The logic and data used for this analysis has been strongly challenged both by EPA in-house experts and many others (more on this in the links below). Another key claim is that the standards will only reduce fuel use by a small percentage. But given the huge role that the transportation sector plays in CO2 emissions and the urgent need to reduce CO2 from every source possible, this is a specious argument. The proposal goes on to question the availability of necessary technology, to make and heavily weigh unsupported assumptions about consumer behavior, and claim that CA’s waiver is not legal, among many other claims that use flawed, questionable or unsupported logic, science, legal interpretation or data.

References

 

 

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