NATSO on Oct. 26 filed comments with the Environmental Protection Agency in response to the Agency's proposed changes to fuel economy requirements that were previously finalized by the Obama Administration. NATSO expressed support for the agency’s efforts to tie Corporate Average Fuel Economy (CAFE) standards to today’s market realities while also providing the agency several ideas for how it could improve a new standard to better achieve its regulatory objectives.
The National Highway Traffic Safety Administration’s (NHTSA) and the Environmental Protection Agency’s (EPA) proposal would freeze the 2020 fuel economy requirements through 2026, rather than requiring increasing, not necessarily achievable, fuel economy improvements during that time period. NATSO essentially argued that the original standard (requiring increasing fuel economy improvements) were developed six years ago when world market conditions—and therefore future market projections-- were dramatically different.
The regulatory agencies developed the current standard in 2012 under the premise that fuel prices would continue to rise significantly and that the United States would continue to rely heavily on oil imports. Instead, fuel prices today are significantly lower and are projected to remain low through 2050 and the United States is the largest global oil producer.
“Taken together, these incorrect projections necessitate reevaluating the CAFE standards,” NATSO wrote. “The United States’ extraordinary growth in oil production has mitigated any preexisting concerns regarding unhealthy dependence upon foreign oil; and fuel prices being so much lower than anticipated has resulted in automobile consumers being less concerned about strong fuel economy than was projected.”
NATSO further outlined a series of ideas that the agency should consider in forming any new standard. Specifically, NATSO said the agency should:
--Treat natural gas vehicles on par with electric vehicles, applying this principle of neutrality to any technology, and establish performance standards that enable all fuels and technologies to compete on a level playing field;
--Explore high octane fuels, in conjunction with high compression engines, as a potential means of compliance; and
--Refrain from considering an incentive for connected and autonomous vehicle technologies unless the agency requires auto manufacturers to demonstrate such technologies' real world emissions benefits.
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