ACEEE applauds the EPA and NHTSA for taking the enormous step towards energy security and environmental protection that this joint rulemaking represents. The proposed rule offers very substantial increases in fuel economy and reductions in vehicles' greenhouse gas (GHG) emissions. It also reflects important analytical improvements over previous rulemakings, especially a more thorough and transparent analysis of technical potential. Ending reliance on confidential manufacturer product plans in setting standards not only allows the public to understand in detail the basis for the standards but also can lead to a program that promotes manufacturer innovation.
We urge the agencies to strengthen the proposal in the final rule by addressing features that could cause the standards to fall short of the benefits they are meant to provide in the next seven years and by establishing principles in the rule to ensure that any subsequent rules will make maximum contribution to meeting national energy, environmental, and economic goals.