I’m in Philadelphia today, testifying at a public hearing on the recently proposed model year 2017-2025 vehicle greenhouse gas and fuel economy standards. The two agencies in charge of the process – the U.S. Environmental Protection Agency (EPA) and the Department of Transportation’s National Highway Traffic Safety Administration (NHTSA) – proposed the standards last November, and are soliciting written comments on their proposal until February 13th. They’re also holding three public hearings (in Detroit, Philadelphia, and San Francisco) on the standards, and welcoming public input. Along with my colleagues Elizabeth Irvin and Rachel Cohen, I’m joined by a wide array of stakeholders who have all come out to voice support for these standards.
As I will be stating today, the proposed standards are “a keystone to cutting our reliance on oil, reducing global warming pollution, and putting money back into the pockets of American consumers.” But don’t just take my word for it. Bob King, President of the United Auto Workers (UAW) said earlier this week at the Detroit hearing, “The proposed rules are sensible, achievable and needed…They are good for the auto industry and its leaders, good for the broader environment and good for our national security.”
As always, there’s still some room for improvement. Certain provisions of the proposal, if exploited by automakers, would reduce the program’s anticipated benefits. UCS is sharing our perspective with the agencies, and look forward to them addressing these issues and finalizing strong standards this July.
My hearing testimony is pasted below. To add your voice to the chorus of support, take action today.
Agencies Should Finalize Strong Vehicle Standards, Addressing Provisions
That Could Erode Program Benefits
Statement of Jim Kliesch
Research Director, Union of Concerned Scientists Clean Vehicles Program
January 19, 2012
Docket ID Nos. EPA-HQ-OAR-2010-0799 & NHTSA-2010-0131
My name is Jim Kliesch and I am here today on behalf of the Union of Concerned Scientists and our more than 350,000 supporters. UCS is the leading science-based nonprofit organization working for a healthy environment and a safer world. UCS strongly supports the proposed model year 2017-2025 vehicle greenhouse gas and fuel economy standards, and applauds the work of the U.S. Environmental Protection Agency (EPA), the National Highway Traffic Safety Administration (NHTSA), and the California Air Resources Board (CARB) for their respective roles in the development of the proposed standards. Throughout the regulatory process, the agencies have been transparent, relied heavily on independent technical analysis, and sought ongoing input from the public and other stakeholders. UCS urges the agencies to finalize strong vehicle standards, with attention paid to susceptible provisions in the proposal that, if exploited by automakers, would reduce the program’s anticipated benefits.
America’s dependence on oil puts our economy, health, environment, and national security at risk. Whether it is the threat of international terrorism, the devastating impacts of global climate change, or lost income and jobs due to oil price shocks, the damage caused by America’s heavy reliance on oil is clear. Since transportation accounts for the majority of America’s oil consumption, making our cars and light trucks cleaner and more fuel-efficient is a keystone to cutting our reliance on oil, reducing global warming pollution, and putting money back into the pockets of American consumers.
Based on UCS analysis, the 2017-2025 standards alone would reduce global warming pollution by as much as 290 million metric tons (MMT) in 2030. This is equivalent to shutting down 62 (600 megawatt) coal-fired power plants for an entire year. Cumulatively, this program will reduce U.S. greenhouse gas emissions by more than 1,700 MMT through 2030.
The proposed standards will also dramatically reduce U.S. oil consumption by as much as 1.5 million barrels per day (mbd) – roughly 23 billion gallons of gasoline annually – in 2030 alone. This is equivalent to the 2010 U.S. imports from Saudi Arabia and Iraq combined. And the oil savings of the full MY2012-2025 program could result in a total reduction in U.S. oil consumption of nearly 3.5 mbd in 2030, almost double the amount the U.S. currently imports from the entire Persian Gulf.
No other federal policy has delivered greater oil savings, energy security benefits, or greenhouse gas emission reductions to the country.
Applying clean, efficient technologies to our cars and trucks is a boon for the auto industry, the environment, and the economy alike. According to our analysis, full implementation of the proposed 2017-2025 standards would save consumers, cumulatively, $535 billion at the pump through 2030. Even after paying for the additional cost of better technology, consumers would see over $260 billion in net savings through 2030.
And while the cost of clean car technology will lead to an increase in new vehicle price, the average consumer will save money the moment they drive off the lot. Since most Americans finance the purchase of a new vehicle, the higher vehicle price is borne as a slightly higher monthly loan payment, which is more than offset by avoided monthly fuel expenses.
The standards also strengthen our economy. By spending less on oil, consumers have more money to spend on goods and services that would create U.S. jobs. A recent report from Ceres found that standards similar to those proposed by the agencies would create nearly 500,000 new jobs nationwide in 2030.
Moreover, better fuel efficiency and greenhouse gas performance will improve the competitiveness of the American auto industry. In 2008, in the face of rising gas prices and a declining economy, American automakers were woefully ill-prepared to meet consumers’ needs. These standards will ensure that manufacturers continue to innovate over the coming decade, providing consumers clean, efficient vehicles choices that will help them fight gas price spikes for years to come.
UCS applauds the agencies for proposing standards that represent historic progress for American consumers, the U.S auto industry, clean air, and U.S. energy security. That said, key provisions in the proposal could erode these benefits if automakers exploit them, and should be addressed by the agencies before the standards are finalized.
For example, the proposal’s mid-term evaluation provision must be structured to ensure that it is used to support strong standards moving forward and not as an opportunity by the industry to stall or forego regulatory obligations.
We are also very concerned that the significantly weaker standards for light trucks could give automakers an incentive to reclassify passenger vehicles as non-passenger vehicles. For example, a gap of roughly 6-10 mpg exists between car and light truck target stringencies in the footprint range seen by many crossover vehicles. This gap is much larger than the fuel economy loss a crossover would face from adding four-wheel drive, which could enable it to qualify for the weaker standard as a “non-passenger vehicle.” Gaming of the system like this will cut down on the anticipated program benefits. Given the sizable (and growing) popularity of the crossover vehicle segment, the agencies cannot afford to dismiss this issue.
That said, the proposed 2017-2025 light-duty vehicle standards represent a historic step forward, with the potential to nearly double the fuel efficiency and halve the greenhouse gas emissions of light duty vehicles sold in model year 2025 compared to new vehicles sold today. Together with the 2012-2016 standards, this represents the most significant action ever taken by the federal government to cut America’s oil dependence and curb global warming pollution.
We thank the agencies for their diligent work in developing these proposed standards, and look forward to the finalization of strong standards through 2025 by this July, consistent with the timeline issued in the most recent Notice of Intent.
Support from UCS members make work like this possible. Will you join us? Help UCS advance independent science for a healthy environment and a safer world.