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Friday, August 24, 2018 @ 9:00 am - Tuesday, October 23, 2018 @ 8:59 pm


  1. Open your browser and paste in this URL http://www.regulations.gov/docket?D=EPA-HQ-OAR-2018-0283 to open the EPA comments page.
  2. Click the blue COMMENT NOW! button to open the comment box.
  3. Select and copy the text below the line here.
  4. In your browser, paste the text into the comment box. Check the little permissions box and click Submit.

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I oppose the EPA’s proposed revocation of states’ authority to keep stronger limits on tailpipe pollution.  The Safer Affordable Fuel-Efficient Vehicles Proposed Rule for Model Years 2021-2026 is badly misnamed.  It is a direct attack on the air we breathe and the world we live in. If enacted it will add more poison to the air. There’s nothing safe about that.  Pollution from car exhaust causes severe illnesses, particularly in the elderly and children. It will cost money at the gas pump that could be spent locally.  It will stifle auto innovation, and hamper business with uncertainty. It will encourage production of bigger inefficient cars, which cause more damage upon collision in accidents.  Only multinational oil companies will benefit.

The proposal halts improvement of federal standards and locks in outdated permission levels through 2026.(1)  Those levels were a small improvement on levels set in 2007.  At that time, U.S. car fuel efficiencies had not risen significantly since 1983.(2)  So EPA proposes to throw out 43 years of innovative improvement in fuel efficiency.

The rule would not make vehicles safer or more affordable.  It would:

  •       Worsen the climate emergency. Car exhaust is the biggest source of  the carbon we force into the U.S. atmosphere, and that makes gasoline a major culprit in the climate emergency. We need less exhaust pollution.  The nation is already beginning to suffer the human and financial damage from the increasingly destructive storms and fires happening now, and without swift anti-pollution action, it will get much worse.(3,4)
  •       Cost drivers billions at the gas pump. The standards you propose to rescind are projected to save drivers $50 billion at the pump by 2030.  This is money they can spend on local businesses instead. Taking away our rights and rolling back federal standards in effect makes a gift to multinational oil companies at the expense of the American people. (5)
  •       Decrease road safety. Encourage production of more massive cars, which strike harder in accidents, causing more damage and injury.6
  •       Cost jobs. Rolling standards back would tifle the innovation that has been producing cleaner cars.  EPA and NHTSA’s  own analysis shows that junking the new standards would cost the nation 50,000 to 60,000 “job-years.”(7)
  •       Hamper businesses. Force auto makers to deal with unnecessary uncertainty.  Forcing California to allow the federal emissions standard would change the rules for more than a third of cars and trucks in the country and the industry would have to deal with it for years – because we would surely oppose this coercion in court for as long as it takes.(8)
  •       Harm our health.  According to the American Lung Association, more than 40% of Americans breathe dirty, unsafe air(9) and 25 million Americans – including more than 6 million children – suffer from asthma.(10) The health effects of breathing dirty air are worst for vulnerable groups like the elderly and children.
  •       Discriminate against the poor and people of color.  These people are more likely to live near highways and freeways, so they bear the worst of air pollution.(11,12)

The proposal is bad for the residents of all states.  It would toss away more than 40 years of progress toward cleaner car exhaust, causing physical harm to millions of Americans, especially the elderly and children.  It forces more climate-killing pollution into the air. It stifles innovation that creates good jobs. The Environmental Protection Agency’s job is to protect our environment. The proposed rule does not serve that mission.

  1. http://www.yahoo.com/news/draft-epa-memo-freezes-fuel-economy-standards-42-130000776.html
  2. http://www.nhtsa.gov/staticfiles/rulemaking/pdf/cafe/Performance-summary-report-12152014-v2.pdf
  3. http://www.washingtonpost.com/news/capital-weather-gang/wp/2017/09/23/harvey-irma-maria-why-is-this-hurricane-season-so-bad/
  4. http://www.latimes.com/local/lanow/la-me-fires-heat-20180731-story.html
  5. http://www.ucsusa.org/clean-vehicles/electric-vehicles/fuel-economy-low-income#.W323ZK01Su5
  6. http://www.nber.org/papers/w23340
  7. http://www.nhtsa.gov/sites/nhtsa.dot.gov/files/documents/ld_cafe_my2021-26_pria_0.pdf
  8. http://www.latimes.com/politics/la-na-pol-mileage-20180427-story.html
  9. http://www.lung.org/assets/documents/healthy-air/state-of-the-air/sota-2018-full.pdf
  10. http://www.aafa.org/page/asthma-facts.aspx
  11. Ostro B. et al. Fine particulate air pollution and mortality in nine California counties: results from CALFINE. Environ Health Perspect. 2006: 114: 29-33
  12. Ostro B. et al. The Impact of Components of Fine Particulate Matter on Cardiovascular Mortality in Susceptible Subpopulations. Occup Environ Med. 2008; 65(11): 750-756.



Friday, August 24, 2018 @ 9:00 am
Tuesday, October 23, 2018 @ 8:59 pm