Andrew Wheeler
Administrator, US EPA
William Jefferson Clinton Building
1200 Pennsylvania Avenue, N. W.
Mail Code: 1101A
Washington, DC 20460

Re The Safer Affordable Fuel-Efficient Vehicles Rule for Model Years 2021-2026 Passenger Cars and Light Trucks EPA-HQ-OAR-2018-0283-0756

Dear Mr. Wheeler,

I oppose the EPA’s proposed revocation of my state’s authority to keep stronger limits on tailpipe pollution. The Safer Affordable Fuel-Efficient Vehicles Proposed Rule for Model Years 2021-2026 is badly misnamed. You propose a direct attack on the air we breathe and the world we live in. The pollution your proposal fosters will add more poison to your air and ours. There’s nothing safe about that. It causes severe illnesses, particularly in the elderly and children.
The proposal slams the brakes on improving federal standards and locks in outdated permission levels through 2026.(1) Those levels were a small improvement on levels set in 2007.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. So the proposal tosses out all the fuel-efficiency improvement the auto industry has seen since you, Mr. Wheeler, were a college freshman.(2)
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. (5) 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.
Decrease road safety. Encourage production of bigger cars that 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 locks in old outdated pollution levels that harm 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 reduce pollution. The action you propose would increase it.

Sincerely,

1. https://www.yahoo.com/news/draft-epa-memo-freezes-fuel-economy-standards-42-130000776.html
2. https://www.nhtsa.gov/staticfiles/rulemaking/pdf/cafe/Performance-summary-report-12152014-v2.pdf
3. https://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. https://www.ucsusa.org/clean-vehicles/electric-vehicles/fuel-economy-low-income#.W323ZK01Su5
6. http://www.nber.org/papers/w23340
8. https://www.nhtsa.gov/sites/nhtsa.dot.gov/files/documents/ld_cafe_my2021-26_pria_0.pdf
9. http://www.latimes.com/politics/la-na-pol-mileage-20180427-story.html APR 27, 2018
10. http://www.lung.org/assets/documents/healthy-air/state-of-the-air/sota-2018-full.pdf
11. http://www.aafa.org/page/asthma-facts.aspx
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.