Talking point 1 – General

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.

Talking point 2 – Tosses 43 years of work

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The proposal halts improvement of federal standards and locks in outdated permission levels through 2026. 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 EPA proposes to throw out 43 years of innovative improvement in fuel efficiency.

Talking point 3 – Climate disaster

EPA’s proposed rule would worsen the climate emergency by revoking states’ authority to keep stronger limits on tailpipe pollution. 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 (See https://www.washingtonpost.com/news/capital-weather-gang/wp/2017/09/23/harvey-irma-maria-why-is-this-hurricane-season-so-bad/ and  http://www.latimes.com/local/lanow/la-me-fires-heat-20180731-story.html)

Talking point 4 – Environmental  Injustice

The proposed rule attacks our health and discriminates against the poor and people of color.  According to the American Lung Association, more than 40% of Americans breathe dirty, unsafe air (http://www.lung.org/assets/documents/healthy-air/state-of-the-air/sota-2018-full.pdf) and 25 million Americans – including more than 6 million children – suffer from asthma (http://www.aafa.org/page/asthma-facts.aspx).  Highways and freeways are most often located near neighborhoods where people of color and those with low incomes live, so the bad health effects of auto exhaust fall most heavily on them. (See Ostro B. et al. Fine particulate air pollution and mortality in nine California counties: results from CALFINE. Environ Health Perspect. 2006: 114: 29-33 and 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.)

Talking point 5 – More expensive and less safe

EPA’s proposed rule would cost drivers billions at the gas pump and make our roads less safe. The standards you propose to rescind are projected to save drivers $50 billion at the pump by 2030 (See https://www.ucsusa.org/clean-vehicles/electric-vehicles/fuel-economy-low-income#.W323ZK01S).  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.  The lax efficiency rules also encourage production of more massive cars, which strike harder in accidents, causing more damage and injury (See http://www.nber.org/papers/w23340)

Talking point 6 – Job loss and a burden to the industry

The proposed rule would cause job loss and hamper business. Rolling standards back would stifle 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” (See https://www.nhtsa.gov/sites/nhtsa.dot.gov/files/documents/ld_cafe_my2021-26_pria_0.pdf).

The rule would 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. (See http://www.latimes.com/politics/la-na-pol-mileage-20180427-story.html.)

ADDRESSES
Thank our Attorney General for bringing the lawsuit to protect California’s right to its stronger standards.
Attorney General Xavier Becerra
Office of the Attorney General
1300 “I” Street
Sacramento, CA 95814-2919

Tell EPA Director Wheeler what you think of the proposed rule.
Andrew Wheeler
Administrator, US EPA
William Jefferson Clinton Building
1200 Pennsylvania Avenue, N. W.
Mail Code: 1101A
Washington, DC 20460
Facebook: @EPAAndrewWheeler
Twitter: @EPAAWheeler

Sec. Elaine L. Chao
US Department of Transportation
1200 New Jersey Ave, SE
Washington, DC 20590