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Consumers Union comments on NHTSA Environmental Impact Statement (EIS) for MY2022-2025 Fuel Economy Standards

August 25, 2017

National Highway Traffic Safety Administration
U.S. Department of Transportation
West Building, Ground Floor, Room W12-140
1200 New Jersey Avenue SE.
Washington, DC 20590


Consumers Union Comments on NHTSA’s Notice of Intent
To Prepare an Environmental Impact Statement for Model Year 2022–2025
Corporate Average Fuel Economy Standards
(Docket No. NHTSA-2017-0069)
Submitted via: www.regulations.gov



Consumers Union (“CU”), the policy and mobilization division of Consumer Reports, submits the following comments to the National Highway Traffic Safety Administration (“NHTSA”) in the above-referenced matter. CU represents the interests of consumers and has provided comments on fuel economy-related public dockets for over a decade, including the setting of the 2017-2025 standards in 2012, the Draft Technical Assessment Report in 2016, and the final determination in 2017. During the course of these rulemaking procedures, CU collected 31,973 signatures in support of strong fuel economy standards.

Gradual improvements to fuel economy and emission standards, like those in place today, are part of a practical and tested program to reduce fuel consumption, improve the vehicle fleet, protect public health, and save consumers trillions of dollars in fuel costs. Automakers have developed the technology to make better, safer, and more efficient vehicles, and federal agencies should now set standards at a higher level to continue this progress in increasing consumer savings and protection. Both our subscriber and nationally representative surveys demonstrate overwhelming public support for continuing to strengthen fuel economy standards, and our recent analyses indicate that doing so will improve consumer welfare through greater owner satisfaction, and is unlikely to impact the entry-level price of new vehicles or affordability of used vehicles (which constitutes 70 percent of light-duty vehicle purchases).

In addition to the environmental and health benefits, consumers are likely to see significant net savings from strong standards, especially light truck buyers.The comments below address the range of alternatives that should be under consideration, key consumer and other impacts that should be considered, and important matters for in-depth analysis in the EIS, with a focus on those that the Secretary of Transportation must consider when setting “maximum feasible” average fuel economy standards.

Consumers Union works for pro-consumer energy policies, health reform, food and product safety, financial reform, and other consumer issues in Washington, D.C., the states, and in the marketplace. Consumer Reports is the world’s largest independent product-testing organization. Using its more than 50 labs, auto test center, and survey research center, the nonprofit rates thousands of products and services annually. Founded in 1936, Consumer Reports has over 8 million subscribers to its magazine, website, and other publications.


Full copy of Consumers Union’s public submission is available here.