NHTSA-EPA Joint Propos

Rulemaking: Summary Public Comments

Briefing for OMB

December 2, 2009
EPA-NHTSA Deliberative Material 

Agenda

 Summary of key public com Key inputs for NHTSA and 

models

 Schedule for Final Rule & N
Review of Public Com

Date 

 More than 129,000 comments subm

EPA and NHTSA docket

 ~130 substantive comments from orga Vast majority of letter writing campaign Comments will continue to come in ove

processed through the docket staff

 EPA and NHTSA staffs are still in the 

receiving and reviewing comments

 Today, we’re sharing our preliminar

the key issues identified thus far in 

 For various issues, we give an indica

the key commenters, but by no meato be an inclusive list

EPA-NHTSA Deliberative Material
EPA-NHTSA Deliberative Material 

Overview of Public Co

 There is significant support for the central tenets of th

 Coordinated EPA-NHTSA set of standards which phase-in 

250 g/mi CO2 and 34.1 mpg

 Supported by:

 Major auto OEMS (GM, Ford, Chrysler, Honda, Toyota, Niss

Automobile Mfrs, AIAM)

 California & other states (CARB, NACAA, NJ, MA, NJ) NGOs (NRDC, UCS, EDF, Sierra Club, Consumer Federation 

 Comments not supportive of proposal

 A few commenters not supportive of National Program ( Center for Biological Diversity commented that significan

are appropriate

 Many industry trade groups oppose EPA finalizing the ve

concerns with the implications for stationary sources (rePSD Tailoring rule and Endangerment finding) 

 National Association of Manufacturers, American Chemical C

American Farm Bureau Association, US Chamber of Comme

 Several commenters applauded EPA and NHTSA for th

analytical work supporting the proposal (Sierra Club, UCS, 

Transportation Research Institute (UMTRI), Public Citizen, Ctr for Bio D

 There are many important issues which EPA & NHTSA 

address
EPA-NHTSA Deliberative Material 

Key comments

 Small volume manufacturers treatm

 Less stringent standards/additional lead

volume, niche, luxury/high-performance manufacturers (Jaguar/Landrover, Porsche, Aston

 Electric vehicle CO2 impacts under E

 Whether to include upstream emissions 

emissions (environmental NGOs, states, Honda supp

2012-2016)

 Truck footprint curve shape

 Truck stringency for large footprints (GM Truck curve upper and lower kink points 

 Phase-in rate for 2012-2015 standar

 Auto Alliance, Ford, Toyota suggest more linear, less-stri CARB supports the proposed std. phase-in rates
EPA-NHTSA Deliberative Material

Key comments (conti

 Social Cost of Carbon

 ~20 commenters (4 focused entirely on SCC)

Steven Rose, UCS, NACAA, CARB, UC Santa Barbara, Alliance, NAD

NESCAUM, CT DEP, NJ DEP, National Petrochemical Refiners AssocCooperative Association, Institute for Energy Research 

 Comments from autos, states, NGOs, and ac

discount rate selection and use of SCC in ben

 Discount rate: Most said 5% is too high, notin

arguments for lower rates, while an auto grou

 Use of SCC: Detailed comments about approp

benefit-cost analysis; one recommended using 

 Other key comments.

 SCC underestimated: Identified omitted impac

term values account for uncertainty and risk p

 Scope of SCC: Most supported global values, N

domestic.

 Distribution: Reliance on single value (e.g., me

capture distribution of estimates, especially fa

 Development of long-term values: Some recom

provide strong justification, especially for discosupported new model runs.
EPA-NHTSA Deliberative Material 

Key comments (conti

 Consumer welfare and valuation of fuel 

 Many comments note a number of market/behavioral f

fuel economy and cite these failures as a basis for regu

Federation of America, ACEEE, UCS, UMTRI, Investor Network 

Institute for Policy Integrity, International Council on Clean TraDomini Social Investments)

 These include asymmetric and absent information, imperf

aversion, lack of choice over fuel economy within classesother “energy paradox” issues, as well as vehicles as posstatus; fuel-inefficiency may result from “keeping up with purchases)

 A number observe that the rule protects the existing varie

the market (e.g., CARB, NESCAUM, NJ DEP)

 Some argue that automakers as well as consumers will be 

fuel economy (UMTRI, Investor Network on Climate Risk, 

 Two commenters argue that the market for fuel econo

efficiently (UAW, Institute for Energy Research)

 If consumers wanted more fuel-efficient vehicles, someon

 Auto companies appear not to have commented on thi
EPA-NHTSA Deliberative Material 

Key comments (conti

 Mass reduction and impact on safety

 Center for Auto Safety, NRDC, Several auto OEM

Climate Campaign, ICCT, NACAA, Tom Wenzel, CSteel Inst., SABIC Innovative Plastics, Dynamic REnterprise Institute...

 EPA proposed N2O and CH4 standards

 Autos oppose standards for N2O and CH4, but if 

inclusion in a fleetwide CO2-equivalent standard; 

avoid measurement costs

 Several NGOs, MECA support cap standards

 EPA program flexibilities (early credits, TLA

cycle credits, FFV credits, A/C credits)

 Many, many comments by autos, states, environ Auto’s generally support proposal or ask for an e States and environmental groups concerned with 

potential windfall credits
EPA-NHTSA Deliberative Material 

Key comments (conti

 NHTSA request for comment on A/C test procedures f

 Auto Alliance and GM oppose CAFE A/C mpg credits Toyota, Chrysler, and Daimler support CAFE A/C mpg cr

 Backstop standard

 Autos generally opposed, environmental groups and sev

 GHG certification & compliance provisions 

 Numerous technical comments, mainly from autos, some 

 Transparency in compliance reporting to public (EDF, N

Climate Campaign)

 Technology effectiveness and costs (GM, MECA, Motor & Equip 

CARB)

 Indirect costs

 Use of indirect cost multipliers generally supported (UMTR

 Economic and other assumptions:

 Discount rates (NRDC, NADA) Monopsony benefits (NYU) Rebound effect (NADA, CARB, ICCT) Refueling benefits Scrappage rates (CARB)  Fuel Prices (CARB, NADA)
EPA-NHTSA Deliberative Material 

Key Model Inputs for NHT

 Social cost of carbon Discount rates Monopsony Fuel prices Criteria pollutant $/ton valuation VMT rebound effect Value for increased noise/accidents/conges Value of additional driving from rebound Value from reduced refueling events Technology costs and effectiveness Vehicle reference fleet projection
Overview of Key Public Comment

 “No Action” Alternative: DEIS should account for reasonably 

and agencies that will affect GHG emissions from the transpo

 Sierra Club, Public Citizen & CBD

 Context:

 Place impacts in context that provides basis for comparison betwe

alternatives in terms of reducing GHG emissions to 1990 levels by CBD)

 DEIS minimizes climate change impacts by analyzing them as pro

instead of emissions from motor vehicles or the US transportation 

& CBD)

 Consultation: NHTSA must complete Endangered Species Ac

ensure action will not jeopardize/adversely modify critical habendangered species 

 Sierra Club, Public Citizen & CBD

 National Security: DEIS should assign national security value 

consumption

 Consumer Federation of America
Key Public Comments on the EIS 

 Complexity

 DEIS does not adequately inform public because it is too 

layperson (Public Citizen)

 Alternatives

 DEIS fails to analyze a “technology forcing”/ “technology 

(Sierra Club, Public Citizen & CBD)

 Environmental Impacts

 DEIS does not account for emissions associated with ge

charge plug-in hybrids and electric vehicles in future veh

 Health Impacts

 Health-related consequences of factors, such as increasi

availability of, fossil fuels, should be analyzed pursuant 

Control and Prevention) 
EPA-NHTSA Deliberative Material 

Joint NHTSA/EPA FinaSchedule & Next Steps

Draft Final EIS circulated for inter-Agency Review Formal submission of available FRM package sections to OMB Final EIS completed and sent to EPA for FR printing and mailed to stakeholdersFormal submission of FRM package to OMB FRM cleared by OMB and Signature by DOT/ EPA