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Mid-term Evaluation of Model Year 2022-2025 Light-duty Vehicle Greenhouse Gas Emissions Standards

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Southern Environmental Law Center (SELC) filings
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Southern Environmental Law Center (SELC) filed 1 comment on this docket between Sep 29, 2016 and Sep 29, 2016. 119 other organizations filed here. The comment window closed 3218d ago.

What Southern Environmental Law Center (SELC) filed (1)

Sep 29, 2016· Comment submitted by Warren G. Lavey, University of Illinois Applied Environmental Law Program et al., University of Illinois Applied Environmental Law Program, Environmental Law & Policy Center, Southern Environmental Law Center· EPA-HQ-OAR-2015-0827-4080

Comments of University of Illinois Applied Environmental Law Program, Environmental Law & Policy Center, Southern Environmental Law Center SUMMARY Section 3.4 of the Draft Technical Assessment Report (DTAR) recognizes the importance and challenges of autonomous vehicle systems. DTAR proposes a "watchful evaluation" approach: to "inform any regulatory development beyond model year 2025", the agencies (United States Environmental Protection Agency (USEPA), United States Department of Transportation (USDOT), and the National Highway Traffic Safety Administration (NHTSA)) are "beginning to explore research on the potential emissions and fuel economy impacts of emerging transformational technologies and transportation trends". Market developments in autonomous vehicles require more stringent emissions standards for years 2022-2025 as well as immediate actions by the agencies to improve performance testing and establish benchmarks, modeling and indicators for beyond year 2025. Major automotive manufacturers are now selling scores of vehicle models with various semi autonomous driving and connectivity systems, and fully autonomous vehicles began serving ride-sharing customers in Pittsburgh in August 2016. The roll-out will grow in innovations and vehicle numbers each year. These features are affecting greenhouse gas (GHG) emissions and fuel economy in actual vehicle performance in many ways not captured in the agencies' measurements, adjustments and projections established in 2012. These innovations require more stringent standards and improved testing. To prepare for the next generation of standards, the agencies should promptly begin a comprehensive assessment to measure, benchmark, analyze and model the environmental impacts of autonomous driving and connectivity systems. These actions should encourage manufacturers to design and sell autonomous vehicle technologies that lower emissions and raise fuel efficiency. Moreover, the agencies should develop additional indicators of these systems' environmental impacts and best practices to help consumers select and use vehicles that minimize emissions and fuel consumption. In this field of complex innovations and behavioral changes, the Technical Assessment Report should commit to issue drafts of these tools for public comments. CONCLUSION The Technical Assessment Report must address autonomous vehicle and connectivity systems through actions now and over the next five years. The agencies should approach these systems in the context of a range of innovations which affect light-duty vehicle GHG emissions and fuel economy. All changes must be measured in performance tests and adjustments; standards for 2022-2025 should be made more stringent to reflect the impacts and opportunities of these systems; and benchmarks, modeling and indicators should be developed with public comments for proposing new standards. The agencies correctly observe that these technologies have potentially significant environmental impacts and are uncertain. However, the DTAR fails to acknowledge the immediacy of the innovations and the detrimental effects of current regulations - which fail to test the environmental impacts of or incentivize these systems -- in limiting the environmental benefits of the emerging systems. Merely studying the manufacturers' developments and market adoption means that opportunities (and obligations) to maximize environmental benefits will be missed. Inadequate performance testing and adjustments decrease manufacturers' incentives for reducing emissions and increasing fuel economy. Similarly, there should be guidance to manufacturers that new standards will project the environmental benefits of making these advances available on low-emissions vehicles. Also, consumers need better information on environmental impacts in deciding whether to buy vehicles with these features. Finally, the agencies should develop through research, public com…

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Abstract

The model year 2017-2025 rule establishing standards for light-duty vehicle greenhouse gases and corporate average fuel economy established a mid-term evaluation process for model year 2022-2025 greenhouse gas standards. The first step in the mid-term evaluation is a Draft Technical Assessment Report, issued jointly by EPA, the National Highway Traffic Safety Administration, and the California Air Resources Board, to inform EPA’s determination on the appropriateness of the GHG standards and to inform NHTSA’s rulemaking for the CAFE standards for model years 2022-2025.

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Mid-term Evaluation of Model Year 2022-2025 Light-duty Vehicle Greenhouse Gas Emissions Standards (EPA) — Southern Environmental Law Center (SELC) | OpenPolis