The George Washington University Regulatory Studies Center improves regulatory policy through research, education, and outreach. As part of its mission, the Center conducts careful and independent analyses to assess rulemaking proposals from the perspective of the public interest. This comment on the National Highway Traffic Safety Administration (NHTSA) and Environmental Protection Agency (EPA) proposed rule setting corporate average fuel economy (CAFE) standards for model years 2021–2026 does not represent the views of any particular affected party or special interest, but is designed to evaluate the effect of NHTSA and EPA’s proposal on overall consumer welfare.
I am an economist with 25 years’ experience analyzing laws, policies and regulations in the U.K., E.U. and U.S. Much of my work has focused on environmental issues, ranging from waste management to climate change. Of particular relevance to these comments, I have written several studies assessing the effects of U.S. fuel economy standards and the regulation of greenhouse gas (GHG) emissions, including:
- Baruch Feigenbaum and Julian Morris, CAFE Standards in Plain English, Los Angeles: Reason Foundation, 2017.
- Julian Morris and Arthur Wardle, CAFE and ZEV Standards: Environmental Effects and Alternatives, Los Angeles: Reason Foundation, 2017.
- Julian Morris, The Effect of Corporate Average Fuel Economy Standards on Consumers, Los Angeles: Reason Foundation, 2018.
- Julian Morris, Climate Change, Catastrophe, Regulation and the Social Cost of Carbon, Los Angeles: Reason Foundation, 2018.
The present comments focus on several salient features of the proposed Safer Affordable Fuel-Efficient (SAFE) Rule and the preliminary regulatory impact analysis (PRIA) of that rule. They address the likely effects of the rule on vehicle fuel economy, fuel consumption, the cost of new and used vehicles, safety, and the environment. In addition, they consider the effects of state regulations that are related to fuel economy, including vehicle tailpipe GHG emission standards and zero emission vehicle standards—and the potential inconsistency of these state regulations with CAFE standards and federal GHG emissions standards. The agencies estimate that the proposed SAFE rule will have potentially enormous and very widespread benefits to society—saving thousands of lives and hundreds of billions of dollars. At the same time, they estimate that the rule will have very limited effects on the environment.