The following is testimony presented to the National Highway Traffic Safety Administration at the public hearing on corporate average fuel economy standards on September 28, 2023.
Good morning My name is Kathy Harris and I am a Senior Advocate for Clean Vehicles and Fuels at NRDC, the Natural Resources Defense Council. Thank you for holding this hearing. I am here today on behalf of the more than 3 million NRDC members and online activists who support our efforts to protect the rights of all Americans to clean air, clean water and a healthy planet.
The National Highway Traffic Safety Administration [NHSTA] has a duty to set the highest possible fuel economy standards for passenger cars and light trucks to ensure our country reduces its dangerous dependence on petroleum. Since 1975, fuel economy improvements have saved more than 2 trillion gallons of gasoline—enough to power every car and light truck in the United States for more than 15 years.
More efficient vehicles on our roads not only help save consumers money at the pump, but more importantly, they also help reduce our dependence on oil. And as a knock-on effect, also help to reduce emissions in the transport sector.
Now is not the time to slow these improvements – especially as gas prices continue to rise, impacting households across the country. NHTSA’s current proposal would require annual improvements in passenger car efficiency of 2% and light truck efficiency of 4%.
While this is a step in the right direction, it is clear that NHTSA can and must go further. In fact, NHSTA’s own analysis shows that adopting a more powerful alternative would save more energy, provide greater fuel economy benefits and reduce certain pollutant emissions. Therefore, we urge NHTSA to adopt a rule that is at least as stringent as Alternative PC3LT5 [which would require 3% improvements in passenger car efficiency and 5% improvements in light truck efficiency annually].
A rule at least as stringent as PC3LT5 is feasible and achievable based on improvements automakers can make in their current fleets and engine configurations, while encouraging further possible improvements in internal combustion engine vehicles. Analysis has shown that OEMs can achieve huge improvements by simply switching to the most efficient technology packages they offer.
Light trucks make up the majority of the fleet and are also some of the least efficient vehicles with the most room for improvement. NHTSA should not artificially link growth in car and truck fleets and should focus on maximizing improvements in light trucks to achieve the greatest overall improvement in fleet-wide fuel economy.
And it’s important to remember that NHSTA fuel economy standards are intended to be technology-driven — and the agency should be mindful of the limits of what is possible rather than the limits of automakers’ ambitions. NSTHA should adopt a standard at least as stringent as PC3LT5.
Thank you for the opportunity to speak today.
Comments are closed.