SAFE Analysis of the EPA & NHTSA’s Notice of Proposed Rulemaking for Fuel Economy Standards
With the release by the Environmental Protection Agency (EPA) and the National Highway Traffic Safety Administration (NHTSA) of the Notice of Proposed Rulemaking (NPRM), the fuel economy debate has taken its latest and most crucial step. At a time when gasoline prices are rising, oil markets are contending with increased geopolitical risk and an era of tighter oil supply is predicted, the U.S. Department of Transportation (DOT) and the EPA have a unique opportunity to modernize the fuel economy standards by incorporating new technologies that reduce U.S. oil dependence and strengthen American energy security.
Previous agency analysis, and current expert opinion, contradict the findings in the NPRM that freezing fuel economy will save 12,000 lives.
New vehicle purchase prices have fallen by three percent since 2013 even as the total Consumer Price Index has risen by eight percent.
Electric vehicle sales have increased significantly on a year-over-year basis, reflecting increased consumer acceptance of these vehicles. 2018 sales are at a 50 percent increase over 2017.
The proposed rulemaking will increase U.S. gasoline demand by .5 mbd through the early 2030s—a significant detriment to achieving the administration’s stated goal of energy dominance. The document’s assessment that oil prices will remain low through 2050 contradicts current price assessments and market dynamics, and historical precedent.
Agency cost-benefit analysis methodology must be updated to account for significant military cost of oil dependence.