CARB Letter to USEPA Regarding Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards
Use link below to download copy of letter signed to US EPA Administrator by CARB Executive Officer Richard W. Corey, dated September 27, 2021.
Text of letter:
September 27, 2021
Mr. Michael Regan, Administrator
United States Environmental Protection Agency
EPA Docket Center
Office of Air and Radiation
Docket ID No. EPA-HQ-OAR-2021-0208
Mail Code 28221T
1200 Pennsylvania Avenue, NW
Washington, DC 20460
Re: Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards, Docket ID No. EPA-HQ-OAR-2021-0208
Dear Administrator Regan, The California Air Resources Board (CARB) welcomes this proposal by the United States Environmental Protection Agency (U.S. EPA) to revise its 2023 and later model year light-duty vehicle greenhouse gas emissions standards. U.S. EPA correctly recognizes that standards more stringent than those currently in place are appropriate, feasible, and necessary to protect public health. It has a legal and policy obligation to require the maximum emission reductions possible.
U.S. EPA has improved its analysis of appropriate greenhouse gas emission standards to propose more stringent standards. CARB offers the following detailed comments and materials in support of U.S. EPA’s proposal and urges the agency to adopt the most stringent standards feasible. All the proposed standards – the preferred alternative, the more stringent alternatives, and thus necessarily the less stringent alternative - are technologically feasible. U.S. EPA has a legal obligation to follow the science and the Clean Air Act and cut emissions as deeply as possible. Alternative 2, a return to the National Program standards with an improvement of those standards for model year 2026 by an additional 10 grams of carbon dioxide per mile, would maximize the reduction in emissions. However, CARB recognizes that U.S. EPA may determine additional lead time is appropriate; if so, the best option is to adopt a standard at least as stringent as its preferred alternative for model year 2023 and greater stringency thereafter, along the lines of Alternative 2 for later model years, with additional reductions required in model year 2026 to recoup further lost emission reductions.
We strongly support urgent action to protect public health and stabilize the climate. The wildfires, drought, declining air quality, and extreme heat we face due to the climate crisis are becoming increasingly extreme and frequent. They confirm the assessments of climate scientists that we must act quickly to stave off the worst effects of climate change. Indeed, America’s most vulnerable communities – and communities in California in particular – face very serious public health and economic threats without swift action.
The solutions are at hand. The ingenuity of engineers and scientists has improved vehicle emission technology and significantly reduced emissions of greenhouse gases and other pollutants. In many instances these improvements pay for themselves in fuel savings, and in all ways their benefits to public health and welfare far outweigh their costs. Automobile manufacturers are already including in their vehicles the technologies to meet these proposed standards, including in other markets. The proposed standards will ensure they accelerate deployment here.
CARB is continuing its work to ensure clean transportation technology is equitably available in California. CARB appreciates U.S. EPA’s proposal that is consistent with CARB’s work and is fully supported by the facts concerning the technology, costs, and benefits. We are also encouraged that the law and facts once again matter as reflected in U.S. EPA’s pending proposals and look forward to continuing to work together on standards for increasingly cleaner conventional technology and expanded use of zero-emission technology. Please contact Mr. Craig Segall, Deputy Executive Officer at Craig.Segall@arb.ca.gov for any questions you may have about our comments.
Richard W. Corey, Executive Officer