The Department of Transportation should alter its proposed fuel economy standards for passenger cars and light duty trucks released earlier this summer, as several groups representing renewable fuel producers, fuel marketers and agricultural interests told the agency in a Monday letter that the agency “improperly” incorporated electric vehicles into its analysis.
The letter comes after the DOT’s National Highway Traffic Safety Administration in July issued its Corporate Average Fuel Economy (CAFE) Standards, which call for the fuel efficiency of passenger cars to rise 2% each year from model year 2027 and MY2032 alongside a 4% per year increase for light trucks over the same period.
Current CAFE standards require cars and light trucks to average 49 mpg in MY2026.
The agency’s proposal also would require a 10% per year efficiency increase for commercial pickup trucks and work vans between MY 2030 and 2035.
But the groups on Monday’s letter–which include the Renewable Fuels Association, the National Farmers Union, the National Corn Growers Association, and the fuel marketing and retail groups NATSO, SIGMA and NACS–were less concerned over the specific figures in the proposal, and more perturbed by the decision to account for EVs into the multi-year proposal to begin with.
They said the agency should be concerned over the “consequences and legality” of its approach in forming the new standards, noting that the decision to include EVs in the analysis violated a provision in the Energy Policy and Conservation Act that prohibits NHTSA from accounting for dedicated alternative fuel automobiles.
“NHTSA violated this prohibition by including a significant number of Battery Electric Vehicles (BEVs) in the analysis supporting its proposed maximum feasibility determination,” the groups said, adding that, “including zero emission vehicles (ZEVs) in the analysis violates the direction Congress provided on the treatment of BEVs and other dedicated alternative fuel vehicles.”
The group went on to note that NHTSA’s decision to circumvent this provision by “misinterpreting” statute “is plainly a violation of Congressional intent.”
“As such, the underlying analysis used to determine fuel economy standards should be revised to eliminate consideration of electric vehicles,” the groups said in the letter.
Beyond imploring the agency to eliminate such considerations in its final rule, the groups in general said the agency should be focused on a “technology-neutral approach to improving fuel economy, in which all fuels and technologies are treated equally, [which] will create the most positive and immediate outcomes while upholding the intent of the law.”
They also said the proposed rule misses the mark on affordability and cost effectiveness–citing the agency’s own projection that implementation would result in net societal disbenefits of $4 to $5 billion, net personal disbenefits of $5.7 to $5.8 billion.
“As proposed, the standards are not economically practicable and would dramatically limit consumer access to affordable transportation solutions,” the groups said in the letter.
Comments on the agency proposal were due Oct. 16.
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–Reporting by Patrick Newkumet, [email protected]; editing by Jordan Godwin, [email protected]
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