Comments to EPA on the Multi-Pollutant Emissions Standards for Model Years 2027 and Later Light- and Medium-Duty Vehicles
To the Environmental Protection Agency on the Multi-Pollutant Emissions Standards for Model Years 2027 and Later Light-Duty and Medium-Duty Vehicles
The following comments cover two issues. First, EPA “solicits comments on the proposed changes to the shape of the footprint curves, including the flattening of the car curve and our approach for deriving the truck curve from the car curve.” Using estimated compliance costs estimated from a recent working paper, RFF Senior Fellow Josh Linn quantifies how much the existing footprint curves incentivize vehicle manufacturers to reclassify cars as light trucks and to increase vehicle footprint. The implication is that flattening the curves would reduce these incentives. This comment is based on a blog post he published on RFF Common Resources. Second, EPA seeks comment on the proposed standards and on three alternatives to its proposed standards. Using the RFF light-duty vehicle model, Linn estimates benefits and costs of the proposed standards and two alternatives. For vehicles sold in 2030, tighter standards improve social welfare by $128 billion (2022$) over the lifetimes of those vehicles. Lower-income households enjoy larger fuel cost reductions than other households, which causes them to enjoy a disproportionately large share of the overall benefits. This comment is based on a new report that evaluates the overall benefits and costs of the proposed GHG emissions standards and the distribution of benefits across new vehicle consumers.
