Not surprisingly, elements of the Biden Administration’s Proposed Rule reverse many elements of the Trump Administration’s SAFE Rule. It is worthwhile to note that while there was a wide range of reactions to the SAFE Rule, most comments submitted for the 2021 Proposed Rule have been supportive of the proposed revisions—with some notable exceptions. It is also important to note the current Proposed Rule was individually published by the EPA and not jointly with the National Highway Traffic Safety Administration (NHTSA). Recent proposals and subsequent rules have been developed jointly between EPA and NHTSA. The shift to separate rules may indicate growing differences between the two rule-making entities. The industry has strongly supported EPA and NHTSA to develop a single coherent rule.

In the Proposed Rule, the EPA presents and analyzes standards at three levels: The (preferred) proposed standard, a more stringent standard, and a less stringent standard. This paper presents key points of the proposed standard and provides a sample of key stakeholder reactions. However, it is possible—even likely—that the EPA’s final implemented ruling will include elements beyond what has been proposed.

The Proposed Rule intends to supplement the current Administration’s decarbonization goals through the implementation of more stringent emissions regulations. The EPA recognizes that achieving the Administration’s goals will be difficult, and compliance from automotive manufacturers may require increased flexibility. While some organizations may directly benefit from more flexible regulations, others argue that the flexibilities will hinder progress towards emissions reduction.

The post A Brief Review of Proposed Rulemaking: The Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards appeared first on Center for Automotive Research.

• Establishing a baseline cost curve from two different vehicles with no evidence that these two are representative of the U.S. fleet
• Extrapolating lightweighting costs (cost curve) from one vehicle to other vehicles with different, yet unknown lightweight material technology
• Assuming that all 2008 model year vehicles possess a common baseline of lightweight technology
• Relying on vehicle curb weight as a proxy for measuring the amount of lightweight material technology in a vehicle
• Adjusting curb weight only for footprint increase and previous safety regulations but not considering mass add-backs for future safety improvements and new vehicle content

CAR recommends that the EPA employ a material-based lightweighting cost analysis as recommended by the National Research Council and reevaluate the cost to lightweight the U.S. fleet based on this analysis

The post EPA Mass Reduction Analysis – Observations and Recommendations appeared first on Center for Automotive Research.