Yesterday, the Competitive Enterprise Institute, FreedomWorks, Institute for Energy Research, and Small Business & Entrepreneurship Council submitted a joint comment letter on the Environmental Protection Agency (EPA) and National Highway Traffic Safety Administration’s (NHTSA) proposed rule, “Greenhouse Gas Emissions and Fuel Efficiency standards for Medium- and Heavy-Duty Engines and Vehicles – Phase 2.”
The agencies’ Phase 1 rulemaking in 2011 established first-ever greenhouse gas (GHG) and fuel-economy standards for model years (MYs) 2014-2018 semi-trucks, large pickups and vans, and assorted vocational trucks. Phase 2 will set more stringent medium- and heavy-truck GHG and fuel economy standards for MYs 2021-2027.
In 25 thrill-packed pages, our comment letter lays out the following argument:
EPA and NHTSA’s proposed Phase 2 greenhouse gas/fuel economy standards for heavy-duty vehicles endanger the economic viability of small-business truckers. The rule’s putative energy-security and climate benefits are entirely speculative and vanishingly small at best. The agencies fail to demonstrate that, absent regulation, truckers won’t make cost-effective investments in fuel-saving technology. If EPA wants to know why heavy trucks don’t get better mileage than they do today, it should look itself in the mirror. During the 2000s, EPA’s diesel-truck emission standards, both by directly reducing the fuel-efficiency of diesel engines, and by crowding out fuel economy-related R&D and consumer spending, created the problem the agencies purport to solve via additional regulation.