Clean car standards legal resources

In 2012 Environmental Protection Agency (EPA), the National Highway Traffic Safety Administration (NHTSA), and California’s Air Resources Board finalized crucial greenhouse gas emission standards for Model Year 2017-2025 cars and trucks.

As part of the Clean Car program, EPA conducted a thorough Mid-Term Evaluation to assess the MY 2022-2025 standards, which included engagement from the public, advocates, and industry stakeholders, and led to a massive technical record to support the agencies' conclusion in 2017 that the standards should remain as is, in place.

The Trump Administration, however, is trying to roll back these much-needed climate and consumer protections. In April 2018, EPA issued a second Final Determination stating its intent to roll back the Clean Car standards. In August 2018, EPA and NHTSA jointly issued a formal proposal for the rollback.

EDF opposes the Trump Administration’s efforts to dismantle this program, and we are working hard to defend the standards.

Comments on Rollback

Comment of EDF
Oct. 26, 2018
Addressing technical and legal issues with the proposed rule to roll back the Clean Car standards

Joint NGO Comment
Oct. 26, 2018
Addressing legal issues with the proposal
Submitted by EDF with Center for Biological Diversity, Conservation Law Foundation, Earthjustice, Environmental Law & Policy Center, Natural Resources Defense Council, Public Citizen, Sierra Club, and Union of Concerned Scientists

Joint NGO Comment
Oct. 26, 2018
Addressing climate change
Submitted by EDF with Center for Biological Diversity, Earthjustice, Natural Resources Defense Council, Sierra Club, and Public Citizen

Comment of States and Cities
Oct. 26, 2018
Submitted by California, Connecticut, Delaware, Hawaii, Iowa, Illinois, Maine, Maryland, Minnesota, New Jersey, New Mexico, New York, North Carolina, Oregon, Rhode Island, Vermont, and Washington, the Commonwealths of Massachusetts, Pennsylvania, and Virginia, the District of Columbia, and the Cities of Los Angeles, New York, Oakland, San Francisco, and San Jose

Joint NGO Comment
Oct. 26, 2018
Addressing Endangered Species Act issues
Submitted by Center for Biological Diversity, Earthjustice, Natural Resources Defense Council, and Sierra Club

Additional Technical Analysis Comments

Comment of EDF and Union of Concerned Scientists
Oct. 26, 2018
Addressing issues with the analysis and application of the rebound effect

Comment of California Air Resources Board
Addressing technical issues with the proposal, plus expert reports submitted by CARB on specific technical subjects

Comment of Professor Cinzia Cirillo, University of Maryland
Oct. 18, 2018
Addressing the use of her research in the proposal

Comment of Professors James Stock & Ken Gillingham, Havard University Oct. 26, 2018
Addressing vehicle cost and other technical issues with the proposal

Comment of Professors Mark Jacobsen & Arthur van Benthem, UC San Diego
Oct. 8, 2018
Addressing the use of their research and technical concerns with the proposal

Comment of Assistant Professor Joshua Linn, University of Maryland
Oct. 11, 2018
Addressing the improper use of the rebound effect in the proposal

Comment of Professor Emeritus Kenneth Small, UC Irvine
Sept. 14, 2018
Addressing the use of his research in the proposal

Comment of NRDC
Oct. 26, 2018
Addressing the flawed assumptions made by NHTSA regarding mass reduction technologies in the proposal

Comment of Union of Concerned Scientists
Oct. 26, 2018
Addressing economic feasibility and successful implementation of past fuel economy and greenhouse gas emissions standards for light-duty vehicles

Comment of American Council for an Energy-Efficient Economy (ACEEE)
Oct. 2018
Addressing cost of compliance technology, safety issues, and flexibility provisions

Comment of BlueGreen Alliance
Oct. 26, 2018
Regarding economic benefit of fuel economy improvements and greenhouse reductions

Comment of the Consumer Federation of America (CFA) and other consumer groups
Oct. 26, 2018
Addressing factual errors in the proposal

Comment of Consumers Union
Oct. 26, 2018
Reviewing technical and analytical flaws in the proposal

Joint Comments of ACEEE, CFA, and Consumers Union
Oct. 26, 2018
Addressing vehicle sales, ownership costs, and other economic considerations

Comment of the International Council on Clean Transportation (ICCT)
Oct. 25, 2018
Addressing technical deficiencies in the analyses contained in the proposal

Comment of the Institute for Policy Integrity (IPI)
Oct. 26, 2018
Addressing flaws in the legal, technical, and econometric reasoning in the proposal

Comments on NHTSA’s Draft Environmental Impact Statement

Comment of EDF
Oct. 26, 2018
Addressing technical and legal issues with NHTSA's Draft Environmental Impact Statement

Joint NGO Comment
Oct. 26, 2018
Addressing technical and legal issues with NHTSA's Draft Environmental Impact Statement
Submitted by Center for Biological Diversity, Earthjustice, Environmental Law and Policy Center, Natural Resources Defense Council, Public Citizen, Inc., Safe Climate Campaign, Sierra Club, Southern Environmental Law Center, and Union of Concerned Scientists

Comment of States & Cities
Oct. 26, 2018
Addressing issues with NHTSA's Draft Environmental Impact Statement
Submitted by States of California, Connecticut, Delaware, Hawaii, Iowa, Illinois, Maine, Maryland, Minnesota, North Carolina, New Jersey, New Mexico, New York, Oregon, Rhode Island, Vermont, Washington, the Commonwealths of Massachusetts, Pennsylvania, and Virginia, the District of Columbia, and the Cities of Los Angeles, New York, Oakland, San Francisco, and San Jose

Final Determination Litigation

Order Referring Motions to Dismiss to Merits Panel

Responses to Government and Industry Motions to Dismiss

Motions to Dismiss

Motions to Intervene

Petitions for Review

Administrative Proceedings