To Re: NHTSA should presumptively select the alternatives that will maximize net
16 October 2023
For passenger cars and light trucks, EPCA instructs NHTSA to set fuel-economy standards at the “maximum feasible average fuel economy level” that “manufacturers can achieve” in each model year.7 NHTSA must “consider technological feasibility, economic practicability, the effect of other motor vehicle standards of the Government on fuel economy, and the need of the United States to conserve energy”. [...] NHTSA uses several criteria to assess this factor: the results of its RIA, the application rates of available technologies, other technology-related considerations, the cost of meeting the standards, sales and unemployment responses, and uncertainty and consumer acceptance of technologies.40 In tentatively concluding that PC6LT8 is economically impracticable, NHTSA cites many of these criteria, in. [...] However, the cause of the bi- modal outcome appears to be the result of the discrete nature of technology (such as the adoption of Strong Hybrid Electric Vehicles (SHEVs)). [...] NHTSA Should Consider Vehicle Upsizing as a Likely Compliance Strategy and Reevaluate the Slope of the Footprint Curve in Light of that Consideration The Proposed Rule, like prior NHTSA fuel-economy rules, is footprint-based, meaning that more stringent fuel-economy requirements apply to smaller vehicles (measured by footprint).85 The steeper the footprint curve, the more manufacturers are incenti. [...] 94 According to EPA, as the fleet transitions to an increasing percentage of zero-emission vehicles, the appropriate slope for the fleet will need to consider not just the current available technology of internal-combustion-engine (ICE) vehicles, but also the ratio of those ICE vehicles sold as a percentage of the entire fleet of new vehicles.