3/4/2023 0 Comments Slapdash eraFirst, the estimated $1000 – $2000 increase in new-vehicle prices will be subsumed by more significant determinants of vehicle price like macroeconomic conditions. It’s also true that many times, development of environmental regulations does not involve careful consideration of equity.ĮLC’s research revealed, however, that relaxing the GHG emissions standards will not meaningfully increase vehicle affordability for low-income consumers. The simple logic of “regulation equals price hikes equals harm to low-income consumers” is indeed compelling at first glance. Automakers, in their request to EPA to reconsider the standards, had raised the concern that the standards will harm low-income consumers. In a second letter, ELC examined the SAFE Vehicles Rule’s claim that relaxing the Obama-era vehicle GHG emissions standards will advance vehicle affordability. Attached to its letter, ELC submitted the 100+ peer-reviewed research papers on which it relied-many of which were published after the waiver was granted in 2013-to update the record before EPA on what climate change really means for California. California’s stringent GHG standards are essential to curbing the acceleration of conditions like these. Relying on the most current climate science, the letter described several dramatic climate-induced conditions in California, including extreme heat events, rainstorm intensification, water shortages, human health risks, and dwindling crop yields. Complementing the Emmett Institute’s comment on the legal reasons this move would be inappropriate and unlawful, ELC’s letter demonstrated how vital the California standards are for the welfare of this state and its residents. ![]() Although the rule is rife with the logical inconsistencies, slapdash legal analyses, and sweeping, unsubstantiated claims that typify Trump deregulatory actions, ELC’s letters focused on two aspects of the proposed rule: the California waiver and vehicle affordability.ĮLC was especially concerned about implications for its home state if EPA rescinds the California waiver. The UC Berkeley Environmental Law Clinic (ELC) submitted two comments on this proposal. ![]() On Friday, the comment period closed on EPA’s proposed “Safer Affordable Fuel-Efficient Vehicles (SAFE) Rule.” The rule would roll back Obama-era vehicle GHG emissions standards and rescind California’s preemption waiver, which allows the state to maintain its own standards.
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