Global Automakers and the Alliance of Automobile Manufacturers (Alliance) filed comments in response to the Notice of Proposed Rulemaking on the adjustment of the civil penalty rate under the Corporate Average Fuel Economy (CAFE) program. Based on careful analysis, the trade associations concur fully with NHTSA’s conclusion that the CAFE civil penalty rate is not subject to adjustment under the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015.

The comments by Global Automakers and the Alliance also address rounding issues and include a response to the Union of Concerned Scientists’ comments.