Global Automakers submitted comments on the U.S. Environmental Protection Agency's (EPA) Proposed Determination on MY 2022-2025 Light-Duty Vehicle Greenhouse Gas (GHG) Standards, which was part of the EPA's "Midterm Evaluation" of those standards.  These comments were submitted on the heels of EPA's earlier denial of Global Automakers' request to either withdraw the Proposed Determination or extend the comment period, a move which suggests that the agency is more intent on pushing through a final determination before the end of this Administration versus a collaborative and data-driven process. 

In 2012, EPA, NHTSA, and California agreed to a Midterm Evaluation of the MY 2022-2025 standards. This Midterm Evaluation was designed to serve as an important "reality check" of both the EPA's GHG standards and the fuel economy standards promulgated by the National Highway Traffic Safety Administration (NHTSA), commonly referred to as the "One National Program." It was supposed to result from an objective analysis, coordinated between the EPA, NHTSA, and California.

Our members remain committed to a national GHG and fuel economy program and to the purpose of the Midterm Evaluation.  However, due to EPA’s truncated comment period, Global Automakers’ submission focused on the high-level concerns with the Proposed Determination.  These include (a) the lack of harmonization between the EPA, NHTSA and California regulations, (b) questions regarding EPA’s assessment of the technological feasibility of its standards and the flexibilities needed to meet them, and (c) EPA’s failure to adequately account for customer needs in the Proposed Determination.

EPA's rush to finalize a determination before the current Administration leaves office threatens to undo the very purpose of the One National Program and the Midterm Evaluation: a harmonized set of regulations that improve fuel economy and reduce greenhouse gas emissions year over year, while ensuring customers have a wide choice of affordable vehicles that meet their needs.