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Illinois Attorney General Kwame Raoul
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October 26, 2021


Chicago  — Attorney General Kwame Raoul, as part of a multistate coalition, today urged the National Highway Transportation Safety Administration (NHTSA) to increase the stringency of corporate average fuel economy (CAFE) standards for model year 2024 to 2026 vehicles. Under the Energy Policy Conservation Act, the NHTSA is required to set standards to improve fuel economy and reduce the energy consumption of passenger cars and light-duty trucks to the maximum extent feasible. Strong fuel economy standards have saved consumers hundreds of dollars each, reduced harmful emissions and helped protect the health of communities. In today’s comment letter, Raoul and the coalition argue that the NHTSA’s proposed standards – unlike the existing rules the coalition is currently challenging in court – are supported by science, reason and the law.

“The NHTSA’s proposed standards will reduce greenhouse gas emissions, which is essential to slowing climate change and limiting the impact of climate change on the environment and public health,” Raoul said. “I urge the NHTSA to implement these standards that will help states combat the effects of climate change, which disproportionately impact low-income communities and communities of color.”

The Energy Policy and Conservation Act requires the NHTSA to establish “maximum feasible” fuel economy standards and, in doing so, to 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.” Under the previous administration, the NHTSA abdicated this responsibility with its so-called “SAFE” rules, which rolled back the nation’s Clean Car Standards. The changes to the CAFE standards alone were expected to “result in 1.9 to 2.0 additional billion barrels of fuel consumed,” and reverse consumer savings through increased fuel expenditure. All in all, the NHTSA estimated that the net benefits of their final rules “straddle[d] zero.”

In today’s comments, Raoul and the coalition express their support for the NHTSA’s proposal to set more stringent fuel economy standards for model years 2024 to 2026. Improved fuel economy saves consumers money, improves national security by reducing dependence on imported oil, counters climate change, improves air quality and benefits public health. For example, the NHTSA expects these standards to reduce multiple types of harmful air pollution, including particulate matter. Studies also show that air pollution may increase individuals’ vulnerability to contracting COVID-19 and may increase the severity of, and mortality risk from, contracting the virus. Importantly, the impacts of the NHTSA’s proposed standards are likely to be magnified in low-income communities and communities of color, which are often located in transportation corridors and are disproportionately impacted by pollution and the resulting health consequences.

Joining Raoul in filing the comments are the attorneys general of California, Colorado, Connecticut, Delaware, the District of Columbia, Hawaii, Maine, Maryland, Massachusetts, Michigan, Minnesota, Nevada, New Jersey, New Mexico, New York, North Carolina, Oregon, Pennsylvania, Rhode Island, Vermont, Washington and Wisconsin, and the cities of Denver, Los Angeles, New York, Oakland, California, San Francisco, and San Jose, California.

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