The Need for Stronger Fuel Economy Standards

The following is testimony presented before the National Highway Traffic Safety Administration at the Public Hearing for Corporate Average Fuel Economy Standards on September 28, 2023. 

Good morning. My name is Kathy Harris, and I am a Senior Advocate for Clean Vehicles and Fuels at NRDC, the Natural Resources Defense Council. Thank you for holding this hearing. I’m here today on behalf of NRDC’s more than 3 million members and online activists who support our efforts to safeguard the rights of all Americans to clean air, clean water, and a healthy planet.

The National Highway Traffic Safety Administration [NHSTA] has a duty to set the maximum feasible fuel economy standards for passenger cars and light trucks to ensure our nation is reducing our dangerous dependence on petroleum. Since 1975, fuel economy improvements have saved more than 2 trillion gallons of gasoline—enough to run every car and light truck in the U.S. for more than 15 years. 

More efficient vehicles on our roads not only help to save consumers money at the pump but importantly help to cut our reliance on oil. And as a subsequent effect, also help to reduce emissions from the transportation sector. 

Now is not the time to slow down on these improvements—particularly as gasoline prices continue to rise, affecting households across the country. NHTSA’s current proposal would require 2% improvements in passenger car efficiency and 4% improvements in light truck efficiency annually. 

While this is a move in the right direction, what is clear is that NHTSA can and must go further. In fact, NHSTA’s own analysis shows that the adoption of a stronger alternative would conserve more energy, provide greater fuel savings benefits, and reduce certain pollutant emissions. Therefore, we urge NHTSA to adopt a rule that is at least as strong as Alternative PC3LT5 [which would require 3% improvements in passenger car efficiency and 5% improvements in light truck efficiency annually].

A rule that is at least as stringent as PC3LT5 is feasible and achievable based on improvements that automakers can make within their current fleets and engine configurations, while still promoting additional, possible improvements on internal combustion vehicles. Analysis has shown there is the potential for tremendous improvements by OEMs by merely shifting to the most efficient technology packages they offer.

Light trucks make up the majority of the fleet and are also some of the least efficient vehicles with the most room for improvement. NHTSA should not artificially link increases in the car and truck fleets and should focus on maximizing light truck improvements to achieve the greatest overall improvements in fleetwide fuel economy. 

And it’s important to remember that NHSTA’s fuel economy standards are intended to be technology forcing—and the agency should be looking at the limits of possibility rather than the limits of automaker ambition. NSTHA should adopt a standard that is at least as stringent as PC3LT5. 

Thank you for the opportunity to speak today.