597_sejda-DYJ.pdf - Chapter 1 Purpose and Need for the...

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Chapter 1 Purpose and Need for the Proposed Action 1-14 standards, the EIS must consider CAFE standards that are more stringent than the augural standards. Environmental Law & Policy Center stated that NHTSA should consider a robust range of alternative standards, including those stronger than the augural standards, given that the transportation sector has now overtaken the power sector as the largest source of U.S. GHG pollution and remains dependent on oil. To identify the range of possible options, Consumer Federation of America provided a table showing three potential approaches to standard setting within the confines of the law and guidance, defining each in terms of the benefit-cost ratio it would reflect. The State of Hawaii commented that the elimination of considerations is a critical concern and stated that the importance of valuing and assessing benefits cannot be understated, because devaluing or eliminating benefits can effectively be used to lower the maximum feasible band in NHTSA’s proposed bracketing approach for CAFE standards. The commenter argued it is important that, in setting the upper bound in particular, NHTSA does not set up the analysis in such a way as to understate the potential for achieving higher standards of fuel efficiency. Alliance & Global Automakers stated that the present reality of low gasoline prices, market demand, and actual technology performance create considerable uncertainty regarding the augural standards, but they argued that it is understandable if NHTSA decides to select the augural standards as an upper bound as part of the joint NHTSA and EPA mid-term evaluation. Cato Institute argued that the lower end of the MY 2022 2025 CAFE standards considered by NHTSA in its EIS must be the 2021 standard. NHTSA has reviewed and considered these comments in the development of this EIS. While the agency agrees that the four-alternative bounding approach it originally considered is reasonable, the agency has opted to include a wider range of alternatives in the EIS to cover the complexity of this action. The No Action Alternative, described in Chapter 2, Proposed Action and Alternatives and Analysis Methods, is the most stringent alternative under consideration. Although several commenters expressed a desire for NHTSA to analyze alternatives that are more stringent than the augural standards, the agency ultimately concluded that such alternatives are beyond maximum feasible and are not reasonable for consideration here. NHTSA describes its selection of alternatives in Chapter 2, Proposed Action and Alternatives and Analysis Methods , and in Section IV of the NPRM. No Action Alternative and Baselines Several commenters, including industry organizations, environmental advocacy organizations, and state and local agencies, provided input on the No Action Alternative and baselines.
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  • Fall '19
  • UCI race classifications, Tour de Georgia, Corporate Average Fuel Economy, NHTSA

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