669_sejda-DYJ.pdf - Chapter 1 Purpose and Need for the...

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Chapter 1 Purpose and Need for the Proposed Action 1-22 EDF et al. suggested that NHTSA undertake a wedge analysis to characterize the magnitude of climate pollution reductions at stake, using an approach similar to that used in a 2007 EPA analysis of the U.S. transportation sector, which evaluated cumulative growth in GHG emissions. Citing case law, EDF et al. argued that CAFE and EPA GHG standards have resulted in meaningful mitigation of GHG emissions. NHTSA analyzes the potential cumulative climate impacts of the proposed rule and alternatives in Chapter 8, Cumulative Impacts . Environmental Justice Some commenters addressed the potential environmental justice impacts of changes to fuel economy standards. Most of these commenters, including Acadia et al., CARB, and American Lung Association, urged NHTSA to address such environmental justice impacts in terms of air pollution’s disproportionate health effects on minorities, low-income communities, and other traditionally disadvantaged groups. Acadia Center et al. and EDF et al. commented that the EIS should consider the geographic distribution of changes in criteria pollutants and air toxics associated with any change in the NHTSA augural standards. CARB remarked that Executive Order 12898 and Title VI of the Civil Rights Act compel NHTSA to analyze environmental justice impacts, whereas Acadia Center et al. cited EPA NEPA guidance that says federal agencies must consider environmental justice in their activities under NEPA. Acadia et al. suggested that the EIS sho uld consider the effect, if any, of the Trump Administration’s proposed decreases in federal spending on environmental justice activities. NHTSA analyzes the potential environmental justice impacts of the proposed rule and alternatives in Chapter 7, Other Impacts . Other Environmental Impacts A few commenters suggested other environmental impacts that NHTSA should consider in the EIS. Alliance & Global Automakers recommended that NHTSA consider impacts in areas such as land use, hazardous materials, historic and cultural resources, noise, and safety, and urged NHTSA to update evaluations of those impacts to reflect the most recent scientific literature. The State of Hawaii stressed the importance of continued consideration of these well understood but difficult to quantify effects. Pearson Fuels disputed a statement in the 2012 EIS section on land use and development that land use change resulting from increased ethanol production could increase GHG emissions and cause other environmental impacts; it asserted that EPA has developed an adequate renewable fuel standard regulatory framework to ensure that indirect land use change emissions are taken into account in the evaluation of whether ethanol meets the 20 percent lifecycle GHG emissions reduction standard.
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