On September 6, 2017, in Washington, D.C., the public will have a rare opportunity to tell Scott Pruitt’s EPA, directly and in person, not to roll back vital public health and environmental protections.
The September 6 hearing will begin at 9 AM at the Renaissance Hotel, 999 Ninth St., NW, in Washington, D.C. It is open to all members of the public. Anyone who wishes to speak will be permitted to do so if they reserve a speaking slot with EPA by sending an email by August 30, 2017. Very simple instructions for how you can speak at the hearing are available on EPA’s hearing notice here. The hearing will continue all day (and, if necessary, into the evening).
It is vital that there be a strong showing at the Sept. 6 hearing to demonstrate that the public opposes these foolish, destructive rollbacks of vital protections.
THE CLEAN CAR STANDARDS
The Clean Car Standards are EPA’s greenhouse gas emissions standards for “light-duty” motor vehicles – which includes cars and SUVs.
The transport sector is now responsible for over a quarter of all man-caused greenhouse gas emissions in the United States. Any path to sustainable climate means sharply reducing emissions from cars and trucks.
The good news is that we have made real progress – in large part as a result of the first-ever GHG emissions standards adopted by EPA in 2010, in response to the 2007 Supreme Court decision in Massachusetts v. EPA. The Massachusetts decision confirmed EPA’s responsibility under the Clean Air Act to emissions of greenhouse gases that endanger public health and welfare. In 2009, EPA found that, based upon an overwhelming scientific record, greenhouse gases do, in fact, endanger the public. The Obama Administration then adopted its first-generation Clean Car Standards, coordinating with the Department of Transportation’s fuel economy standards and with standards developed by the State of California, which agreed to align its standards with the federal Clean Car Standards. U.S. automakers – reeling from severe financial distress after the recession – affirmatively supported the Clean Car standards. When the endangerment finding and Clean Car Standards were attacked in court by others – including then-Oklahoma Attorney General Scott Pruitt – they were unanimously upheld in court.
The Clean Car standards for Model Years 2012-2016 were highly successful. In the years that followed, there were sharp reductions in GHG emissions from new cars (and correspondingly, major increases in fuel economy), and, at the same time, a historic revival of the auto industry. Automakers consistently outperformed the standards, and manufacturers adopted cleaner, more efficient technologies at unprecedented rates – all while vehicle sales have increased for seven consecutive years to an all-time record high in 2016.
In 2015, EPA (again acting in coordination with the Department of Transportation) adopted a next generation of standards, this time governing new cars for Model Years 2017 through 2025. These standards build on the progress of the first set of standards and will deliver even more massive reductions in greenhouse gas emissions -- eliminating an estimated 6 billion metric tons of carbon dioxide over the life of the vehicles subject to the standards. (That’s more than a year’s worth of total U.S. carbon emissions).
In establishing Clean Car Standards for 2017-2025, EPA promised to conduct a “Mid-Term Evaluation” to ensure that the standards for the later four years (2022-2025) would remain appropriate in light of updated data and experience under the standards. That process proceeded during 2016, with extensive input from the public, the manufacturers; after considering this input and performing exhaustive technical analyses, EPA determined in January 2017 that, in fact, the emissions standards put in place in 2015 for Model Years 2022-2025 remained feasible, affordable, and should remain in place.
In affirming the standards for 2022-2025, EPA found that maintaining the standards as established in 2015 would: (1) avoid six billion metric tons of climate pollution; (2) avoid use of about two million barrels of oil a day, (3) save U.S. consumers over a trillion dollars (and save individual buyers thousands) at the pump over the life of the program. EPA also determined that the standards for 2022-25 are “feasible at reasonable cost, without need for extensive electrification” of auto fleets. (While leaving the standards in place, EPA acknowledged that rapid deployment of clean car technology and declining costs could have supported a strengthening of the standards.)
ENTER TRUMP AND PRUITT
Now comes the bad part in the form of the unprecedented public health and environmental disaster that is the ascension of Donald Trump and Scott Pruitt. Scott Pruitt’s mission at EPA is to permanently hobble the very agency he’s charged with leading. That is especially true with respect to EPA’s efforts to reduce GHG emissions from cars and trucks. He has questioned the premise that climate change warrants federal action and does not seem to understand that it’s now his job to enforce federal environmental laws. As part of the Trump’s broader effort to gut federal regulation by gutting core federal technical and administrative capacities, Pruitt has supported budget proposals that would eviscerate EPA’s own scientific and engineering staff that works on automotive pollution control technologies.
Trump, at a rally in Michigan, announced the initiative to “review” the Clean Car Standards – trotting out the stock falsehood that clean air protections are bad for jobs, and that the Clean Car standards represented an “assault on the auto industry.” Accordingly, EPA has begun reconsidering its decision that the 2022-2025 standards remain feasible and appropriate, and will very likely try to weaken them.
Trump’s and Pruitt’s line that environmental protections are precluding economic growth is pure baloney. The implementation of the first-generation Clean Car Standards coincided with the recovery of the U.S. auto industry from an almost fatal crisis and with years of strong sales. In 2016, the industry “sold more vehicles than ever before, increased employment by 700,000 direct jobs since the recession, and complied with the most stringent fuel efficiency standards in our history.” There are already more than 100 cars, SUVs, and pickups on the market today that already would meet 2020 or later standards. Auto manufacturers can meet the model year 2022 to 2025 standards at lower costs than predicted when the standards were developed.
But EPA’s Clean Car Standards are a particular target for Pruitt in part because they address greenhouse gases and seek to mitigate climate climate. Scott Pruitt has repeatedly voiced doubt about basic climate science, and has questioned whether reducing greenhouse gas emissions is even a worthwhile objective. In the face of the Massachusetts decision and subsequent court decisions upholding EPA’s statutory authority to regulate, he has repeatedly expressed doubt about EPA’s authority to regulate greenhouse gas emissions under the Clean Air Act.
The September 6 hearing is a first step in Pruitt’s “review” of the standards. EPA has also asked for written comments which are due on October 5, 2017. (Instructions on where to submit them available here – and the Environmental Defense Fund or Union of Concerned Scientists have online tools allowing you to submit comments). It’s expected that EPA will come out with a proposal to weaken and or delay the standards after the current review is under way. (An effort to weaken separate, already-issued Clean Air Act protections addressing emissions from trucks as well are underway).
WHY SEPTEMBER 6 MATTERS
How the public responds to the proposed rollback of Clean Car will likely determine whether Pruitt succeeds and the extent of future such efforts. The stakes of the current debate are huge:
First, because the amount of climate-destabilizing greenhouse gas pollution emitted by motor vehicles is staggering, the consequences of weakening emissions standards for new vehicle are enormous. We’ve made progress in reducing emissions from vehicles, and are poised to make more progress if we keep incentives in place. And because greenhouse gas emissions are cumulative and mitigating climate change is a race against time, delaying the schedule for ratcheting down emissions levels is itself harmful even if the numerical standards remain the same.
Second, the auto manufacturers need to know that the public won’t stand for rollbacks of key health and environmental protections. At least some of the companies already recognize that the future lies in low- and zero-emitting vehicles (for example, Ford has announced that the number of electric vehicles it offers will exceed gas models within 15 years). Individual auto companies should be called out for their support for this rollback effort, and shouldn’t be allowed to hide behind their trade associations.
Third, if, as expected, Pruitt seeks to weaken the Clean Car Standards, there is a strong possibility that he will next move on to attack California’s historic authority to adopt its own emissions standards stronger than federal standards. While there would be major legal obstacles to doing that, that won’t stop Pruitt from trying to (1) weaken the federal standards, and then (2) seek to preempt or override California’s ability to retain/maintain more protective greenhouse gas standards. A forceful public push-back against this first step will help to defeat the larger attack on California’s pivotal efforts to lead on climate.
Fourth, there are thousands of public servants at EPA and other agencies who want to carry out their statutory mission to protect the public from pollution. It is important for them to hear that the people are standing up for the environment and for EPA’s historic role as protector of health and welfare. Scott Pruitt’s ability to bleed EPA of its institutional memory and cripple the agency for years after he’s gone will depend in part on his ability to demoralize the public servants who are trying to hold on. Showing up at September 6 hearing, the first public hearing on Pruitt’s efforts to roll back climate protections, will help send a signal that the public still values EPA’s vital role in protecting the public health and environment and public servants with the expertise and commitment to carry out that mission.
SHOW UP FOR THE CLIMATE AND FOR EPA’S VITAL MISSION
The September 6 hearing is a rare opportunity to say no to rollbacks of core climate protections and to Trump-Pruitt’s anti-climate agenda and to stand up for the basic scientific and technical integrity that has been EPA’s hallmark for 50 years. The public really, really, really doesn’t support these things, but Scott Pruitt’s only “public” is the oil and gas industry and little else.
Sure, Scott Pruitt himself is unlikely to be swayed by the voices of citizens concerned about climate change and access to cleaner transportation. But a strong showing on September 6 also sends a message to Congress, to fellow citizens, to the state governors and attorneys general who are fighting EPA’s rollbacks, and to federal civil servants who still want to stand up for science and following the law.
If we want to stop the biggest threat to the U.S. and global environment we’ve ever encountered, we have to show up and fight at every opportunity. If you can, please attend the September 6 hearing in D.C.. Consider registering to speak at the hearing (remember: you need to register by August 30). If you don’t want to speak, then attend. Also, consider submitting comments in EPA’s docket by October 5.
(For more on Clean Cars standards and fight to keep and extend them, see discussions from the California Air Resources Board, the Center for Auto Safety’s Safe Climate Campaign, Natural Resources Defense Council, Environmental Defense Fund, and the Union of Concerned Scientists.)