MEMO
To: Interested Parties
From: Megan Thorpe, Communications Director
Date: October 26, 2018
RE: DEQ Comments on Proposed Rulemaking and Draft Environmental Impact Statement for “The Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule for Model Years 2021–2026 Passenger Cars and Light Trucks”
As the lead agency charged with implementing the Clean Air Act, DEQ is committed to protecting and improving ambient air quality for the health, benefit and economic well-being of all North Carolina citizens. For these reasons, DEQ opposes the proposed rule to relax CAFÉ and CO2 standards. Additionally, DEQ requests that the NHTSA and EPA maintain existing CAFÉ and CO2 standards, finalize augural CAFE standards for model years 2021-2025, and maintain the California GHG emission standards waiver for light-duty vehicles.
Based on our review of the proposed rulemaking and draft environmental impact statement, DEQ has determined that the EPA’s analysis supporting the relaxation of the CAFÉ and CO2 standards is flawed and underestimates the costs and public health impacts. Adverse effects anticipated by relaxing the pollution rule include:
- Increasing the vulnerability of our state’s low-lying coastal infrastructure, including railways, ports, airports, as well as water and energy supply systems
- Increasing the risk for exceeding the ozone and particulate matter of aerodynamic diameter of 2.5 microns or less (PM2.5) National Ambient Air Quality Standards.
- Increasing the likelihood of volatile weather conditions ranging from drought to flooding to heat waves to high-impact hurricanes
- Economic damage from increasingly severe weather to homes, businesses, and natural and built infrastructure.
Thus, DEQ has concluded that keeping the existing and augural CAFE standards and existing CO2 standards for light-duty vehicles in place is critical for mitigating climate change impacts in North Carolina.