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SAFE Vehicles Proposed Rule: U-M faculty comment for EPA Dearborn hearing

On September 25, the Trump administration held public hearings in Dearborn, Michigan on their Safer Affordable Fuel Efficient (SAFE) Vehicles Proposed Rule, which would weaken Corporate Average Fuel Economy (CAFE) standards after 2020. What follows are comments prepared for the hearing by five University of Michigan faculty.

These comments represent the professional assessments and expertise of the commenters alone, and should not be taken to reflect views or positions of the University of Michigan or any of its schools, colleges, or research units.

John DeCicco
University of Michigan Energy Institute

Thank you for the opportunity to present this comment today.

Having reviewed the proposed rule, I find that it fails to scientifically or economically justify freezing the standards for model years 2021 through 2026. My assessments show that the greenhouse gas emissions and fuel economy standards for those years remain sound.

My overarching conclusion is that there is no justification for changing the standards.

The one new development with any significance is that fuel prices are lower now than projected. However, this does not justify weakening the standards. Lower prices are all the more reason why fuel economy and emission standards should remain untouched.

Lower fuel prices increase consumer payback time from 3½ years to roughly 5 years. This change in economics is not enough to justify weaker standards, which remain highly cost-effective for both consumers and society over the life of the vehicles.

Strong standards, such as those we have now, will help keep oil prices down and buffer consumers from inevitable fluctuations in fuel prices.

The fact is that technology is available to cost-effectively meet the standards.

A more conservative study that I conducted several years before EPA’s Technical Assessment Report showed that we could cost-effectively achieve a fleet average of 52 mpg, higher than the new average projected under the current standards. Moreover, these standards have already adjusted to the shift from cars to light trucks and SUVs and they will continue to adjust – as they were designed – to accommodate changes in vehicle sizes and classifications.

While the standards’ flexibility helps them track the changing market, we have also seen outstanding progress in automotive engineering. This progress provides automakers with many affordable ways to achieve steady gains in efficiency. The past decade saw average fuel economy rise by 23 percent, even as vehicle sales and performance reached new highs. This is a tribute to the engineering ingenuity of our domestic automakers as well as the industry as a whole. Such gains refute any concerns that the standards put sales or jobs at risk.

In summary, the proposal to effectively freeze the standards after 2020 reflects a denial of basic science and a denial of the auto industry’s extensive capabilities to engineer, market and successfully sell ever more fuel-efficient cars and light trucks.

I urge the agencies to set aside this ill-considered proposal and issue final rules for 2021-2025 that maintains steady progress on both fuel economy and emission reduction.
Thank you again for the opportunity to comment.

Samuel Stolper
School for Environment and Sustainability

Thank you for the opportunity to comment here today. My name is Samuel Stolper; I am a professor of environmental and energy economics and policy at the University of Michigan, Ann Arbor and I’m here as a private citizen. Policies like the SAFE Vehicles Rule are what I study for a living.

I would be remiss if I didn’t begin my comment by highlighting the moral responsibility of the United States to reduce greenhouse gas emissions. In 2011, per capita emissions in the U.S. were 20 tons; in the rest of the world they were 7. The U.S. is responsible for 27% of greenhouse gas emissions in the last 160 years, more than any other country, and more than 28 European Union countries combined. The moral imperative of climate change mitigation continues to be ignored by our representatives in government.

That said, climate change mitigation policy will always have effects beyond the main target of emissions levels. For that reason, regulatory impact analysis is a vital – though not on its own sufficient – step to inform and justify policy decisions. The environmental benefits of higher fuel economy should absolutely be considered together with impacts on driving, congestion, and safety. The problem is that the SAFE Vehicles Rule is currently being justified by an incomplete, unscientific, and non-transparent consideration of costs and benefits. Others here today have already exposed this fact and highlighted a litany of important flaws. Among these, I’d like to quickly reiterate two: first, the estimate of reduced fatalities from accidents under the SAFE Vehicles Rule is inflated and indefensible; and second, regulatory certainty is integral to cost-effective policy and yet widely ignored in the proposal and analyses of fuel economy freezes.

I’d like to elaborate on a third flaw: the woefully incomplete and short-sighted consideration of environmental benefits, from reductions of both of local and greenhouse gas pollution. I’ll focus on the latter. The social cost of carbon – which the government uses to place a monetary value on greenhouse gas emissions – has been dropped from a 2020 central estimate of 45 $/ton, to between 1 and 6 $/ton. The assumptions that underlay this drop – higher discount rates, and omission of damages outside the U.S. – are inconsistent with scientific modeling practices, the recommendations of the Council of Economic Advisers, and the logic of the climate problem. Moreover, even our most complete estimates of the social cost of carbon fail to account for a large portion of benefits. Labor productivity, crime, conflict, the impacts of sea level rise, natural disasters, ocean acidification – none of these are considered. Just because you can’t easily monetize it, doesn’t mean you don’t count it.

If the government is going to justify policy decisions on the grounds of net benefits, it must give a complete and scientific consideration of all costs and benefits. Such consideration would reveal the “no-action” alternative to be superior to any freezes on fuel economy increases. I strongly advise DOT and EPA to maintain existing fuel economy standards. Thank you.

Stuart Batterman 
School of Public Health, College of Engineering

Thank you and good afternoon. My name is Stuart Batterman. I am a Professor of Environmental Health Sciences in the School of Public Health, and Professor of Civil and Environmental Engineering in the College of Engineering, both at the University of Michigan in Ann Arbor. I direct several centers in Environmental and Occupational Health, and have been a teacher and researcher in air quality and health for over 30 years, with ongoing research supported by EPA, NIH, CDC, State of Michigan and industry, including the auto industry. In the few minutes allotted, I will focus on the public health impacts of the proposed rule. I find the assessment presented by NHTSA and in the DEIS (Draft Environmental Impact Statement) is deficient or incorrect for multiple reasons.

First, the transportation sector is major source of criteria pollutants, including NOx, CO, PM2.5, toxic pollutants, e.g., VOCs, and greenhouse gases, e.g., CO2. Light duty vehicles emit most of the highway emissions of CO, 40% of PM2.5, and 56% of PM10. The transportation sector’s importance will increase as the building, industry and the power sector adopt renewables and conservation measures and reduce emissions. Vehicle emissions are important as large numbers of individuals live close to major roads and are disproportionately exposed to traffic related air pollutants, e.g., 20% of the nation or about 60 million live within 500 m or major roads, moreover, many in this large population are vulnerable to adverse health effects and will suffer adverse health effects. The NHTSA assessment states that the preferred alternative would increase PM2.5-related adverse health impacts by 135 to 299 deaths per year by 2035 due to premature mortality, acute bronchitis, and respiratory emergency room visits. If we account for deaths over the lifetime of the proposed rule, not presented in the docket, this represents between 2323 and 6685 deaths. On this basis alone, the proposed rule is not protective of public health. But this assessment is an underestimate.

Second, the NHTSA analysis of health impacts is outdated, incomplete, flawed, and arbitrary. The analysis does not attempt a quantitative analysis of impacts of greenhouse gas emissions. It does not evaluate impacts due to secondary PM, which is now approaching or exceeding the importance of primary PM. It does not appropriately account for the 60 million individuals living near large roads, nor the enhanced susceptibility of these individuals. It does not consider tropospheric O3, which will increase due to emissions and climate warming, and for which approximately 40% of the nation is in non-attainment or maintenance status of the ozone standard under the Clean Air Act. The NHTSA analysis does not properly account for the dispersion and exposure to either tailpipe and upstream emissions. It does not account for regional differences in emissions associated with the power grid and growth of renewables. It discounts pollutants other than PM2.5 and cumulative effects. It does not quantify effects from heat stress and other impacts associated with increased greenhouse gas emissions. It does not consider Impacts outside the US. The uncertainty is not plus or minus as stated in the DEIS, but is biased downwards to disregard known impacts.

Third, the alternatives presented in the DEIS do not represent the range of technically feasible and affordable options that have been achieved and demonstrated in numerous instances of control technologies and air quality management.

In summary, the regulatory analysis is flawed, incomplete, and misleading, and the selection of the least stringent alternative for the proposed rule is not protective of public health.

I will submit detailed comments on behalf of several research teams and organizations working on air quality issues to the NITSA and EPA Dockets. I thank the panel for considering these comments.

Trish Koman
Faculty Research Program Manager, College of Engineering Research Investigator, Environmental Health Sciences, School of Public Health Center Scientist, Michigan Environmental Exposure and Disease Center

Koman’s testimony contains important citations. View a pdf at this link for full sourcing. 

Thank you for this opportunity to provide oral testimony. My name is Trish Koman, and I am an environmental epidemiologist. I am also the mother of two adult children from Ann Arbor, Michigan. I conduct scientific research on the health effects of air pollution and climate-related impacts on human health. Before joining the University of Michigan 6 years ago, I served at the U.S. Environmental Protection Agency (EPA) for 22 years under both Republican and Democratic administrations as a senior environmental scientist, most recently in the Office of Transportation and Air Quality. I am currently a member of the Environmental Protection Network, an organization that includes former EPA career employees and political appointees working to preserve the nation’s bipartisan progress toward clean air, water, land and climate protection. I am also a member of the Climate Reality Leaders of Washtenaw County, Michigan, Save EPA Ann Arbor, and the American Public Health Association. The views I express are my own. I strongly urge the US Department of Transportation and the US EPA to withdraw this flawed proposal and implement the current standards as quickly as possible for the following reasons​. 1) Following Clean Air Act and the endangerment finding, the US EPA has a legal obligation to reduce greenhouse gas emissions (such as carbon dioxide (CO2 )) and to take actions requisite to protect public health from the threats of climate change. US EPA may not shirk its responsibility under the law or delegate to US Department of Transportation.

2) Our climate system is our life support; thus, climate change threatens every being on our planet. The scientific community shares a rare consensus that we are at a critical juncture while it is still possible to reduce emissions and avert the worst outcomes. As documented in the Intergovernmental Panel on Climate Change (IPCC) Fifth Assessment report, if we don’t reduce greenhouse gas emissions from all sectors, people’s health will suffer from excessive heat, worse air pollution, more frequent storms, droughts, fires, changes in vector-borne illnesses, and less nutritious grains. Importantly, vehicular emissions in the U.S. contribute to those negative health impacts and public endangerment. Thus, these negative health effects are preventable.

For example, increased temperatures and heat waves can have significant effects on health that can lead to a number of adverse health outcomes, resulting in illness, hospitalization of even death. A heat wave in Chicago killed over 700 people in Chicago in July 1995; a heat wave killed more than 70,000 people in Europe in August 2003. Areas like Michigan that are not well adapted to heat may be especially impacted. Individuals with pre-existing conditions including diabetes, chronic obstructive pulmonary disease (COPD), congestive heart failure, or heart disease are at increased risk of mortality during extreme heat events. Increased hospitalization rates for respiratory and cardiovascular diseases can also occur as a consequence of extreme heat exposure. Heat-related illness is expected to increase with increases in frequency and duration of hot days and nights (heat waves) and average temperatures due to climate change. Without significant greenhouse gas reductions, average temperatures for North America are expected to rise resulting in a significant increase in extreme heat events and therefore an increase in heat-related illnesses and deaths. 3) Because manmade CO2 concentrations are persistent in the atmosphere, emissions today affect future generations. Thus, it is imperative that emissions from mobile sources are reduced as quickly as possible to avert the worst predicted outcomes for climate change and human health. Unlike other types of air pollution with shorter atmospheric concentration residence times or where the proximity of emissions and to people is a factor, CO2 reductions contribute towards the global solution. Delays in reductions from this misguided and flawed proposal have major implications for generations. This proposal did not adequately factor in the full impact of the physical properties of CO2 concentrations on population health or equity.

4) The analysis for this proposed rulemaking did not adequately consider the health impact to vulnerable groups, and it relied on faulty assumptions about consumer behavior, vehicle miles traveled and safety implications of light-weighting. Regarding vulnerable groups, as part of a much larger body of scientific studies, my own research documents that susceptibilities and vulnerabilities can increase the impact on certain groups, such as pregnant women, children,outdoor workers, the elderly, those with pre-existing diseases, racial minorities, and people experiencing poverty. More specifically with respect to heat vulnerability, for example, young children, the elderly and people with respiratory or cardiovascular diseases, diabetes, obesity, or chronic mental health conditions are at greatest risk of being negatively affected by heat waves. Some individuals have pre-existing conditions that reduce their ability to sense heat (e.g., diabetes), the effectiveness of sweating to cool (e.g., obesity) or may be unable or unwilling to drink fluids (e.g., children under 5, the elderly or very frail, and some with religious practices such as fasting/ abstaining from water which is important here in Dearborn). Furthermore, certain socially vulnerable populations (e.g., those experiencing poverty, having low education or living in substandard housing) are more at risk in heat events as they have fewer resources to mitigate the effects of heat. These populations may be experiencing other environmental exposures such as from air pollution as documented in Southeast Michigan.

5) Because of the significant health impacts, major health organizations such as the American Public Health Association, American Academy of Pediatrics, and other members of the Medical Society Consortium have called for immediate actions to reduce greenhouse gases. This rulemaking is important to me as a parent and my community for the following reasons. I am very proud to be the mother of two young men who unfortunately will be negatively affected by this proposal. First, my older son is a teacher in an underserved elementary school in Chicago. After his first week of teaching in August, he described how hot it was in his school building – made worse by lack of air conditioning or adequate fans and the poverty of his district. His 8- and 9-year-old students have trouble paying attention because it is so hot in their apartments at night that they don’t sleep well and thus aren’t ready for the next day’s lesson. They miss school due to asthma made worse from nearby freeways. This situation will only get worse for schools around the country with this flawed proposal. Our children deserve better. My second son is training to be a US Army Officer. The US Armed Forces has long understood climate change to be a security threat. As is the case for other service men and women in uniform, this proposal will make my son’s service more hazardous – through stresses to his person such as increased heat, air pollution, fires, and storms or through increased global crises that occur as a result of the changing climate system. Because of impacts on people who work outdoors or are in the military, the existing standards should be maintained or strengthened.

Finally, despite these challenges from this flawed proposal, I want to thank the dedicated men and women at the US EPA Office of Transportation and Air Quality at the national lab in Ann Arbor whose engineering and policy competence crafted the current Clean Air Act standards in partnership with industry, affected communities, and health advocates. These existing standards are working and must be implemented in all due haste. The current standards achieve significant CO2 reductions, save consumers money, and industry agreed they were achievable. Without these standards, the nearly 900 million metric tons of CO2 reduction that this flawed proposal would forego must now be found from other sources. Accordingly, States like Michigan will be hard pressed to find more cost-effective approaches, but they must and they will. Under the Clean Air Act, States must update their State implementation plans (SIPs) and Governors will be obligated to find other local ways to reduce pollution to make up deficits in national emissions progress. It makes no sense to abandon a cost-effective, common sense program that is working to promote public health, with a roll back based on flawed analyses. In conclusion, the US EPA has a duty under the Clean Air Act to reduce greenhouse gas emissions from mobile sources in order to protect public health. The decisions we make now have lasting impact on our future because of the physical properties of CO2 concentrations, the magnitude of U.S. emissions, and the severity and distribution of the health impacts, especially for vulnerable populations. Therefore, I urge the Administration to withdraw this flawed proposal and implement and enforce the current 2012 standards vigorously​.

Larry Junck,
Michigan Medicine

I am Dr Larry Junck. I am a professor at University of Michigan Medical School and a practicing physician. I am speaking today as a citizen. The request I am making to the EPA today is NOT to weaken the CAFE standards because the proposed change would be bad for the health of the people of Michigan and of our great nation.

As a medical school professor, it is part of my mission to provide service promoting the public health, and that is the foundation for my comments today. In contrast to some of the speakers today, my comments are not geared to increase the profits of my employer or anyone else. Nobody tells me on which side of this issue I should stand. I reach my opinions based on science.

The greatest public health hazard from burning of fossil fuels is from air pollution. Air pollution causes the death of approximately 100,000 people per year in the U.S. This number is supported by studies from the World Health organization, the Global Burden of Disease project funded by the Gates foundation, and other studies. These 100,000 deaths are greater than the number of opioid deaths, also greater than the number of deaths from suicides and homicides combined. The reason you don’t hear much about deaths from air pollution is that death certificates don’t say “air pollution” – they say “heart disease”, “stroke”, “chronic lung disease”, and other conditions. These are excess deaths from these diseases because of air pollution, just as pollution from second-hand cigarette smoke is a risk factor for these diseases. The components of air pollution that are mainly responsible are tiny particles called PM2.5, which are derived mainly from vehicle exhaust and coal-fired plants, followed by ozone, which comes from vehicles and other sources of burning fossil fuels. Further evidence that air pollution from vehicles is a major cause of health problems comes from a number of studies that show higher rates of heart disease and stroke in people living within 50 to 500 m of major highways, almost certainly because of the higher levels of air pollution.

The existing EPA CAFE rules that would be weakened would decrease fuel consumption by cars and light trucks by a bit more than 20% between 2020 and 2025, and air pollution tends to follow in parallel. Do the math properly, and you will find that current CAFE plan, by decreasing pollution over that interval, would save several thousand lives per year. You, the EPA, are better equipped than I am to do an accurate scientific study of the number of increased deaths caused by your proposed change, for which I would urge you to involve qualified external scientists and to include the result in your environmental impact statement. In your proposal to weaken the standards after 2020, you claimed that this would save lives by allowing more people to afford newer safer cars. I urge you also to subject that claim to careful scientific analysis including qualified external scientists. Comparing the increased deaths from air pollution with your proposal with your claimed safety benefits, I think you will find that the weakened CAFE standards will lead to a substantial increase in deaths, also accompanied by
an increase in children with asthma missing school and growing up with disability.

For this reason, I urge you NOT to weaken the CAFE standards.