Clean Cars Are a Win All-Around

The cars and trucks on our road help to get us around, but they are also a major source of pollution that not only harms our climate, but also our air quality and our health. The United States has set important goals—such as the Biden Administration's goal to achieve net zero emissions by 2050—and commitments by joining the Paris Agreement. 

However, there will need to be a whole-of-government approach to tackling transportation sector emissions, which are the largest source of carbon pollution and a major source of toxic pollutants (such as particulate matter and nitrogen oxide) that harm human health. One such approach that has continued to provide success is the U.S. Environmental Protection Agency’s (EPA) clean car and clean truck tailpipe emission standards. 

EPA recently released a proposal for new tailpipe emission standards for cleaner passenger cars and trucks, as well as for heavier duty trucks. The proposed standards build upon EPA’s previous federal greenhouse gas emissions standards for cars and light trucks for model years 2023 through 2026. They also build on state action and incentives for clean cars and trucks in last year’s Inflation Reduction Act, which has been followed by the announcement of more than $210 billion in electric vehicle-related manufacturing and battery investments in the U.S. 

NRDC and other public interest advocates have issued calls for EPA to finish the job for cleaner cars as swiftly as possible, since cleaner cars are a win for public health, a win for consumers, and a win for the environment – and this action from EPA is the next step to answering this call.

To learn more about the importance of clean vehicle standards, check out Kathy’s testimony before the Senate Environment and Public Works subcommittee on Clean Air, Climate, and Nuclear Safety. You can also watch the full hearing entitled, “Cleaner Vehicles: Good for Consumers and Public Health.”

The Proposal

EPA is proposing both greenhouse gas and criteria pollutant standards for light-duty and medium-duty vehicles for vehicle model years 2027 through 2032. The proposed criteria pollutant standards are projected to reduce particulate matter emissions by 95% and nitrogen oxide by 60%. 

In addition to the proposed greenhouse gas standards, EPA is seeking comment on three alternative levels of greenhouse gas stringency, the range of standards across these alternatives and the proposal, whether the trajectory of the standards should ramp up at a slower rate in the earlier years of the regulations, and if EPA should consider setting standards beyond model year 2032 and out to model year 2035.

While EPA’s proposal is a good start, the agency should finalize the most stringent standards feasible to protect public health, meet our climate targets, and save consumers money. Accordingly, EPA should finalize a standard that is at least as strong as "Alternative 1" of their greenhouse gas proposal (which is the strongest version in the agency’s proposal) and put the United States on a path to 100% of new vehicles being zero emission by 2035.

The Proposed GHG Standards for Light-Duty Vehicles

EPA’s preferred proposal is projected to result in a 56% reduction in projected fleet average greenhouse gas emissions target levels, relative to the existing model year 2026 standards. Although EPA estimates that these emission standards will be met through approximately 67% new zero-emission vehicle sales, it is important to note that these standards are NOT sales requirements, but are instead based on EPA’s projections for how they believe manufacturers will choose to comply with the agency’s standard. 

Alternative 1 (Strongest Proposed)

Alternative 1 is the strongest version of the proposed rule, and EPA should finalize a standard that is at least as strong as this option. This alternative version of the rule includes a larger increase in stringency between model year 2026 and model year 2027, the current standard and the start of the proposed regulation, respectively. This stronger alternative proposal would allow for the emissions benefits to be realized sooner, than would occur under the “proposed” standard and the other weaker alternative proposals provided for comment. Alternative 1 is 10g/mi more stringent than EPA’s preferred approach (by the time the standard fully ramps in during model year 2032) and the agency estimates that compliance should result in 69% of new vehicle sales being zero-emission vehicle.  

Alternative 2 (Weakest Version Proposed)

This version of the rule would involve a smaller increase in stringency between model year 2026 and the start of this regulation in model year 2027. EPA asserts that this version of the regulation would be inappropriate because it would forgo feasible emissions reductions that would improve public health and welfare. We agree.

Alternative 3 

This alternative is crafted with a smaller increase in stringency in early years of the standard and larger reductions occurring in the later regulated years. This version of the rule is designed to generate roughly equal reductions in greenhouse gas emissions while still hitting the same overall reductions targets for model year 2032. EPA also asserts that this version of the regulation would be inappropriate for the same reason Alternative 2 would be, since it would forgo feasible emissions reductions that would improve public health and welfare. We also agree.

The Proposed GHG Standards for Medium-Duty Vehicles

For medium-duty vehicles (like delivery vans), EPA is proposing to revise the existing standards for model year 2027 through model year 2032. The agency considers these updates to be feasible given the opportunities for increased greenhouse gas reducing technologies (like electrification) in this sector and within this time frame. The standards would increase in stringency year-over-year, and when fully phased in by vehicle model year 2032, these standards are projected to result in a 44% reduction in projected fleet average greenhouse emissions levels, relative to the current model year 2026 standards. EPA is estimating that this reduction will be met by approximately 46% new medium-duty vehicles being zero-emission vehicles. 

The Proposed Criteria Pollutant Emission Standards 

For light-duty vehicles, EPA is proposing emission standards that will reduce criteria pollutants from vehicle tailpipes, such as particulate matter, Nitrogen Oxide (NOx) and non-methane organic gas (NMOG). The proposed particulate matter regulations would reduce these emissions by approximately 95% and are likely to be met by the installation of gasoline particulate filters. NOx and NMOG emissions are proposed to be reduced by 60% by 2032.

For medium-duty vehicles, EPA is also proposing stronger standards to reduce toxic pollutants from these vehicles. EPA is proposing identical particulate matter standards as the light-duty vehicles that would result in a 95% reduction of these emissions. EPA is also proposing a reduction of NOx and NMOG emissions by 66-76%, depending on the vehicle size. 

Additional Considerations for the Agency

While it is ultimately EPA’s main responsibility to set standards that are feasible and deliver clean air and environmental protections, we recognize that there are other considerations that ultimately impact the level of stringency that the agency is comfortable finalizing. This section explores some of these considerations.

Supply Chain Considerations 

The market is moving quickly toward an increasing share of zero-emission vehicles and automakers have already made commitments to transition their fleets in the next decade. Additionally, state-level vehicle emissions policies, like the Advanced Clean Cars rules, work complementary to federal-level efforts and the historic investments from Congress and help increase car model availability and affordability. 

While it is true that there are some near-term supply chain issues, those near-term constraints must be viewed in context. First, supply chain constraints can affect vehicles of all types, not just electric vehicles. The global chip shortage has impacted zero-emission vehicles and gas-powered vehicles alike, and recent increases in global oil prices have also uniquely impacted those polluting vehicles. There is reason to believe that today’s zero-emission vehicle supply chain constraints – including critical mineral concerns – will be resolved in time to comply with these future standards, in part due to the investments from the federal government to help bring these supply chains to the United States.

Economic Considerations 

Consumers are expected to benefit from significant cost savings on operating costs over the lifetime of a vehicle that meets the proposed standards. For all vehicles meeting the standards, these savings include fuel savings and, for battery electric vehicles, maintenance, and repair savings as well. In fact, EPA is estimating that drivers will save up to $13,000 during the initial ownership of an electric vehicle compared to its gas-powered counterpart.

The economics will only continue to improve due to advances in battery technology and increased zero-emission vehicle production. Additionally, a growing set of state, federal, and utility incentives from the Inflation Reduction Act, bipartisan infrastructure law and other federal and state programs will further reduce zero emission vehicle costs.

Additionally, emission standards have a proven track record of promoting investment in the U.S. auto sector and in creating jobs. We have an enormous opportunity to ensure the vehicles of the future are built at home and by complimenting these investments with the right policies, we can also ensure that the jobs that result are high-quality jobs. 

Charing Infrastructure and Grid Considerations

Most driving occurs for people’s daily commutes for work and errands, and those average about 30 miles per day or less. For those trips people can charge at home. For longer trips, drivers will need to access public chargers, and numerous state and federal investments will help accelerate the build-out of charging infrastructure for drivers traveling long distances. For example, the bipartisan infrastructure law specifically established the National Electric Vehicle Infrastructure (NEVI) program to provide funding for a strategically built, interconnected, accessible, and reliable nationwide charging network.

Additionally, if you are concerned about whether our nation’s electricity grid can handle all of the electric vehicles that will be coming over the years, it certainly can. The grid is built for the most demanding hour of the year and every other hour there is excess capacity. 

Powering vehicles from the grid will also deliver growing public-health and environmental benefits since battery electric vehicles are much cleaner than gas-powered vehicles, from cradle to grave, and will only getting cleaner as the grid becomes increasingly powered by clean renewable energy sources.

For more information on how electric vehicles improve grid reliability, see this blog.

Next Steps & How You Can Help

EPA must finalize a rule at least as strong as Alternative 1 to achieve the goals of the Paris Agreement and to maximize the benefits of this regulation in terms of climate, air quality, human health, and consumer savings. Doing so will provide us with the best opportunity to stay competitive with the rest of the world as the global transition to a cleaner vehicle future occurs.

EPA is seeking comment on this proposal through July 5, 2023. NRDC and other public-interest groups and stakeholders will be providing comments and will push the EPA to finalize the strongest possible standard to protect public health and our climate. Every voice counts—you too can help by telling EPA to adopt the strongest rule