Comment Log Display

The statement below represents the comments of 114 Ph.D. economists
from around the nation. Please see the attached document (pdf) to
view the full list of signers.

The statement below represents the comments of 114 Ph.D. economists
from around the nation. Please see the attached document (pdf) to
view the full list of signers.

Gina McCarthy 
Assistant Administrator 
Office of Air and Radiation 
U.S. Environmental Protection Agency 
1200 Pennsylvania Avenue N.W. 
Washington, DC 20004 

David Strickland 
Administrator 
National Highway Traffic Safety Administration 
1200 New Jersey Avenue, SE, West Building 
Washington, DC 20590 

Mary D. Nichols 
Chairman, California Air Resources Board 
1001 I Street 
P.O. Box 2815 
Sacramento CA 95812 

June 7, 2011 

Dear Assistant Administrator McCarthy, Administrator Strickland,
and Chairman Nichols: 

Last year, the Environmental Protection Agency (EPA), the National
Highway Traffic Safety Administration (NHTSA), and the California
Air Resources Board (CARB) worked together to set standards through
2016 that would raise the average fuel efficiency of new vehicles
to about 34.1 miles per gallon and cut the average global warming
pollution from new vehicles to about 250 grams per mile. Now, your
agencies are working together to develop the second phase of
standards covering new vehicles sold in model years 2017-2025 that
could cut new vehicle global warming emissions up to an additional
45 percent and raise fuel efficiency standards to as much as 60
miles per gallon. 

Strong, cost-effective standards will provide consumers with a
wider choice of cleaner and more fuel efficient vehicles that save
drivers money. In the absence of standards, market barriers prevent
drivers from realizing these savings, leaving drivers without the
options they need to respond to volatile and rising gasoline
prices. Standards are the right policy approach given the realities
of this marketplace. 

Our continued dependence on oil puts our economy at risk from the
effects of oil price volatility and energy insecurity. Oil price
spikes were associated with most of the U.S. recessions in the past
40 years.1 The United States currently sends $1 billion each day to
foreign countries to pay for oil and other petroleum products—that
is equivalent to more than half of the average daily U.S. trade
deficit over the last decade.2 

Strong standards that save drivers money can also support robust
employment. Increasing standards will promote new vehicle
technologies and increase investment in the auto industry,
generating new jobs throughout that sector. The savings consumers
realize at the pump will also shift consumer purchases away from
the petroleum and wholesale industries to other parts of the
economy that generate more jobs for every dollar spent.3

Finally, strong standards will help reduce the heat-trapping
emissions that cause global warming. Current and projected climate
change impacts pose significant risks to public health, the
economy, and the environment. Delaying action now and waiting for
the future before initiating accelerated action to reduce global
warming emissions would be more costly than initiating action now.


We support these efforts to reduce global warming emissions,
improve the fuel efficiency of our vehicles, reduce our dependence
on oil, and protect public health by ensuring drivers have more
choices for clean cars and light trucks through the use of strong,
cost-effective standards. 

Signed,
SEE ATTACHMENT FOR LIST OF SIGNERS

1 Causes and Consequences of the Oil Shock of 2007–08,
http://www.brookings.edu/~/media/Files/Programs/ES/BPEA/2009_spring_bpea_papers/2009a_bpea_hamilton.pdf
What is An Oil Shock, Hamilton (2003)
http://dss.ucsd.edu/~jhamilto/oil.pdf 

2. Cost of petroleum imports based on U.S. Energy Information
Agency data, net petroleum product imports between March 19th 2010
and March 18th 2011 averaged 9.6 million barrels per day. At $100
per barrel, this equates to $960 million dollars per day. EIA data
available at:
http://www.eia.doe.gov/dnav/pet/pet_move_wkly_dc_NUS-Z00_mbblpd_w.htm
Historical U.S. trade data from the U.S. BEA available at:
http://www.bea.gov/newsreleases/international/trade/trad_time_series.xls


3. Based on data from the Bureau of Labor Statistics,
http://www.bls.gov/emp/ep_data_industry_out_and_emp.htm