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1 1 (September 27, 2021)

handle is hein.amenin/aeiaecx0001 and id is 1 raw text is: N~ ~ AMERK.CAN \ ENTEF.RPRSE Comment to the Environmental Protection Agency Proposed Rule to Revise Existing National GHG Emissions Standards for Passenger Cars and Light Trucks Through Model Year 2026 Document ID No. EPA-HQ-OAR-2021-0208-0116 Federal Register August 10, 2021, 86 FR 43276 FRL 8469-02-OAR RIN 2060-AV13 Benjamin Zycher Senior Fellow, American Enterprise Institute September 27, 2021 Submitted through the Federal eRulemaking Portal at htths://www~regu atins 1ovdocument/EPA- HO-OA R-2O21-0208-1 16 The Environmental Protection Agency Proposed Rule to Revise Existing National GHG Emissions Standards for Passenger Cars and Light Trucks Through Model Year 2026 is fatally flawed methodologically, and in particular cannot satisfy a standard benefit/cost test even assuming the quantitative estimates provided in the Proposed Rule and the accompanying Regulatory Impact Analysis. It does not provide a reliable guide for the estimation of the magnitude of an assumed greenhouse gas externality in the passenger car and light truck sector, and it does not and cannot provide a rigorous basis for an updated analysis in support of the future promulgation of greenhouse gas policies generally. Accordingly, the Proposed Rule is inappropriate; it must not be finalized in its current form, and any such finalization must reflect a very substantial revision of the underlying analysis. Any such updated analysis based upon the same or similar methodologies and assumptions similarly will be fatally flawed. Summary This comment letter to the Environmental Protection Agency (EPA) addresses the Proposed Rule and the draft Regulatory Impact Analysis (RIA) on greenhouse gas (GHG) emissions from passenger cars and light trucks through model year 2026, which by necessity devolves into a regulation on fuel mileage standards. The arguments presented below can be summarized as follows. The American Enterprise Institute (AEI) is a nonpartisan, nonprofit, 501(c)(3) educational organization and does not take institutional positions on any issues. The views expressed in this comment are those of the author.

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