October 10, 2018


Coltura Comments on EPA-HQ-OAR-2018-0283-0756:

The EPA’s Clean Cars Rollback Proposal

Coltura is a nonprofit dedicated to improving climate, health and equality by accelerating the switch from gasoline vehicles to clean, zero-emission alternatives. We write today to strongly OPPOSE the administration’s plan to roll back the clean car standards.

Clean car standards are good for drivers, manufacturers, the economy, public health, air quality and healthy climate. Rolling them back won’t make us “safer” as the EPA claims. Nor will it save money. Rather, the rollback will do the opposite.

First, the EPA’s proposal will lead to more dangerous air pollution from vehicle exhaust. Burning gasoline in our cars emits highly toxic substances, including volatile organic compounds, nitrogen oxides, carbon monoxide, sulfur dioxide, and particulate matter. It’s a matter of common sense that this is a toxic mix – no one would put their face up to a tailpipe and breathe the exhaust.

Vehicle emissions account for 80% of smog-causing air pollution. They increase risks of asthma, heart and lung disease, dementia and cancers – especially in children and near busy roads.  An MIT study found that 58,000 people die prematurely in the US from vehicle emissions. The rollback would exacerbate these diseases and deaths. That’s not safer.

Second, gasoline-powered transportation is the single biggest source of carbon emissions.  Overloading the atmosphere with more CO2 (two billion tons more) will only worsen the impacts of climate change we are already seeing in severe natural disasters. The EPA admits that the clean cars rollback will result in MORE global warming, resulting in more severe natural disasters and less safety. CO2 emissions are already causing global warming and severe natural disasters. We can’t afford to make this problem even worse with fossil fuel cars. 2017 was a record year for natural disasters, causing $306 billion in damage in the US and considerable loss of life. North Carolina just experienced another “1,000 year event.” Houston had its third 500-year flood in 3 years. In Puerto Rico, 3,000 Americans lost their lives in the aftermath of the hurricanes.  Presently, Hurricane Michael, the strongest hurricane to hit the US in 50 years, and the third strongest in history, is pounding the Florida coast. California is reeling from the Mendocino Complex Fire -- the largest in California history.

The clean cars rollback would overload the atmosphere with even more CO2, causing land and ocean temperatures to rise, and leading to more extreme weather events. That’s not safer – it’s just the opposite.

Third, the rollback will cost consumers money – up to $500 a year in extra gas costs, according to M.J. Bradley & Associates. Overall, drivers will have to spend an extra $20 billion on gas by 2025, and nearly $50 billion by 2035. But it’s not just gasoline costs that will go up. People will also have to pay more in health costs from vehicle emissions. The American Lung Association report looking at just 10 states found that vehicle emissions already cost $24 billion a year in health costs in just those states. More emissions will make those costs go up. That’s not savings – it’s the opposite.


Rolling back the clean car standards is a step in the wrong direction. Instead we should be pushing for even cleaner standards – replacing gas cars altogether with clean electric vehicles. Here are a few reasons why:

·       The global trend is away from gas cars and toward EVs. Austria, Britain, China, Costa Rica, Denmark, France, Germany, India, Ireland, the Netherlands, Norway, Scotland and Taiwan have all announced plans to phase out gas cars. China is dominating the EV industry. The CEO of Shell Oil has called for Britain to move its gas car phaseout date from 2040 to 2035. British Petroleum and Shell are buying up EV charging networks. The end of the gasoline era is coming. If the US doesn’t move to clean cars, we’ll be left behind.

·       Switching to EVs is one of the most effective ways to reduce carbon emissions and decrease risks of more dangerous hurricanes, fires and droughts.

·       EVs are cheaper to fuel – $1.20 per gallon equivalent, according to the Department of Energy.

·       Thanks to falling battery costs, the price of EVs is forecast to be cheaper than equivalent gas cars by 2025.

·       EVs are safer. The batteries on the underside of the car give them a low center of gravity. EVs don’t roll.

·       Moving to EVs advances environmental and economic justice.

We also OPPOSE the EPA’s proposal to end California’s ability to set stricter vehicle emissions standards than the federal government. California has some of the worst air quality in the nation, and should be allowed to set stricter standards to address the source of 80% of its smog. California has proven that emissions reductions and economic growth go hand in hand. Let it continue to be a leader and a role model for strong, effective action on air quality and climate.

Please do the right thing by the American people. Keep the clean cars standards. Keep California’s vehicle emissions standards waiver. To do otherwise would be disastrous across the board.