The Energy Policy Research Foundation (EPRINC) appreciates the opportunity to submit comments on the proposed rule entitled “Reconsideration of 2009 Endangerment Finding and Greenhouse Gas Vehicle Standards” (“Proposed Rule”).
EPRINC was established in 1944 and is based in Washington DC. It is an independent, not-for-profit, and non-partisan research institution that focuses on policy issues at the intersection of energy, economics, and security with special emphasis on oil, natural gas, petroleum products, electricity markets, and energy transitions. EPRINC is recognized internationally for providing objective and technical analyses on these topics. Its research is routinely presented at U.S. and international conferences organized by trade associations, educational institutions, and government agencies. It has been a source of expertise for numerous government studies, and its chairman and president have contributed to virtually every National Petroleum Council study.
One of the key questions raised in the Proposed Rule is the contribution of greenhouse gas (GHG) emissions from new U.S. light-duty vehicles (LDVs) and medium-duty vehicles (MDVs) to global GHG emissions that may cause an endangerment. On page 36,311, the Proposed Rule notes that GHG emissions from LDVs and MDVs in the U.S. “amounted to approximately 1.8 percent of global GHG emissions in 2022.” The Proposed Rule also correctly notes that these percentages do not account for trends demonstrating that the United States has been decreasing absolute GHG emissions while other countries, like China, are significantly increasing their GHG emissions.