Columbus, OH – On Monday, The Buckeye Institute filed two sets of public comments—one from Buckeye’s policy experts, the other from Buckeye’s legal experts—outlining the technical and legal reasons the U.S. Environmental Protection Agency (EPA) should rescind its 2009 greenhouse gas endangerment finding and motor-vehicle greenhouse gas standards, which have driven up the price of cars and trucks for American consumers.

In its technical comments, The Buckeye Institute notes that repealing the motor-vehicle greenhouse gas standards is an “opportunity to correct a program that imposes heavy costs without producing measurable climate benefits.” Buckeye shows how the standards “fail the tests of efficiency, equity, and statutory alignment…drive up new-vehicle prices, distort capital allocation, slow fleet turnover, and generate compliance credits detached from real-world emissions reductions.” Buckeye’s technical comments point out that “Even if every U.S. car and truck stopped emitting CO2 tomorrow, the effect on global temperatures would be too small to detect,” and “that the resulting higher vehicle prices slow down fleet renewal, keeping older, dirtier vehicles on the road longer.” Repeal, Buckeye concludes, “offers a practical way forward.”

In its legal comments, The Buckeye Institute notes that Congress never authorized the U.S. EPA to use the nebulous and malleable “market failure” concept to impose its will and choices upon consumers and manufacturers. In fact, “Congress specifically limited EPA’s considerations to ‘cost, energy, and safety factors associated with the application of [available] technology.’” Buckeye further argues that the EPA exceeded its authority under the Administrative Procedure Act by taking into account “foreign or global concerns” in issuing the greenhouse gas endangerment finding and the motor-vehicle greenhouse gas standards.” “Federal agencies exist to protect the rights and interests of Americans, not non-citizens living around the world.”

Sai C. Martha, an economic research analyst at The Buckeye Institute, authored the technical comments. David C. Tryon, director of litigation, and Bret Baker, legal fellow, authored the legal comments.

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