Internal-combustion engines are essential to the transportation sector. The spark-ignition car, fueled by gasoline, transformed American life, enabling freedom of mobility like never before. Similarly, compression-ignition trucks powered by energy-dense diesel have “profound socioeconomic consequences.” They are the “backbone of food deliveries, as well as a key link in the distribution of industrial parts and manufactured goods.” Motor vehicles—and the prosperity they unlock—are virtually all powered by internal-combustion engines that rely upon abundant, energy-dense, liquid fuels.
Although these prime movers are essential to modern economic life, they are threatened by misguided policies. In the United States, these efforts culminated in the Biden Administration’s “whole-of-government” plan to phase out the internal-combustion engine from the Nation’s roads. To carry that plan, EPA turned to Section 202(a) of the Clean Air Act. Specifically, the Biden EPA set carbon-dioxide standards for new motor vehicles that internal-combustion motor vehicles cannot meet. Under the Biden EPA’s regulations, roughly 70% of new passenger cars and light trucks and nearly half of new heavy-duty trucks would have to be plug-in electric vehicles by model year 2032. In other words, the market share of new internal-combustion motor vehicles must plummet under the final rules. EPA’s plan to end the internal-combustion engine would be disastrous. To meet the standards, given flagging demand for battery-electric motor vehicles, manufacturers would have to reduce sales of new internal-combustion motor vehicles, leading to shortages and price hikes similar to the ones California is already experiencing in the market for heavy-duty vehicles.
EPA now proposes to reconsider the 2009 “Endangerment Finding” for greenhouse gas emissions from new motor vehicles. EPA accordingly proposes to repeal all greenhouse gas standards promulgated under Section 202(a) of the Clean Air Act. The Prime Mover Institute supports the Proposed Rule and urges the EPA to adopt the primary legal rationale, the alternative scientific rationale, and the separate bases for repeal, as detailed in our comments below. Prime Mover Institute, however, also urges EPA to freeze the carbon-dioxide standards at model year 2026 as a backup alternative. A belt-and-suspenders approach will give a final rule the best chance of withstanding legal scrutiny and avoiding the serious economic dislocations the Biden EPA rules would otherwise cause.