IN OPPOSITION RE: OAR-2022-0829
To: Environmental Protection Agency
I am writing to express my opposition to the proposed tailpipe emissions rule outlined in EPA-HQ-OAR-2022-0829. As proposed, I believe these regulations for light-duty vehicles go too far, reduce consumer choice, and fail to include safeguards to address serious infrastructure, resource, and funding shortfalls.
Firstly, the country’s current charging infrastructure is inadequate to support a forced shift towards electric vehicles. Charging infrastructure is not yet fully developed or accessible in many regions of the country. Forcing consumers to transition to EVs without ensuring sufficient charging infrastructure could place undue burdens on drivers across the country.
Secondly, by not taking any significant steps to improve permitting for the mining of critical minerals in America, we are endangering our ability to access the minerals required for EV production. This over-reliance on foreign sources of minerals could undermine our domestic energy security and jeopardize our nation’s economic independence. After seeing how international supply chains can break down during the pandemic, American consumers cannot and should not be subject to increased reliance on unstable foreign supply chains, especially concerning something as vital as personal transportation.
Additionally, I am concerned about how these new standards could negatively impact the Highway Trust Fund. If implemented without addressing the funding structure, these proposed regulations could strain the already precarious state of transportation funding. It is crucial to consider additional solutions, such as a Low Carbon Fuel Standard, to address the revenue lost by having fewer internal-combustion engines on the road.
In conclusion, I strongly urge the EPA to reconsider the proposed tailpipe emissions rules. It is crucial that the EPA engage in meaningful collaboration with Congress, automotive manufacturers, and other stakeholders to develop a comprehensive approach that accounts for the current limitations in charging infrastructure, safeguards consumer choice, promotes domestic energy security, and ensures the continued funding of our vital transportation infrastructure.
Thank you for your attention to this critical matter.
Sincerely,
Roy Littlefield IV
Tire Industry Association
The EPA’s recently proposed tailpipe emissions rule could have far-reaching impacts on our economy, the automobile market, national security, and transportation infrastructure.
Here’s how:
• AUTO MARKET TRANSITION: Under this rule, two-thirds of all light-duty vehicles sold in the country must be all-electric by 2032. For reference, electric vehicles only made up 6 percent of total sales in 2022. The EPA is asking for over ten times that amount in less than a decade.
• ELECTRIC VEHICLE INFRASTRUCTURE: These rules would put millions of new electric vehicles on the road without the charging infrastructure necessary to deal with such an influx. If you don’t live in a big city with well built-out EV charging infrastructure, this could mean running out of charge when you need it most.
• CRITICAL MINERALS AND NATIONAL SECURITY: The U.S. relies heavily on imported minerals like lithium, cobalt, manganese nickel, and graphite to make batteries for electric vehicles. This proposal does not address improving the permitting process for mining these critical resources in America, which could mean relying on hostile nations like China for our energy needs for decades to come.
• DECREASED HIGHWAY FUNDING: With the decline of internal combustion engines, revenue from gas taxes, a primary source of funding for the Highway Trust Fund, will dwindle. This could create a significant funding gap that could hamper our ability to carry out vital road repairs and infrastructure projects.
We can't allow this far-reaching policy to go unchecked.