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EPA’s own analysis shows fuel efficiency rollback will kill people and cost money

The Environmental Protection Agency (EPA) is attempting to revoke California’s authority to set its own emissions rules, a right enshrined in federal law that California has had for over 50 years. We recently covered why the EPA will have a hard time winning this fight.

In a move that seems to come straight out of George Orwell’s Ministry of Truth, the administration has applied the acronym “SAFE” to their effort. This stands for, if you can believe it, “Safe and Affordable Fuel Efficient vehicles.”

The problem is that this rule is neither about safety, affordability, or fuel efficiency.  And we need look no further than the EPA’s own analysis, and statements from its former career scientists, to show this.

It turns out that the EPA has been around for a while, and in that time, it has commonly been staffed by people who are interested in science and data analysis. This as opposed its current political leadership, who are more interested in political ploys to protect their buddies in the failing coal industry and denials that air pollution is bad for you.

And in those years, the EPA produced multiple analyses of the very law at the center of this waiver process: the bipartisan, landmark Clean Air Act. These studies are still posted on the EPA’s website.

EPA’s own science reveals the adminstration’s lie

The first analysis, from 1997, found that in the first 20 years of the law, it avoided 205,000 premature deaths; avoided millions of illnesses including heart disease, chronic bronchitis, asthma attacks, hypertension, and stroke; resulted in increased child IQ; and saved the country between $6 trillion to $50 trillion with a mean estimate of $22 trillion.

The estimate also stated that the total cost to achieve these pollution reductions was $523 billion, which means that these costs resulted in a 40:1 return on investment in the mean benefit scenario.

Were it not for the Clean Air Act, the EPA estimated that air quality from particulate matter in several large US cities would have been bad enough to put them on the list of the most polluted cities in the world — worse than Bangkok, Manila, Mumbai, or even Delhi (one of the top 10 most polluted cities in the world).

A later analysis, from 2011, analyzed the effects of additional amendments to the Clean Air Act from 1990-2020. In this analysis, benefits exceeded costs by 30:1 over this time period, and avoided another 230,000 early deaths, 200,000 heart attacks, 2.4 million cases of exacerbated asthma, 5.4 million lost school days, and 17 million lost work days.

These analyses focus primarily on the Clean Air Act overall, not only on the vehicle-related portions of it. But then again, vehicle regulations are not the only way in which this administration has worked to make the air dirtier and deadlier.

An analysis specific to the Obama-era standards concluded that it would result in US consumers saving a total of $1.7 trillion in lower fuel costs, with an average savings of more than $8,000 per vehicle based on the 2025 54.5 mpg standard. This would reduce foreign oil dependency by a total of 12 billion barrels and eliminate 6 billion tons of greenhouse gas emissions.

We talked to EPA scientists who have done further analysis of this rollback to show exactly how this administration’s actions will affect the country negatively.

Former EPA scientists respond

After yesterday’s piece, we were contacted by the Environmental Protection Network, a group that includes more than 450 former high-level EPA administrators, scientists, economists, attorneys, and others who remain committed to advocating for the EPA’s mission to protect the environment.

Electrek had a short phone interview with Trish Koman, a senior environmental scientist for 21 years with the Office of Transportation and Air Quality, and Jeff Alson, a senior engineer and policy adviser for 40 years. Alson was directly involved in crafting the Obama-era clean car standards that have been rolled back by this administration, and Koman was involved in other pollution rules and responsible for cost-benefit analyses.

Koman pointed out that the Environmental Defense Fund produced an analysis (which can be found here in the EPA’s public comment docket) using standard EPA methods to show that the fuel efficiency rollback would result in between 14,501 and 32,362 premature deaths in the coming decades. In addition, it would result in 40,000 emergency room visits, 10 million lost work days, 2.3 million cases of asthma exacerbation, and between 10,000 and 94,000 non-fatal heart attacks. Koman is a member of the American Public Health Association, who wrote a letter to the EPA stating their opposition to this rollback and citing the aforementioned public health harms.

She wanted to remind the public that “just as in the Vietnam War, we need to remind the public of the difference between the ‘troops’ and the political leadership” who are making these decisions. She urged the public to remember that the rank-and-file staff at the EPA are, for the most part, dedicated to the science of environmental protection.

Those staff “do the credible scientific work that allows the public to understand the trade-offs and implications of various policy options on the nation’s health, the economy, children’s health, and environmental justice communities” — when they are allowed to do their jobs, anyway. And with the scale of the current climate crisis, the EPA needs to be involved in any global solutions, and we “need good people at the EPA” to do the work properly.

The problem is that this administration has locked those dedicated EPA scientists out of the process of policy analysis in an “unprecedented” manner. Alson told Electrek that the analysis of the so-called “SAFE” rules was done entirely by the National Highway Traffic Safety Administration (NHTSA), and that “EPA staff were completely locked out of participating,” even though the final rules used the EPA’s name and logo. Representatives of the EPA responded by writing a letter on public record to the Office of Management and Budget demanding the logo be removed from the final analysis.

After a 40-year career at the EPA, Alson retired in 2017, thinking he could do better from the outside. He did, however, provide “pep talks” to his former colleagues, encouraging them to stay the course and not be discouraged by their temporary political leadership. Since his retirement, Alson has been leading the charge to reveal the ridiculous methods used by the administration to justify their assertion that these rules will make cars “safer.”

Safer? More Affordable? …Really?

So where do the authors of this “SAFE” rule get the idea that this will make cars safer?  According to Alson, the crux of the administration’s rationale is that if cars cost more to fuel, people won’t drive as much. And if people don’t drive as much, then there will be fewer total road deaths from accidents.

Even under this assumption, no cars are actually made any safer per mile, which is generally what we consider when thinking about safety.  In fact, they are more dangerous per mile, as they will be less efficient and thus emit more toxic pollutants that all of us breathe each moment of our lives.

But this analysis runs counter to the administration’s other assertion, that “SAFE” will make cars more “affordable.” Even within their own flawed analysis of their own rule, they contradict themselves.


The administration is, clearly, being disingenuous about its justifications for this move. It will cost consumers more money both in fuel and health costs, it will hurt the environment, it causes regulatory uncertainty for automakers who asked the administration to reconsider it, and it certainly won’t make cars any safer.

It seems that nobody wants this to happen, and yet they charge forward anyway. The only group that could conceivably benefit from this is the fossil lobby — who, incidentally, had a man on the inside in previous EPA administrator Scott Pruitt, who was in charge when the battle with California over clean air started.

This can’t end soon enough. The political leadership of the Environmental Protection Agency needs to stop acting to make the environment worse, and start doing the job their agency was created for and is legislatively required to do. Picking losing fights with California is not part of that job.

The EPA was scheduled to revoke this waiver today, but the day passed with no official announcement of the revocation (other than a series of tweets from a former reality TV host). We reached out to the EPA for comment, but their press contact line was disconnected. They also did not respond to email.

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Avatar for Jameson Dow Jameson Dow

Jameson has been driving electric vehicles since 2009, and has been writing about them and about clean energy for since 2016.

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