Cars and Light Trucks, which threatens our state’s

October 26, 2018

The Honorable Andrew Wheeler

Acting Administrator

U.S. Environmental Protection Agency

Docket ID. No EPA-HQ-OAR-2018-0283

1200 Pennsylvania Avenue, NW

Washington DC, 20460

The Honorable Elaine Chao

Secretary

U.S. Department of Transportation

Docket ID No. NHTSA-2018-0067

1200 New Jersey Avenue, SE

Washington, DC 20590

RE: The Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule for Model Years 2021-2026

Passenger Cars and Light Trucks (Docket ID No. EPA-HQ-OAR-2018-0283 / NHTSA-2018-0067)

Dear Acting Administrator Wheeler and Secretary Chao:

On behalf of the State of Washington, I write to express strong opposition to the proposed rule

entitled Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule for Model Years 2021-2026 Passenger

Cars and Light Trucks, which threatens our state’s authority to set higher emissions reduction targets,

thwarts progress on combatting climate change, and poses a risk to our residents. For these reasons,

the Environmental Protection Agency (EPA) and the National Highway Transportation Safety

Administration (NHTSA) should withdraw this flawed proposal and uphold the California waiver

and other states’ rights to adopt its standards.

We are facing an unprecedented challenge as a nation and as a global community to combat the

threat of climate change. The recent report issued by the Intergovernmental Panel on Climate Change

is a sober reality check about the urgency of acting now to reduce carbon emissions and protect our

planet from reaching an irreversible tipping point of destructively high temperatures. Rather than

seizing the opportunity to showcase our ability to invent and build the technologies that will fuel a

carbon-free future, this proposal is doubling down on the old, polluting technologies that have helped

create this threat in the first place.

Clean car standards are some of the most economical investments ever designed to clean up pollution

– these standards have spurred manufacturers to design ways of making our cars run more cleanly

and efficiently, saving consumers billions of dollars and helping clean our air. We have witnessed

rapid and cost effective development of advanced vehicle technology spurred by California’s

regulations. Past vehicle standards have been achieved faster and at lower cost than experts

predicted, and those standards have helped consumers by delivering cleaner, more efficient

vehicles.

In Washington State, we have adopted aggressive greenhouse gas (GHG) reduction targets. Motor

vehicles are by far our largest source of those emissions. As a Section 177 state, Washington relies

on the California Advanced Clean Cars program to maximize vehicle emission reductions and drive

the development of a cleaner, low-carbon transportation sector. Maintaining California’s authority to

adopt motor vehicle emission standards and the right for states like Washington to opt into those

The Honorable Andrew Wheeler

The Honorable Elaine Chao

October 26, 2018

Page 2

standards, is vitally important to achieving our goals and protecting our communities. We will not

meet our targets without significant additional reductions from the transportation sector. The

proposed rollback of federal standards, if allowed to stand, could add over 2.5 MMT of GHG

emissions into Washington’s atmosphere by 2035.

This Administration’s proposal to withdraw the existing federal standards under the unified national

program is an unacceptable abdication of leadership at a time when the stakes for the health and

safety of Americans couldn’t be higher. Furthermore, it undermines our state’s ability to mitigate

those threats at this critical time. It fails to uphold needed and achievable national standards,

undermines states’ rights and threatens the health and safety of our residents. For these reasons, this

proposal must be withdrawn.

Enclosed, please find a comprehensive evaluation by the Washington State Department of Ecology

detailing the shortcomings and dangers of this proposal. If you have any questions, please contact my

office in Washington, DC (Casey Katims, Director, Casey.Katims@gov.wa.gov, or Sharlett Mena,

Deputy Director, Sharlett.Mena@gov.wa.gov).

Very truly yours,

Jay Inslee

Governor

Enclosure