Client: Office of the California Attorney General
Authors: Liz Stanton, PhD, Gabriel Lewis, and Chirag Lala
September 2021
On behalf of the Office of the California Attorney General, this Applied Economics Clinic white paper examines the Environmental Protection Agency’s (EPA) Proposed Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards. The proposal would increase the stringency of the Safer Affordable Fuel-Efficient (SAFE) Vehicles rule from their 2020 levels, setting the emissions standards close to the path established in the 2012 National Program for controlling light-duty vehicle greenhouse gas emissions. The EPA provides an estimate of the expected benefits in its 2021 Draft Regulatory Impact Analysis (DRIA), highlighting the proposal’s energy security benefits. Our analysis finds the estimated benefits to be a conservative estimate. Other benefits not included in the cost-benefit analysis would increase the net benefits and provide additional support for stricter greenhouse gas emissions standards, if included in the EPA’s calculations. AEC also compared the 2021 DRIA with the Final Regulatory Impact Assessment (FRIA) of the implemented 2020 SAFE final rule, finding that the methodology of the 2021 DRIA is more reliable than that of the 2020 FRIA.