Dear Secretary Chao, Acting Administrator Wheeler, Deputy Administrator King, and Assistant Administrator Wehrum:
I write today on behalf of the U.S. Climate Alliance – a bipartisan coalition of 17 governors representing 40 percent of the U.S. population - to strongly oppose the Notice of Proposed Rulemaking (NPRM) titled “The Safer Affordable Fuel-Efficient Vehicles Rule for Model Years 2021-2026 Passenger Cars and Light Trucks.” The U.S. Climate Alliance resolutely supports the 18 jurisdictions representing 140 million Americans that are suing to defend existing standards for fuel-efficiency and greenhouse gas emissions. The Alliance further supports preserving state flexibility to adopt standards more protective than the federal standards. The existing standards are producing the cleanest and safest vehicles we have ever had—all while addressing the largest source of climate pollution in the United States.
The United States continues to need strong clean car standards that reduce vehicle pollution and improve efficiency to protect our health, environment and climate, while strengthening U.S. manufacturing competitiveness and creating American jobs. The Alliance opposes this effort by the U.S. Environmental Protection Agency and National Highway Traffic Safety Administration to weaken these standards, as it will not only cost our residents more at the pump, but hurt children, senior citizens and people living with respiratory illness. It will limit the ability of Alliance states to meet their own emission reduction targets and take crucial climate action.
Recognizing that climate change presents a serious threat to our environment, residents, communities, and economy, the Alliance remains committed to meeting its share of the U.S. emissions reduction contribution to the Paris Agreement. This proposal to roll back the standards undermines one of the country’s best climate programs and constitutes an unwarranted attack on consumers, our environment, our health, and longstanding tenets of cooperative federalism enshrined in the Clean Air Act. We urge you to withdraw the proposal.
Julie Cerqueira, Executive Director, U.S. Climate Alliance
13 September 2018 | Global Climate Action Summit
Across every sector, U.S. Climate Alliance states continue to lead the nation in reducing greenhouse gas emissions (GHGs) and have done so while growing our economies faster than the rest of the nation and creating 1.3 million clean energy jobs. We have worked across party lines to share our experiences and find common solutions and as a result, are already more than halfway to reaching our share of the U.S.’ Paris Agreement emission reduction goals.
However, in the last year, the federal rollback of our nation’s climate framework has had real consequences. These measures are projected to slow the reduction of carbon pollution across the country - putting the health of American families at risk and raising the costs to our communities and businesses from climate impacts. In the last year alone, extreme weather events, exacerbated by climate change, ravaged our communities and cost the United States over $300 billion.
As leaders, we cannot ignore reality. We must continue to put politics aside and focus on the solutions at hand. The urgency of the climate crisis demands more innovation and ambition. We therefore reiterate our commitment to meeting our share of the Paris Agreement’s emission reduction goals and announce a suite of new actions to further address climate change.
The U.S. Climate Alliance is committed to taking the following new actions:
| Protect our Natural and Working Lands
We recognize that we cannot achieve the goals of the Paris Agreement by mitigating emission through power, transportation and industry alone. We must pull harmful carbon out of our atmosphere as fast as possible. We therefore resolve to protect and sequester carbon in our lands and will integrate actions and pathways into state GHG mitigation plans by 2020. Through these actions, we also will help secure the livelihoods of farmers, ranchers and foresters, protect our food systems and water quality, and preserve our nation’s natural beauty for all our residents for generations to come.
| Drive Down Potent Short-Lived Climate Pollutants
Reducing short-lived climate pollutants (SLCPs) - such as methane, hydrofluorocarbons (HFCs) and black carbon – can avoid as many as roughly 200,000 premature deaths and 6 million tons of crop losses annually in the United States in 2030.[i] Action on SLCPs also presents a tremendous economic opportunity for U.S. companies at the cutting edge of SLCP solutions.
Building on our commitment under the Short-Lived Climate Pollutant Challenge, we are releasing the SLCP Challenge to Action Roadmap, which provides a framework that has the potential to reduce our collective SLCPs emissions by as much as 40-50 percent by 2030. We also commit to develop and implement state-specific strategies to support this goal. As a first step, Virginia announces that it is beginning a process to limit methane pollution from natural gas infrastructure and landfills.
To further demonstrate our commitment to lead, Connecticut, Maryland and New York announce their intention to propose regulations in 2019 to prohibit the use of high-warming HFCs, consistent with the 2015 and 2016 EPA SNAP Rules. These proposed regulations will be substantially consistent across these states and with the regulations recently adopted in California. The U.S. Climate Alliance commits to accelerating the replacement of climate warming HFCs through voluntary and regulatory approaches, and Alliance states will work together in the coming year to explore actions appropriate for each of our states.
| Transform Transportation to Reduce Emissions
Transportation is the largest source of GHG emissions in the U.S. today. Alliance states are already reducing transportation emissions at 3 times the rate of the rest of the United States, and three out of four zero-emission vehicles (ZEVs) on American roads are in our states.[ii] Building on this momentum, we resolve to continue transforming the transportation sector towards deep emissions reductions. Together, the 17 states and territories that make up the U.S. Climate Alliance are investing billions of dollars in infrastructure and vehicle deployment through state programs, mitigation funding, and utility and private investments. Today we announce the deployment of $1.4bn from the auto settlement to drive down our transportation emissions, and challenge the rest of the states to deploy all available resources towards the same effort.
| Increase Access to Affordable Clean Energy for All
All Americans should have the right to clean, affordable power. U.S. Climate Alliance governors are united in their opposition to the misguided federal import tariffs on solar panels and cells, which are forecasted to reduce solar installations and cause the loss of roughly 23,000 American jobs this year alone.[iii] We commit to reduce the impacts of the federal solar import tariffs through the implementation of innovative solar deployment measures and will work to modernize our grids. To achieve these goals, we are releasing an overview of the forthcoming U.S Climate Alliance Solar Deployment Guidebook and Non-Wires Solutions Playbook, groundbreaking implementation resources for regulators and utilities that will reduce emissions and save money for consumers.
| Save families money and avoid emissions through improved appliance efficiency standards
Alignment around a common set of product efficiency standards in the Alliance states could reduce GHG emissions by 5.5 million tons and save consumers across our states $4 billion dollars by 2025. Today the U.S. Climate Alliance announces plans to identify priority state-level appliance efficiency standards and to coordinate with Alliance states on the adoption, implementation and enforcement of such standards. The Alliance will be partnering with the Appliance Standards Awareness Project, an initiative of the American Council for an Energy Efficient Economy, to advance this effort.