Agriculture and renewable energy groups have told EPA the agency is pursuing an impractical, single technology solution for auto emissions that fails to account for the benefits of biofuels. 

EPA estimates its proposed tailpipe emission standards would require two-thirds of new light-duty vehicles to be electric by the 2032 model-year.

In comments made to EPA on the standards, critics said the proposal doesn't account for potential high costs of battery components or reflect consumer demand for electric vehicles. 

The proposal “tilts the scale towards electric vehicles” as it only accounts for emissions from one segment of the value chain with its focus on vehicle tailpipes, according to joint comments filed with EPA by the National Corn Growers Association, National Farmers Union, Growth Energy, Renewable Fuels Association, National Association of Convenience Stores and other groups representing travel plazas and truck stops and leading fuel marketers.

“A technology-neutral approach to transportation decarbonization will help to mitigate costs, promote innovation and address the practical challenges associated with electrification. All fuels and technologies should be treated equally within the context of emissions standards,” the groups said.

The groups said EPA's EV conversion timelines "are entirely untethered from the market’s capabilities.”

The groups add, “The best way to address practical impediments to electrification is to inject flexibility into the proposed rule while simultaneously promoting near-term emissions reductions through the use of multiple technologies, including renewable liquid fuels.”

The groups stated, “Importantly, renewable fuels do not require new vehicle purchases and lead to significant emissions reductions by improving the emissions profile of vehicles already on the road.”

The Alliance for Automotive Innovation, which represents manufacturers, said the proposed rule is “neither reasonable nor achievable in the timeframe provided” and instead writes off plug-in hybrids and fuel cell EVs and focuses only on battery electric vehicles. 

It also departs from the 2021 executive order which called for 50% of electric vehicles, including plug-in hybrid and fuel cell EVs, by 2030.

“A 67% (battery electric vehicle)-only approach by 2032 will unquestionably reduce consumer choice and push automakers to non-compliance with such unachievable requirements,” John Bozzella, president and CEO of the alliance, wrote in a recent blog.

EPA’s rule also “substantially underestimates the cost of batteries while overestimating the availability of consumer and manufacturing tax credits,” the alliance said in its comments. EPA’s model suggests cost reductions and incentives would “eliminate the entire cost of EV batteries." The manufacturers say they don't believe those assumptions are realistic.

But policy analysts with the Natural Resources Defense Council argue in a blog post that EPA is, in fact, giving automakers "the flexibility to determine the vehicle technologies they will use to comply with the agency’s emissions standards," But the agency believes "automakers will choose to comply through increasing the number of zero-emission vehicles (like electric vehicles) in their fleets," the NRDC analysts say. 

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"While increasing sales of zero-emission vehicles is a likely method of compliance, an automaker could also reduce their fleet carbon pollution by favoring sales of their cleaner trims of internal combustion engine models over the dirtier versions of the same models," the analysts say. 

Liane Randolph, who chairs the California Air Resources Board, said at an EPA hearing on the rule in May that CARB supports EPA’s proposal but believes it can be strengthened. CARB said EPA regulations should ensure that future internal combustion vehicles include "cost-effective technologies" that will "maximize emission reductions and save consumers money.”

Joint comments from the transportation departments of Idaho, Montana, North Dakota, South Dakota and Wyoming said they were struck by the singular focus on EVs and said there was “inadequate attention to low carbon liquid fuels and biofuels as additional means of addressing emissions concerns that would not be dependent on an adequate electric vehicle charging network, something that certainly is not available at this time, particularly in rural areas.”

The states also said “EVs are not well suited for all of our nation’s climates, especially in states that are rural, are at high altitude, or both. In such areas long distance travel in often extreme temperature ranges significantly impact EV range and the ability of Americans to access healthcare, food, and other necessities.”

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