Arlington, VA-ACI urges NHTSA to reset the Biden‑era CAFE standards, arguing that the current rules function as an unlawful and economically harmful de facto EV mandate. CAFE has been stretched far beyond its statutory purpose under the Energy Policy and Conservation Act, which was designed to reduce petroleum consumption—not implement climate policy or restructure the auto market. By merging fuel‑economy regulation with EPA’s greenhouse‑gas agenda, federal agencies have imposed major economic and political decisions without clear congressional authorization.
Stringent CAFE standards have had substantial consumer impacts: higher prices for new and used vehicles and widespread hidden subsidies embedded in federal tax credits, utility rates, and manufacturer compliance costs. These burdens fall disproportionately on lower‑income households, while affluent EV buyers capture most of the subsidies.
The original rationale for CAFE—reducing dependence on foreign oil—has been largely achieved through domestic energy production and shifting global supply patterns, making increasingly stringent standards unnecessary. Resetting CAFE is both legally required and economically essential to restore consumer choice, reduce costs, and ensure that vehicle markets evolve based on demand rather than regulatory mandates.
Read ACI’s public comments here.
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The American Consumer Institute is a nonprofit education and research organization.