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Published: June 2008

Public hearings should be held on fuel economy standards

Consumer Action joined 31 national, state and local consumer organizations in a letter to the Secretary of Transportation requesting that the National Highway Traffic and Safety Administration hold public hearings before a final rule is made on fuel economy standards.

The undersigned national, state and local consumer groups, representing millions of consumers, are writing to urge the National Highway Traffic Safety Administration (NHTSA) to hold public hearings with sufficient time to address the public’s concerns before the final rule is issued.  NHTSA should hold hearings around the country to learn how important better fuel economy is to the American people and how essential it is to meet statutory requirements/goals of conserving energy.

This rulemaking is the most important change since the beginning of regulation of fuel economy in America.  It represents the first major revision in the approach to fuel economy standards in over two decades, and it will set the direction for fuel economy for the most vital decade in the struggle to end America’s addition to oil and begin the process of responding to climate change.  With household budgets straining under the weight of soaring gasoline prices and the U.S. importing almost two-thirds of the crude oil it consumes, it is vitally important that NHTSA hear from the American people in hearings, not just through comments submitted to the docket.  Public hearings on this critical issue provide Americans with greater access to the process, and NHTSA will be better able to appreciate the public’s concerns.

The severity of the energy crisis facing the U.S. must be reflected in the fuel economy standards.  Consumers are clamoring for fuel efficient vehicles now, yet the standards proposed for model years 2011-2015 on April 22, 2008 fail to put technology to work for consumers because NHTSA ties its proposed standards to low fuel prices.  The use of more realistic fuel prices make more technology cost-justified and will result in higher standards.

We appreciate the fact that you have recognized the gas price problem in the rulemaking, stating less than a month after the proposed rule was released that: "As we look toward the finalization of the rule and look again what the average fuel costs are then, I think we're going to make more progress on the miles per gallon at a lower overall cost."   High gasoline prices should not have been a surprise to the agency.  The price predictions on which NHTSA has relied in the past several years have consistently been used to undercut the use of existing technology to meet the statutory goals. 

Under the statute, properly reflecting the value of gasoline and the value consumers place on the need to conserve energy are among the most important elements of NHTSA’s analysis. Consumer attitudes and behaviors play a vital role in NHTSA’s analysis of fuel economy standards.  Public hearings are an ideal way for NHTSA to ensure that it hears from the American people and has a proper understanding of how important energy conservation is to the public and the nation.

We would like to see NHTSA hold hearings before the comment deadline, July 1.  But, if that is not feasible, we hope they will be held as early as possible in the summer so the agency can hear from the public—especially consumers who will be looking to buy the vehicles these standards will affect, and that it can give the public comments received at the hearings the critical weight and consideration they rightly deserve.  

Thank you for your attention.  Detailed comments on the rulemaking will be submitted before the comment deadline.  In the meantime, we look forward to your response and hope that you will see the benefit and necessity of holding public hearings before the final rule is issued and act accordingly.

Lead Organization

Consumer Federation of America

Other Organizations

Consumer Federation of America | Consumers Union | Public Citizen | USPIRG | AkPIRG | Arizona Consumers Council | Arizona PIRG | Arkansas Public Policy Panel ALPIRG Citizens’ Utility Board of Oregon | Consumer Assistance Council of Cape Cod | Consumer Federation of the Southeast | Consumers for Auto Reliability and Safety Democratic Processes Center | Empire State Consumer Association | Florida Consumer Action Network | Florida PIRG | Illinois PIRG | Maryland Consumer Rights Coalition Maryland PIRG | Massachusetts Consumers Council | New Jersey Citizen Action | New Mexico PIRG | North Carolina Consumers Council | NYPIRG | PennPIRG | Utility Consumers Action Network | Victims Committee for Recall of Defective Vehicles | Virginia Citizens Consumer Council | Wisconsin Consumers League

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