Earlier legal and administrative Clean Cars resources

Date updated: July 1, 2020

Administrative materials submitted by EDF and allies on the Clean Cars rollback and legal filings challenging EPA's 2018 Mid-term Evaluation Final Determination.

Recent legal filings related to Clean Car Standards »

Clean Cars Rollback

Petitions for Reconsideration

Supplemental Comments

Supplemental Joint NGO Comment
November 21, 2019
Sharing a new report from a top medical research journal discussing the public health harms of climate change, especially those impacting children.

Supplemental Comment of EDF
September 18, 2019
Addressing a recent attack on Saudi oil infrastructure and the ongoing need to protect against oil market volatility by conserving energy.

Supplemental Comment of EDF
September 11, 2019
Sharing statements of President Trump and other White House officials suggesting that the rationales given in the Proposed Rule are pretextual.

Supplemental Joint NGO Comment
August 14, 2019
Sharing new and compelling evidence of the urgent need to reduce ongoing harm and grave danger to public health and welfare caused by greenhouse gas emissions.

Supplemental Comment of EDF
August 7, 2019
Highlighting meetings between senior EPA officials and industry representatives related to the rollback of the Clean Car standard that EPA failed to disclose.

Supplemental Joint NGO Comment
July 18, 2019
Sharing relevant statements of agency leadership and auto industry representatives that were made at the June 20, 2019 House Energy & Commerce Committee hearing on the proposed rollback rule.

Supplemental Joint NGO Comment
June 14, 2019
Comment submitting a letter from 17 automakers to President Trump for inclusion in the rulemaking dockets. Submitted by EDF, Center for Biological Diversity, Natural Resources Defense Council, Public Citizen, Inc., and Union of Concerned Scientists.

Supplemental Comment & Request for Correction
May 31, 2019
Comment addressing EPA’s failure to publish the current version of the OMEGA model, and request for correction due to the agencies’ failure to disseminate accurate information about the cost to automakers of the proposed SAFE Rule. Submitted by EDF, Center for Biological Diversity, Natural Resources Defense Council, Public Citizen, Inc., and Union of Concerned Scientists.

Supplemental Joint NGO Comment
May 31, 2019
Addressing the recent United Nations’ assessment report on the severe degradation that climate change is contributing to biodiversity and ecosystems on a global scale. Submitted by EDF, Center for Biological Diversity, Conservation Law Foundation, Natural Resources Defense Council, Public Citizen, Inc., and Sierra Club.

Supplemental Joint NGO Comment
May 24, 2019
Detailing vehicle emission-reduction technology developments since the close of the comment period, and identifying additional concerns with the Administration’s improper handling of the SAFE rulemaking. Comment submitted by EDF, Center for Biological Diversity, Natural Resources Defense Council, Public Citizen, Inc., and Union of Concerned Scientists.

Supplemental Joint NGO Comment
Apr. 5, 2019
Addressing additional studies and reports on climate change and climate impacts released after the close of the comment period. Submitted by EDF with Center for Biological Diversity, Conservation Law Foundation, Natural Resources Defense Council, Public Citizen, Inc., Sierra Club, and Union of Concerned Scientists.

Supplemental Comment of EDF
Dec. 21, 2018
Addressing errors in the proposed rule’s methodology and modeling of sulfur dioxide emissions

Supplemental Joint NGO Comment
Dec. 20, 2018
Addressing fundamental flaws in the rulemaking procedure.
Submitted by EDF with Center for Biological Diversity, Conservation Law Foundation, Earthjustice, Environmental Law & Policy Center, Natural Resources Defense Council, Public Citizen, Sierra Club, and Union of Concerned Scientists

Comments from Initial Comment Period

Comment of EDF
Oct. 26, 2018
Addressing technical and legal issues with the proposed rule to roll back the Clean Car standards

Joint NGO Comment
Oct. 26, 2018
Addressing legal issues with the proposal
Submitted by EDF with Center for Biological Diversity, Conservation Law Foundation, Earthjustice, Environmental Law & Policy Center, Natural Resources Defense Council, Public Citizen, Sierra Club, and Union of Concerned Scientists

Joint NGO Comment
Oct. 26, 2018
Addressing climate change
Submitted by EDF with Center for Biological Diversity, Earthjustice, Natural Resources Defense Council, Sierra Club, and Public Citizen

Comment of States and Cities
Oct. 26, 2018
Submitted by California, Connecticut, Delaware, Hawaii, Iowa, Illinois, Maine, Maryland, Minnesota, New Jersey, New Mexico, New York, North Carolina, Oregon, Rhode Island, Vermont, and Washington, the Commonwealths of Massachusetts, Pennsylvania, and Virginia, the District of Columbia, and the Cities of Los Angeles, New York, Oakland, San Francisco, and San Jose

Joint NGO Comment
Oct. 26, 2018
Addressing Endangered Species Act issues
Submitted by Center for Biological Diversity, Earthjustice, Natural Resources Defense Council, and Sierra Club

Comment of Tesla
Oct. 26, 2018

Comment of the National Coalition for Advanced Transportation
Oct. 26, 2018

Additional Technical Analysis Comments

Comment of EDF and Union of Concerned Scientists
Oct. 26, 2018
Addressing issues with the analysis and application of the rebound effect

Comment of California Air Resources Board
Addressing technical issues with the proposal, plus expert reports submitted by CARB on specific technical subjects

Comment of Professor Cinzia Cirillo, University of Maryland
Oct. 18, 2018
Addressing the use of her research in the proposal

Comment of Professors James Stock & Ken Gillingham, Havard University Oct. 26, 2018
Addressing vehicle cost and other technical issues with the proposal

Comment of Professors Mark Jacobsen & Arthur van Benthem, UC San Diego
Oct. 8, 2018
Addressing the use of their research and technical concerns with the proposal

Comment of Assistant Professor Joshua Linn, University of Maryland
Oct. 11, 2018
Addressing the improper use of the rebound effect in the proposal

Comment of Professor Emeritus Kenneth Small, UC Irvine
Sept. 14, 2018
Addressing the use of his research in the proposal

Comment of NRDC
Oct. 26, 2018
Addressing the flawed assumptions made by NHTSA regarding mass reduction technologies in the proposal

Comment of Union of Concerned Scientists
Oct. 26, 2018
Addressing economic feasibility and successful implementation of past fuel economy and greenhouse gas emissions standards for light-duty vehicles

Comment of American Council for an Energy-Efficient Economy (ACEEE)
Oct. 2018
Addressing cost of compliance technology, safety issues, and flexibility provisions

Comment of BlueGreen Alliance
Oct. 26, 2018
Regarding economic benefit of fuel economy improvements and greenhouse reductions

Comment of the Consumer Federation of America (CFA) and other consumer groups
Oct. 26, 2018
Addressing factual errors in the proposal

Comment of Consumers Union
Oct. 26, 2018
Reviewing technical and analytical flaws in the proposal

Joint Comments of ACEEE, CFA, and Consumers Union
Oct. 26, 2018
Addressing vehicle sales, ownership costs, and other economic considerations

Comment of the International Council on Clean Transportation (ICCT)
Oct. 25, 2018
Addressing technical deficiencies in the analyses contained in the proposal

Comment of the Institute for Policy Integrity (IPI)
Oct. 26, 2018
Addressing flaws in the legal, technical, and econometric reasoning in the proposal

Comments on NHTSA’s Draft Environmental Impact Statement

Comment of EDF
Oct. 26, 2018
Addressing technical and legal issues with NHTSA's Draft Environmental Impact Statement

Joint NGO Comment
Oct. 26, 2018
Addressing technical and legal issues with NHTSA's Draft Environmental Impact Statement
Submitted by Center for Biological Diversity, Earthjustice, Environmental Law and Policy Center, Natural Resources Defense Council, Public Citizen, Inc., Safe Climate Campaign, Sierra Club, Southern Environmental Law Center, and Union of Concerned Scientists

Comment of States & Cities
Oct. 26, 2018
Addressing issues with NHTSA's Draft Environmental Impact Statement
Submitted by States of California, Connecticut, Delaware, Hawaii, Iowa, Illinois, Maine, Maryland, Minnesota, North Carolina, New Jersey, New Mexico, New York, Oregon, Rhode Island, Vermont, Washington, the Commonwealths of Massachusetts, Pennsylvania, and Virginia, the District of Columbia, and the Cities of Los Angeles, New York, Oakland, San Francisco, and San Jose

Final Determination

Opinion Granting Motion to Dismiss

Oral Argument

Order Referring Motions to Dismiss to Merits Panel

Responses to Government and Industry Motions to Dismiss

Motions to Dismiss

Motions to Intervene

Petitions for Review

Administrative Proceedings