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October 9, 2018

Did the Trump Administration Say It’s Too Late to Tackle Climate Change?

There was a good deal of coverage and commentary recently regarding the Trump Administration’s draft Environmental Impact Statement (EIS) proposing changes to the National Highway Traffic Safety Administration’s (NHTSA’s) Corporate Average Fuel Economy (CAFE) standards. A lot of that commentary focused on the “no action” alternative in the EIS. The EIS projects dramatic climate change by the year 2100, while concluding that lowering the fuel economy standard won’t make any significant difference to that outcome. This was translated in headlines into “Trump Administration says it’s too late to do anything about climate change, so let’s keep emitting.” While this isn’t really that inaccurate a bottom line, it does hide what the EIS really intends to accomplish. It also overstates the idea that the Administration is making a policy statement through the EIS. If climate advocates are going to play policy chess rather than checkers, it’s worth understanding what is really going on in that draft EIS:

  1. Somebody was charged with supporting the proposed rulemaking to roll back CAFE standards.
  2. Rolling back those standards requires an Environmental Impact Statement that is subject to judicial review.
  3. The NHTSA and EPA, the two agencies involved, cannot ignore climate change. If they did, the assessment likely would not survive judicial review.
  4. The NHTSA and EPA cannot present bad science on climate change. If they did, they risk being invalidated upon judicial review.
  5. The NHTSA and EPA need to show that the proposed rulemaking will not have a significant environmental impact in its own right. For better or worse, the draft EIS does this effectively. It wasn’t lost on the EIS’s authors that the more dire the climate change scenario used in the EIS, the better the argument that rolling back CAFE standards won’t really matter.

In other words, the EIS does exactly what it needs to do to support the new rulemaking. The EIS was in not intended to present or assess the risks of climate change, or to evaluate what could be done to slow climate change. The purpose of an environmental impact statement has nothing in common with the purpose of the just-released IPCC Report looking at the implications of 1.5oC of temperature change.

From a broader policy perspective, it is of course hypocritical in the extreme to use the forecast used in the EIS while other parts of the Administration deny the existence of climate change. But from the standpoint of the agencies charged with writing the EIS, it is written the way it needs to be to survive the predictable judicial challenge.

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Mark Trexler

Mark has more than 30 years of regulatory and energy policy experience. He has advised clients around the world on climate change risk and risk management. He is widely published on business risk management topics surrounding climate change, including in the design and deployment of carbon markets. Mark has served as a lead author for the IPCC and holds advanced degrees from the University of California at Berkeley.

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