Light-Duty Vehicle GHG Standards

Policy Engagement Overview

InfluenceMap's database covers roughly 500 companies and 250 industry associations globally, with the most engaged entities scanned on a weekly basis and all entities assessed at least every other quarter. The current state of corporate engagement on this regulation is summarized below. The "Evidence Profile" at right indicates InfluenceMap's capture of corporate positions on the regulation, ranging from strong opposition to strong support. Both this page and the graph were last updated September 1st, 2023.

This page covers corporate and industry association positions primarily from the comment period of the program, highlighting statements issued to the EPA that could have impacted the final rule. InfluenceMap is currently assessing statements on the rule post-release and will upload these on a rolling basis.

Ongoing Lawsuits:

● The American Petrochemical Institute (API), representing members ExxonMobil, Shell, BP, Chevron, and others, filed a lawsuit challenging the EPA’s light- and medium-duty GHG emissions standards in June 2024. API stated that the rules were “arbitrary and capricious” and exceeded the agency’s authority.

● The American Fuel and Petrochemical Manufacturers Association (AFPM) filed a lawsuit opposing the EPA’s light- and medium-duty GHG emissions standards in June 2024.

Engagement Prior to Lawsuits:

● The Alliance for Automotive Innovation strongly opposed the proposed standards. The Alliance advocated to significantly reduce the ambition of the proposed standards and challenged the EPA’s legal authority to enact the rule. The group also pushed to maintain numerous flexibilities that would weaken the program’s stringency, such as off-cycle and multiplier credits.

● Japanese and Korean automakers opposed the proposed standards. Particularly negative advocacy came from Korean and Japanese manufacturers Hyundai, Toyota, Nissan, and Mitsubishi, which all advocated to significantly reduce the ambition of the proposed rule, supported numerous flexibilities that would weaken the proposal’s stringency, and pushed to weaken zero-emission vehicle (ZEV) adoption targets to also include plug-in hybrid vehicles (PHEVs) . Honda opposed all proposed alternatives in favor of a weaker regulation with more flexibilities, but did not explicitly advocate for PHEVs to be included in targets for the regulation. Mazda advocated to reduce the stringency of the regulation and for ZEV adoption targets to include plug-in hybrid vehicle sales in its comments. All six automakers explicitly supported comments from the Alliance for Automotive Innovation, where they are members.

● US automakers had mixed advocacy on EPA’s proposed standards. Tesla supported the more ambitious Alternative 1 proposal, which increases EV share beyond the EPA’s proposed rule, and advocated for further increases in the rule’s stringency beyond this. Ford supported the 2032 endpoint on EPA’s proposal, while favoring the less ambitious stringency curve represented by Alternative 3. General Motors advocated for a significantly less ambitious rule that would achieve 50% EV sales by 2030, a 10% reduction from EPA’s preferred 60% alternative. Neither GM nor Ford explicitly endorsed the Alliance’s comments in their responses.

● Advocacy from other automakers was mostly negative. Advocacy from BMW, Mercedes-Benz, Stellantis, and Volkswagen Group (and its subsidiary Porsche) was negative, advocating for electrification targets of 40-50% by 2030, a significant reduction from the proposed standards projected 60% BEV penetration rate by 2030. Only Mercedes-Benz did not state explicit support for the statements of the Alliance for Automotive Innovation. Volvo Cars supported flexibilities that may reduce the stringency of the program such as off-cycle and A/C credits, and Jaguar Land Rover (Tata Motors) advocated for a reduction in stringency earlier in the program, and requested monitoring points in which the program could be adjusted every two years.

● The petroleum and ethanol industry strongly opposed the rule, advocating to include liquid fuels and a longer-term role for ICE-powered hybrid vehicles. The American Fuel and Petrochemical Manufacturers (AFPM) argued that EPA does not have congressional authority to enact its proposed standards, stating that they were “unachievable”. The American Petroleum Institute (API) opposed the rule, citing concerns about its legality, and pushed for pre- and mid-program assessments in which the stringency of the standards could be adjusted. ExxonMobil, Marathon Petroleum, Valero, and Chevron advocated to weaken zero-emission vehicle targets through the inclusion of “renewable liquid fuels” and ICE-powered hybrid vehicles. The Renewable Fuels Association took a similar position and refuted the legality of the rule, while also advocating to adjust the program to better accommodate ICE-powered vehicles.

● Industry associations representing electric utilities and ZEV manufacturers mostly supported the rule. The Zero Emission Transportation Association (ZETA) supported standards more stringent than those proposed by the EPA, arguing that California’s target of 100% zero emission vehicle sales by 2035 would be feasible nationwide. Advanced Energy United supported the proposed targets, and promoted the economic and grid stability benefits of the program. The Edison Electric Institute's response also appeared generally supportive of the rule

● Other industry associations pushed back or took unclear positions on the rule. The US Chamber of Commerce stated the rule was “going too fast”, and advocated for the standards to instead use a stringency based on 40-50% EV sales by 2030, which the organization also considers a “stretch goal.” The National Association of Manufacturers (NAM) expressed concern about EV infrastructure, but took an unclear position on the rule.