October 26, 2018 The Honorable Andrew Wheeler Acting Administrator U.S. Environmental Protection Agency Docket ID. No EPA-HQ-OAR-2018-0283 1200 Pennsylvania Avenue, NW Washington DC, 20460 The Honorable Elaine Chao Secretary U.S. Department of Transportation Docket ID No. NHTSA-2018-0067 1200 New Jersey Avenue, SE Washington, DC 20590 RE: The Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule for Model Years 2021-2026 Passenger Cars and Light Trucks (Docket ID No. EPA-HQ-OAR-2018-0283 / NHTSA-2018-0067) Dear Acting Administrator Wheeler and Secretary Chao: On behalf of the State of Washington, I write to express strong opposition to the proposed rule entitled Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule for Model Years 2021-2026 Passenger Cars and Light Trucks, which threatens our state’s authority to set higher emissions reduction targets, thwarts progress on combatting climate change, and poses a risk to our residents. For these reasons, the Environmental Protection Agency (EPA) and the National Highway Transportation Safety Administration (NHTSA) should withdraw this flawed proposal and uphold the California waiver and other states’ rights to adopt its standards. We are facing an unprecedented challenge as a nation and as a global community to combat the threat of climate change. The recent report issued by the Intergovernmental Panel on Climate Change is a sober reality check about the urgency of acting now to reduce carbon emissions and protect our planet from reaching an irreversible tipping point of destructively high temperatures. Rather than seizing the opportunity to showcase our ability to invent and build the technologies that will fuel a carbon-free future, this proposal is doubling down on the old, polluting technologies that have helped create this threat in the first place. Clean car standards are some of the most economical investments ever designed to clean up pollution – these standards have spurred manufacturers to design ways of making our cars run more cleanly and efficiently, saving consumers billions of dollars and helping clean our air. We have witnessed rapid and cost effective development of advanced vehicle technology spurred by California’s regulations. Past vehicle standards have been achieved faster and at lower cost than experts predicted, and those standards have helped consumers by delivering cleaner, more efficient vehicles. In Washington State, we have adopted aggressive greenhouse gas (GHG) reduction targets. Motor vehicles are by far our largest source of those emissions. As a Section 177 state, Washington relies on the California Advanced Clean Cars program to maximize vehicle emission reductions and drive the development of a cleaner, low-carbon transportation sector. Maintaining California’s authority to adopt motor vehicle emission standards and the right for states like Washington to opt into those