We are pleased to share the second edition of InfluenceMap's Transport Quarterly covering the first quarter of 2024 (released in April 2024). This bulletin highlights recent insights into the advocacy of major companies and their industry associations. This issue covers:
The release of the final GHG emissions standards for both light- and heavy-duty vehicles in the US
A review of industry comments on the Advanced Clean Cars II EPA waiver
Recent Releases from InfluenceMap
The US Environmental Protection Agency (EPA) has finalized its proposed greenhouse gas (GHG) emissions standards for light- and heavy-duty vehicles. The rules, initially proposed in 2023, were the target of significant advocacy by automakers, truck makers, the petroleum sector, and a range of other actors. The petroleum fuel industry negatively engaged on both rules, often refuting the legality of the rule as a whole.
The petroleum sector engaged in the most aggressive, negative advocacy on both rules; while most automakers advocated to weaken the rules, petrochemical companies and associations issued comments to the EPA that often challenged their legality. The American Fuel and Petrochemical Manufacturers Association (AFPM) and American Petroleum Institute (API) appeared to lead opposition from the sector, collectively representing companies such as Chevron, ExxonMobil, Shell, Marathon Petroleum, and more.
The EPA’s GHG emissions standards for light- and medium-duty vehicles (full analysis available here) were ultimately finalized with the same 2032 target but with a slower ramp up in the earlier years. Many automakers advocated to reduce the final GHG reduction target of the rule (Hyundai, Toyota, Nissan, Mitsubishi, Honda, Mazda, BMW, Stellantis, and Volkswagen Group) and aligned themselves with the position of the Alliance for Automotive Innovation (the Alliance). The EPA’s initial proposal aimed to achieve a total of 60% zero emission vehicle (BEV and FCEV) sales by 2030 and 67% by 2032, and the Alliance advocated instead for a weaker target of 40-50% sales of battery electric vehicles (BEVs), plug-in hybrid vehicles (PHEV), and fuel cell electric vehicles (FCEV). While plug-in hybrids can offer GHG emissions reductions compared to traditional internal combustion engine vehicles (ICE), this depends on how often drivers plug in their vehicles, and their use typically results in significantly higher emissions than a BEV. Post-rule release, Alliance CEO John Bozella stated: “These adjusted EV targets – still a stretch goal – should give the market and supply chains a chance to catch up.”
The rule was finalized with the same proposed emissions reduction target in 2032, but deeper cuts have been delayed to the later years of the proposal, potentially limiting the cumulative emissions reduction of the policy. Notably, while the EPA’s initial proposal centered around higher BEV sales, EPA statements on the final rule clearly also support both PHEVs and ICE-powered hybrid vehicles—technologies that many automakers promoted in their advocacy on the rule.
The EPA’s GHG emissions standards for heavy-duty vehicles, also finalized in March, appear to have benefited from positive advocacy, and the rule’s targets have increased slightly (full analysis available here). While the rule’s targets increased slightly, truck makers successfully requested certain changes to the rule (multipliers for electric trucks and credit trading between vehicle classes) that likely lower the real-world emissions reductions of the standards. PACCAR and Daimler Truck also advocated to maintain credit multipliers, a flexibility that can make it easier for truck makers to comply with the rule
Electric utilities and their industry associations (including Edison Electric Institute, ConEdison, PG&E, Enel, Advanced Energy United, and the Zero Emission Transportation Association) supported the heavy-duty vehicle rule. Similar to the light-duty GHG standards, advocacy from the fossil fuel sector (AFPM, API) on the heavy-duty standards was extremely negative and focused on legal arguments that could delay the regulation or shut it down entirely.
In March 2024, the Australian government announced final legislation for a New Vehicle Efficiency Standard, Australia's first ever CO₂ standard for vehicles. The legislation weakened the standard that the government proposed in February 2024 following a consultation process, despite divided industry voices. The roll-back follows an extensive advocacy campaign by Australia's main industry automotive association, the Federal Chamber of Automotive Industries (FCAI), and key automotive members tracked on InfluenceMap's Australia platform.
Following the February 2024 government announcement, FCAI's Chief Executive emphasized cost and availability concerns around a proposed efficiency standard in a press release. Other FCAI members responded to the announcement: The media reported support for the proposed standard from automakers including Hyundai, Polestar, and Volkswagen, highlighting the FCAI’s internal divisions. In contrast, media reports noted that current FCAI Chair, Mazda urged the government to delay the standard, and current FCAI Vice-Chair, Toyota, criticized the proposal as "too ambitious" and pushed for weaker rules.
Later, in a March 2024 consultation response, the FCAI opposed the proposed standards and advocated to severely weaken the rule's stringency, with the government appearing to adopt some key requests. The FCAI pushed to increase 2029 targets of 58g/CO2 for passenger vehicles up to 84g (unchanged in the final rule) and to increase the proposed 81g/CO2 for light-commercial vehicles to 131g (the final rules were weakened to 110g/CO2). FCAI also advocated for the first two years of the standard to be “reporting-only,” delaying its introduction, with the final rule delaying penalties six months until July 2025. Finally, the FCAI opposed including SUVs in the passenger vehicle categories, and the final rule recategorized some SUVs from passenger cars to light-commercial vehicles, weakening the standard’s ambition.
Following this negative advocacy, in March 2024 multiple FCAI members broke ranks with the group. On March 7th, 2024, Tesla left the FCAI, publicly criticizing the FCAI’s "demonstrably false" claims that the NVES would drive up car prices. Following this, on March 8th Polestar also quit the FCAI over active campaigning against the standard by the association and other member companies. Following this, on March 12th, Reuters reported that Volkswagen had quit the FCAI's policymaking committee to further distance itself from the FCAI campaign against the proposed CO2 standards, after Volkswagen publicly defended the government's proposed standards the week before. Such actions follow a May 2023 InfluenceMap report that previously exposed the FCAI's strategic, coordinated campaign to push back against Australian climate policy, including a CO2 standard then under negotiation.
Amidst stagnant ethanol demand and the potential for significant tax credits, the aviation and ethanol industries have engaged in an advocacy campaign to weaken climate safeguards on US Sustainable Aviation Fuel (SAF) tax credits (full analysis here). The industries have attempted to weaken the sustainability criteria for SAFs under the US SAF blenders tax credit by advocating to change how emissions from SAFs are estimated. The amendments favored by industry increase the likelihood that potentially damaging crop-based fuels are incentivized under the policy.
The original policy proposal for the tax credit included a methodology to estimate fuel emissions that was developed by the UN body for aviation, the International Civil Aviation Organization (ICAO). In addition, any method deemed “similar” to ICAO’s Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) can be used to estimate SAF emissions. InfluenceMap’s July 2023 report revealed coordinated advocacy from the US aviation and ethanol industries in support for an alternative methodology for estimating SAF emissions: the “Greenhouse Gases, Regulated Emissions, and Energy Use in Technologies” (GREET) methodology. The two industries asserted that GREET was “similar” to the ICAO CORSIA method, thus satisfying policy requirements, while pushing for elements of the GREET model that contrast ICAO CORSIA and weaken sustainability rules. This may jeopardize the emissions reduction potential of the policy by rewarding fuels with overstated emissions savings.
In December 2023, the US Treasury Department (the Treasury) determined that GREET does not “currently satisfy the applicable statutory requirements for the SAF credit” and tasked an Interagency Working Group with updating it to fit requirements. Considering the SAF tax credit’s requirements, the Treasury appeared to disagree that GREET is a similar methodology.
Recent corporate engagement with the SAF tax credit:
In the lead up to, and following, the Treasury’s decision on the GREET model, the Renewable Fuels Association (RFA) continued to promote GREET and advocate for amendments that differ from the ICAO CORSIA methodology. In a September 2023 joint letter, the RFA supported GREET and appeared unsupportive of ICAO CORSIA, stating it makes US corn ethanol SAF appear “uncompetitive on the world market.” Furthermore, despite supporting GREET as a similar methodology, in January 2024, RFA sent a letter to the Interagency Working Group that appeared to further push to weaken sustainability rules by advocating for amendments that differ from the ICAO CORSIA model and produce more optimistic estimations of corn ethanol SAF’s emissions.
Similarly, in November 2023, airlines and biofuel groups signed a joint letter supporting GREET as “similar methodology,” but praising a component of GREET that it noted is “unlike the ICAO model.” This amendment would permit the use of reduced estimated emissions for crop-based SAFs resulting from better agricultural practice, without provisions to ensure that estimations are accurate.
In February 2024, the EPA closed the comment period to review California’s request for a waiver of preemption for the Advanced Clean Cars II policy, the most ambitious policy to decarbonize light-duty vehicles in the United States. The policy attracted little corporate engagement; Tesla was the only automaker to engage with the policy, taking a supportive position. However, groups representing the petrochemical industry, including the American Fuel and Petrochemical Manufacturers Association (AFPM), Marathon Petroleum, the American Petroleum Institute, and Valero Energy, requested that the EPA deny the waiver and thus prevent the policy from coming into force.
Pacific Gas and Electric (PG&E) strongly supported the waiver and stated that failing to grant the waiver would introduce regulatory uncertainty and derail investment decisions. The Zero Emission Transportation Association (ZETA) also advocated for the EPA to approve the waiver.
