Federal Register - December 30, 2021
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Source: Federal Register
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Federal Register / Vol. 86, No. 248 / Thursday, December 30, 2021 / Rules and Regulations
M. Affordability and Equity Impacts The impacts of the standards on social equity depend in part on their effects on the affordability of vehicles and transportation services, especially for lower-income households. Access to transportation improves the ability of people, including those with low income, to pursue jobs, education, health care, and necessities of daily life such as food and housing. This section discusses how these standards might affect affordability of vehicles. We acknowledge that vehicles, especially household ownership of vehicles, are only a portion of the larger issues concerning access to transportation and mobility services, which also take into consideration public transportation and land use design. Though these issues are inextricably linked, the following discussion focuses on effects related to private vehicle ownership and use. We also acknowledge that the emissions of vehicles, both local pollutants and GHGs, can have disproportionate impacts on lower-income and minority communities; see Preamble Sections I.E
and VII.L for further discussion of these topics. Finally, we note that social equity involves issues beyond income and affordability, including race, ethnicity, gender, gender identification, and residential location; EPA will continue to examine such impacts.
Affordability is not a well-defined concept in academic literature. As discussed in Cassidy et al. 2016,268
researchers have generally applied the term to necessities such as food, housing, or energy, and have identified some themes related to:
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Instead of focusing on the traditional economic concept of willingness to pay, any consideration of affordability must also consider the ability to pay for a socially defined minimum level of a good, especially of a necessity.
Although the ability to pay is often based on the proportion of income devoted to expenditures on a particular good, this ratio approach is widely criticized for not considering expenditures on other possibly necessary goods, quality differences in the good, and heterogeneity of consumer preferences for the good.
Assessing affordability should take into account both the short-term costs and longterm costs associated with consumption of a particular good.
As noted in Cassidy et al., 2016, there is very little literature applying the concept of affordability to transportation, much less to vehicle ownership. It is not clear how to 268 Cassidy, A., G. Burmeister, and G. Helfand.
Impacts of the Model Year 20172025 Light-Duty Vehicle Greenhouse Gas Emission Standards on Vehicle Affordability. Working paper.
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identify a socially acceptable minimum level of transportation service. However, it seems reasonable that some minimum level of transportation services is necessary to enable households access to employment, education, and basic services such as buying food. It also seems reasonable to assume that transportation requirements vary substantially across populations and geographic locations, and it is not clear when consumption of transportation moves from being a necessity to optional. Normatively defining the minimum adequate level of transportation consumption is difficult given the heterogeneity of consumer preferences and living situations. As a result, it is challenging to define how much residual income should remain with each household after transportation expenditures. It is therefore not surprising that academic and policy literature have largely avoided attempting to define transportation affordability.
As with the proposed rule, we are following the approach in the 2016 EPA
Proposed Determination for the Midterm Evaluation 269 of considering four questions that relate to the effects of the final standards on new vehicle affordability: How the standards affect lower-income households; how the standards affect the used vehicle market; how the standards affect access to credit; and how the standards affect the low-priced vehicle segment. See RIA
Chapter 8.3 for further detail.
Americans for Prosperity, Attorneys General of Missouri and Ohio, Competitive Enterprise Institute, some individual commenters, NADA, Taxpayers Protection Alliance, and Valero Energy Corporation express concern that increases in new vehicle prices will hurt lowand middleincome households by making new vehicles more expensive. EPA notes that the effects of the standards on lowerincome households depend on the responses not just to up-front costs but also to the reduction in fuel and operating costs associated with the standards. These responses will affect not only the sales of new vehicles, as discussed in Section VII.B of this preamble, but also the prices of used vehicles as well as the costs associated with ride-hailing and ride-sharing services. Consumer Reports, Dream 269 U.S. Environmental Protection Agency 2016.
Proposed Determination on the Appropriateness of the Model Year 20222025 Light-Duty Vehicle Greenhouse Gas Emissions Standards under the Midterm Evaluation, Chapter 4.3.3. EPA420R
16020. https nepis.epa.gov/Exe/
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Corps Green for All, and Center for Biological Diversity et al. say that, although up-front costs are higher, the total cost of ownership is lower. In addition, they say that lower-income households may disproportionately benefit, as they observe that low-income households typically buy used vehicles, whose up-front cost increases are more modest compared to the fuel savings;
because fuel costs are a larger proportion of household income for lower-income people, these savings are especially important. Hutchens et al.
2021 270 find that lower-income households spend more on used vehicles than new ones. A recent study notes that lower-income households spend more on gasoline as a proportion of their income than higher-income households,271 suggesting the importance of operating costs for these households. If the per-mile costs of services such as ride hailing and ride sharing decrease to reflect lower operating costs, those who do not own vehicles may benefit. The National Coalition for Advanced Technology comments that Uber and Lyft have a target in 2030 of going all-electric; if those lower operating and maintenance costs are passed along to users, these services may become more affordable.
Most people who buy vehicles purchase used vehicles, instead of new.272 If sales of new vehicles decrease, then prices of used vehicles, which are disproportionately purchased by lower-income households, would be expected to increase; the reverse would happen if new vehicle sales increase.
These effects in the used vehicle market also affect how long people hold onto their used vehicles. This effect, sometimes termed the Gruenspecht effect after Gruenspecht 1982,273
would lead to both slower adoption of vehicles subject to the new standards, and more use of older vehicles not subject to the new standards, with 270 Hutchens, A., A. Cassidy, G. Burmeister, and G. Helfand. Impacts of Light-Duty Vehicle Greenhouse Gas Emission Standards on Vehicle Affordability. Working paper.
271 Vaidyanathan, S., P. Huether, and B. Jennings 2021. Understanding Transportation Energy Burdens. Washington, DC: American Council for an Energy-Efficient Economy White Paper. https
www.aceee.org/white-paper/2021/05/
understanding-transportation-energy-burdens, accessed 5/24/2021.
272 U.S. Department of Transportation, Bureau of Transportation Statistics. New and Used Passenger Car and Light Truck Sales and Leases. National Transportation Statistics Table 117. https
www.bts.gov/content/new-and-used-passenger-carsales-and-leases-thousands-vehicles, accessed 11/3/
2021.
273 Gruenspecht, H. 1982. Differentiated Regulation: The Case of Auto Emissions Standards. American Economic Review 72: 328
331.
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