Tag: Climate change

SGI Welcomes New SEC Climate Rule

SGI Welcomes New SEC Climate Rule

Natalie Wasek

The SEC issued the first ever climate-related disclosure rule earlier this week. In the 3-2 vote, commissioners adopted the rule requiring companies to disclose certain-climate related risks. This rule, which has been long awaited by investors, will require companies to disclose material climate-related risks, activities the company is taking to mitigate these risks, the Board oversight to the climate risk and mitigation, climate targets material to the business, as well as scope 1 and scope 2 emissions deemed material by the company, and reasonable attestation.

While this rule has been weakened from the proposed 2022 rule, Seventh Generation Interfaith, Inc. welcomes the final climate disclosure rule and the SEC’s consideration of our comments. SGI formally submitted one of thousands of comment letters with the proposal of the rule in 2022. In fact, the SGI comment letter was cited seven times by the SEC in the final rulemaking. This rulemaking brings the US closer in alignment to its global peers. SGI is committed to playing an active role in creating a more just and sustainable world. Investors have and will continue to seek clear, consistent, and comparable information on how companies are managing their climate- related risks and opportunities. 

We are disappointed that Scope 3 emission disclosure was omitted from the final rule as the omission will convey an incomplete picture of companies’ risk exposure. This omission means companies will not have to disclose a category of emissions that account for as much as 80-90% of total emissions in some industries. We hope that companies will provide this information to investors voluntarily. We also believe that companies that choose not to disclose Scope 3 emissions will fall and have already fallen behind peers as it will be required in  European reporting requirements under CSRD as well as California’s new disclosure laws. The new rule is a starting point, and higher achieving companies with more robust disclosure will produce greater long term value for shareholders.

Other resources on the new SEC Climate Rule:

Making progress on methane

Making progress on methane

Natalie Wasek

The United Nations Climate Summit (COP28), which took place in Dubai, recently ended with a monumental report that still falls short of necessary progress. World leaders, climate experts, at least 1,300 fossil fuel lobbyists, and one CEO of a large fossil fuel company attended the meetings. ExxonMobil CEO, Robert Woods, attended COP28, marking the first time the CEO of a large fossil fuel company attended the meetings. And sure, while Woods said the conversations  “put way too much emphasis on getting rid of fossil fuels, oil and gas” and not enough on “dealing with the emissions associated with them,” he at least was still part of the discussions. 

The long-awaited and contested COP report recognizes the need for a transition “away from fossil fuels in energy systems, in a just, orderly and equitable manner, accelerating action in this critical decade, so as to achieve net zero by 2050 in keeping with the science.”

For the first time fossil fuels were explicitly discussed and named as a cause to the climate crisis. While the report’s vague language requires more work to ensure its potential, Mindy Lubber, CEO of Ceres, sums it up nicely: 

The agreement comes at an urgent moment. Extreme weather and other climate-related catastrophes are already causing hundreds of billions of dollars in damage each year. The world is at severe risk of far greater challenges as we are on track to miss the 2030 goals of the Paris Agreement and achieve a zero emissions economy in time to prevent catastrophic climate change. At the same time, governments, businesses, and investors have a monumental opportunity to invest in secure, affordable, and reliable clean energy technology that brings enormous economic benefits and job growth.

In addition to the climate talks at COP, other commitments concerning Methane Emissions recently showed some progress. 

Methane, a highly potent climate pollutant, that is responsible for approximately one-third of current warming resulting from human activities. While ExxonMobil, the world’s second largest oil refiner, reported making great progress on its methane emissions reduction, the company was only doing so with estimated emissions, not direct measurements. Without measured data, studies have shown that companies may misallocate capital to less impactful and less cost-effective mitigation opportunities.

Immediately before COP 28 ExxonMobil, announced that it was joining OGMP 2.0, the Oil & Gas Methane Partnership. This came as shocking and exciting news after last proxy season. The Sisters of St. Francis of Dubuque, along with co-filers Benedictine Sisters of Mount St. Scholastica, Congregation des Soeurs des Saints Noms de Jesus et de Marie, and Dana Investment Advisors filed a resolution at ExxonMobil asking the company to issue a report analyzing the reliability of its methane emission disclosures. While ExxonMobil’s opposition to the resolution highlighted their participation in OGCI, Global Methane Partnership, and legal hurdles, the resolution garnered an impressive 36% vote. 

This announcement of Exxon joining OGMP 2.0 is a huge step forward because under OGMP reporting, better-quality emissions data allows operators to accurately understand and characterize methane emissions from their assets, informing a more effective mitigation strategy. 

In addition to ExxonMobil and others joining OGMP in the past few weeks, the EPA released its new methane standards which should help reduce methane emissions. EDF reported on the new rules and how they will help OGMP members comply. There’s been other methane regulation advancements in the EU, China, Australia, and Canada as well. 

The COP agreement, Methane regulation, and hopefully new SEC climate disclosure rules in 2024, there is a lot of forward momentum in the climate world. What is needed now is continued corporate action and more climate policy nationally and internationally. 

SGI members are continuing engagement on climate crisis issues such as GHG emissions, methane, the Just Transition, science based targets and climate transition action plans, as well as climate lobbying. 

There’s still much more work to be done. Next year’s COP is planned to be held in Azerbaijan, one of the birthplaces of the oil industry.

Fast Food – Slow (but steady) Momentum

Fast Food – Slow (but steady) Momentum

Natalie Wasek

As some of the most recognizable, cultural icons that dot the American (and global) landscape, it’s hard to go without seeing a growing drive-through line or an ad for a new product at a local chain restaurant. SGI members have engaged fast food and other consumer based companies on a variety of issues for years.  

In the fast food sector, oftentimes we are urging companies to make improvements that some of their competitors have already made and are now expected. After a resolution is filed, a withdrawal generally means progress. Or at least, movement. 

SGI members have been involved in a campaign led by Ceres and FAIRR, targeting fast food companies to improve their meat sourcing. These chosen companies are vulnerable to impacts of climate change, water scarcity, and other threats due to protein production. A FAIRR report states, “agricultural emissions, including those from meat and dairy, are on track to contribute approximately 70% of total allowable GHG emissions by 2050, creating an 11 gigaton mitigation gap required to stay under the 2°C threshold.” Of the six companies engaged in this campaign, SGI members lead on three: Wendy’s, Restaurant Brands International (RBI), and Yum! Brands. 

After slow movement from Wendy’s, investors filed a resolution asking for a report on whether and how the Company plans to measure and reduce its total contribution to climate change, including emissions from its supply chain, and align its operations with the Paris Agreement’s goal of maintaining global temperature increases well below 2°C. This increased disclosure and target setting would not only be beneficial in reducing the company’s climate impacts but benefit consumers and shareholders. 

The proposal was withdrawn as Wendy’s has committed to pursue Science Based Targets (SBT) for Scope 1, 2, and 3 emissions. Yum! Brands has been committed to the SBT process since a shareholder proposal in 2019 and has approved 2030 targets, including reducing GHG emissions by 46%, required to keep global warming to 1.5°C. RBI has also recently committed to the SBT process.

This is just a first step for these companies. As investors increasingly look for climate disclosure and transparency on environmental issues, setting SBT has become a trusted benchmark in addressing the climate crisis. Investors are encouraged by the move towards stronger climate targets and will use this momentum to continue this campaign working with these companies on water impact and water use. 

Climate Change is now a Climate Crisis

Climate Change is now a Climate Crisis

Chris Cox

By Frank Sherman

Recently, we took time to reflect on another eventful engagement season and to chart the strategic direction for the coming year.

Looking back at the 2019 engagement season and more than one-hundred climate engagements by ICCR members, we observe:

  • In a notable exception, the electricity generation sector is at a decarbonization tipping point driven by cheaper renewable energy, growing industrial and public demand, and changing public opinion. Securitization laws, distributed energy resources (e.g. rooftop solar) and community solar projects are growing in popularity. The “electrification of everything” shows promise of demand growth, energy savings and environmental sustainability. A growing number of utility companies (nine, according to NRDC) have followed Xcel’s lead by committing to carbon-neutral electricity production by 2050 or sooner.
  • In the face of regulatory rollbacks, natural gas production and distribution companies are committing to voluntary methane leakage reduction targets to salvage the ‘bridge-fuel’ story. With 6000 mid- and small-scale producers, the majors are now advocating for a stronger regulatory regime! Investors have been successful in tying support for meaningful regulation to reputational risk.
  • As investors shifted from demanding scenario assessments to Paris-compliant business plans, U.S. oil & gas companies continued to defend their business-as-usual business model while their European counterparts broke rank. A BP supported climate resolution obtained a 99+% vote while Shell agreed to set GHG reduction targets for their products as well as their operations. In contrast, CA100+ investors at Exxon Mobil recommended voting against the Board after the company omitted their GHG reduction target proposal.
  • With noted exceptions (Wells Fargo and Goldman), large financial companies are starting to assess climate risk in their portfolios. Mid-cap companies were slower to respond to our letter campaign, largely it seems, due to limited capacity to conduct broad risk assessment. Investors will connect them with tools they can use to do a straightforward climate footprint analysis.
  • Political spending and lobbying resolution votes, several of which emphasized climate change, increased to 31%.
  • Engagements calling for science based (GHG reduction) targets made slow progress in contrast to the scientific community call for more urgent action.

Impacting the climate science and changing political landscape, 2018 was the wettest year on record while wildfires in California resulted in the first climate change bankruptcy of Pacific Gas and Electric. Global carbon emissions reached a record, and the U.S. power sector reversed its’ multi-year decline.  The IPCC special report warned that countries’ pledges to reduce their emissions are not in line with limiting global warming to 1.5°C. Some are responding to the crisis – 80 countries are planning to increase their climate pledges ahead of schedule. The UK is the first member of the G7 to legislate net zero emissions, joining Finland and Costa Rica.

The 4th U.S. National Climate Assessment Report starkly warns of risks to the U.S. economy while the Trump administration’s environmental rollbacks are poised to increase GHG emissions significantly. Public opinion is finally shifting with over 70% of Americans saying climate change is a reality, with most believing human activity is primarily responsible. Republican millennials support a carbon tax 7-to-1 with 85% stating that the Republican position on climate change is hurting the party. The Midterm elections flipped the House of Representatives and 7 state governorships to Democrats. Twenty-one states have now joined the U.S. Climate Alliance committed to the Paris Climate Agreement. Four states (CA, WA, HI, NM) and Puerto Rico have targeted 100% clean energy by 2050 or sooner, with nine additional states (IL, MA, MI, MN, MS, NC, NY, PA, WI) proposing similar legislation. The Green New Deal resolution changed the conversation on Capitol Hill and the Climate Action Now Act put the House on record as supporting the Paris Accord.    

Financial markets are not immune to this crisis. Munich Re predicts climate change will price regions out of insurance. The broad acceptance of the TCFD guidelines increases pressure on companies to improve disclosure.

Considering the broader investor landscape and NGO campaigns, the CA100+ global initiative focused on large emitters and led by large asset managers, pension funds, and sovereign funds. Some ICCR members participate in the CA100+ teams while others continue parallel engagements to reinforce the message. Still others are shifting focus to mid-cap companies. We believe that more coordination is needed to increase effectiveness.

Efforts to make methane emissions reduction targets the norm have been limited to the oil & gas majors and larger natural gas producers. The EPA’s proposed rollback of the New Source Performance Standards regulating oil and gas emissions will further erode the regulatory floor, especially as the EPA now proposes to deregulate methane. We look forward to publication of an EDF study on methane measurement and mitigation and Union of Concerned Scientists has formed a working group to study CCS.  

Efforts towards a Just Transition have born fruit as investors and companies have a growing awareness of the unintended, negative consequences that decarbonization has on people. We made a good start with last October’s investor statement, representing $3.7 trillion in assets, and the CA100+ framework, which includes just transition questions; however, most companies lack the policies and practices to address these issues. Addressing the needs of employees, customers and local communities will accelerate transition rather than deter it.

Recalling Fr. Mike Crosby’s prophetic statement, “We are at a Kairos moment,” we look forward to developing with our allies a new strategy statement regarding future engagement of the oil & gas sector to help investors differentiate between fossil fuel companies making progress and those protecting business-as-usual models. Rollout will be stepwise with more guidance forthcoming. Finally, alongside our allies, we have reviewed a draft climate change principles which reflect an increased urgency and stepped up action.

Finally, let us turn to our 2020 engagement strategy. Given our progress in recent years within the electric utility sector, we expect to expand engagements further into mid-cap companies and push for net-zero carbon targets. We will collaborate with NGO’s and other partners to engage the state utility commissions and give input on the Green New Deal. ICCR is planning a multi-stakeholder Roundtable in December to discuss the challenges of decarbonization and promote a just transition.

Investors engaging the financial sector are promoting a shift from simply assessing climate change risk to their own operations to assessing the climate-related risk they facilitate through their lending and underwriting. Coordinating with the Climate Safe Lending Initiative, they plan to engage the top five U.S. banks and some regional banks in 2020 on climate risk. Investors will ask banks to follow the TCFD recommendations, complete a climate impact assessment, pledge no new fossil fuel investments, and ultimately, decarbonize their portfolio (Banking on Climate Change: Fossil Fuel Finance Report Card 2019). Planned for early September, an investor brief and webinar will educate interested investors. As well, we will ask smaller banks to join the Platform Carbon Accounting Framework to calculate their carbon footprint.

Our methane work will continue to promote best practices in measurement and management to minimize methane leakage. We plan to engage companies on including their “non-operated assets” (i.e. joint ventures) in their methane targets, and step up engagement of distributors and retailers to source “sustainably produced” natural gas. At the same time, we recognize that natural gas can no longer be viewed as a “bridge fuel” to clean energy and agree that no new gas power plants can be justified given the climate crisis. On the other hand, replacing industrial and residential uses of natural gas remains a challenge.

It is clear that we recognize the increased urgency and need to step-up our demands. Within ICCR, we reflect this by the change to our Program name from Climate Change to Climate Crisis. This can no longer be considered a gradual change. We are in crisis mode so we need to respond differently!

ICCR Conference Highlights

ICCR Conference Highlights

Chris Cox

By Ann Roberts, Dana Investment Advisors

As always, the ICCR March Conference was an energetic gathering of investors and allies, and attendance was record-breaking. One noticeable change from past conferences was a movement toward a more holistic approach to addressing shareholder concerns, echoing the overarching theme of Pope Francis’ Laudato Si’ that everything is connected. For instance, impact on human rights—the S in ESG–is threaded through all the issues we work on, and it is vital to consider this when advocating for specific changes in environmental and governance issues, as well as social.

Vonda Brunsting, Program Manager, The Just Transition Project, Harvard University

Some highlights include discussion of the Just Transition, which concerns the consequences of transitioning from fossil fuels on stakeholders (loss of jobs in the switch to renewables, loss of tax base for communities, etc.)—merging the E and the S. Worker-driven social responsibility (WSR) efforts such as the Fair Food Program and Milk with Dignity were also discussed. We are asking companies to switch from a mindset of company risk to worker risk. If something is bad for the worker, it is bad for the company. The final session on racial justice was particularly impactful as it reminded us that wealth is created by ownership of assets. Contrary to what politicians and others try to tell us, jobs are not the answer to closing the racial wealth divide. Our tax policies favor capital over labor, which disproportionately helps white people and penalizes minorities.

Most of all, this conference once again confirmed for us that there is strength in numbers. We are better together—and we are all connected.

Decarbonizing Electricity Webinar

Decarbonizing Electricity Webinar

Chris Cox

SGI has been leading important work on climate change with regional utilities. Today, we hosted our first educational webinar of 2019 where we learned more about how we can advance those conversations. We hosted Dan Bakal of Ceres and Franz Litz, program consultant at the Great Plains Institute. Dan has been a key partner in our dialogues with the utilities. Franz has led innovative efforts to bring together policy makers, regulators, utilities, and NGOs to take action on climate change. In particular, he has led the building of a Road Map to Decarbonization in the Midcontinent.

We are very grateful for the presence of both our guests in this webinar, for their commitment to work on this issues, and their generosity in sharing their wisdom with us.

As always, we welcome your feedback via a confidential evaluation found here. Slides from the webinar are found here.

Proposed Rollback of Methane Regulations Threatens Long-term Viability of Oil and Gas Sector

Proposed Rollback of Methane Regulations Threatens Long-term Viability of Oil and Gas Sector

Chris Cox

SGI joined a group of investors in a letter sent to oil and gas companies to warn against the Environmental Protection Agency’s (EPA) proposed rollback of the New Source Performance Standards (NSPS), a regulation the investors say is critical to the long-term viability of the oil and gas sector in the energy transition already underway.

Sent to 30 companies on behalf of 61 investor signatories representing US$1.9 trillion in assets under management, the letter calls upon the companies to offer public support for continued EPA regulation of methane emissions and to oppose the elimination of direct regulation of methane emissions.

More than 610 different companies accounted for 50% of U.S. oil and gas production in 2017. While most of the companies receiving the letter have responded positively to investor engagement on methane management, there are hundreds of companies that are not managing methane emissions carefully, which threatens the reputation of natural gas as a ‘cleaner’ fossil fuel.  A study earlier this year in the journal Science estimated that in the U.S., methane equivalent to 2.3 percent of all the natural gas produced in the nation leaks into the atmosphere during the production, processing and transportation of oil and gas every year.

Strong and fair methane regulations, which require companies to conduct regular inspections for leaks and report on their methane management efforts, create a more stable environment by leveling the playing field among U.S. oil and gas companies. As the U.S. is a net exporter of natural gas, and as an increasing number of countries adopt legislation and other policies to address climate change, sound methane regulation preserves the industry’s global competitiveness. According to the recent IPCC report, countries won’t be able to limit global warming to 1.5 degrees Celsius above pre-industrial levels, considered by some scientists and policymakers to be the “safe” limit of climate change, without immediate and rapid reductions in a wide range of greenhouse gases, including methane.

In 2015, ICCR launched a concerted methane campaign with the goal of engaging primarily U.S. companies across the natural gas value chain on improving disclosure, reducing emissions and reporting critical information on methane management efforts, such as leak detection and repair (LDAR). If the EPA is successful in rolling back the NSPS, LDAR, currently one of the most cost-effective ways to curb dangerous methane emissions, will be significantly weakened which, investors say, benefits no one. 

Apart from publicly declaring their support for the NSPS Rule, we ask companies to submit comments to the EPA regarding the benefits of industry-wide methane regulation by December 17th. 

“The companies receiving the letter are large producers representing 35% of U.S. oil and gas production,” said Rob Fohr of the Presbyterian Church, USA.  “Our hope is to convince these more influential companies to use their voices in support of sensible and cost-effective methane regulation to bring along the entire industry and mitigate the risk of an unregulated market.”

A link to the investor letter and signatories as well as a list of the companies receiving the letter can be found at this link. The complete ICCR press release can be found here. Bloomberg covered the letter in an article here.

Faith-based Investors and the Oil and Gas Sector

Faith-based Investors and the Oil and Gas Sector

Chris Cox

By Frank Sherman

The Intergovernmental Panel on Climate Change (IPCC) recently issued a special report on the impacts of global warming of 1.5 °C above pre-industrial levels and related global greenhouse gas (GHG) emission pathways, in the context of strengthening the global response to the threat of climate change, sustainable development, and efforts to eradicate poverty (see FAQ). This was done in anticipation of the UN Climate Change Conference in Katowice, Poland (COP24) in December.

Under the 2015 Paris Agreement, countries agreed to cut GHG emissions with a view to ‘holding the increase in the global average temperature to well below 2°C above pre-industrial levels and pursuing efforts to limit the temperature increase to 1.5°C above pre-industrial levels’. Human-induced warming has already reached about 1°C above pre-industrial levels and the impacts have already been felt. If the current warming rate continues, the world would reach human-induced global warming of 1.5°C around 2040.

Limiting warming to 1.5°C rather than 2°C can help reduce the risks of severe climate disruption. While some cities, regions, countries, businesses and communities are transitioning towards lower GHG emissions, few are consistent with limiting warming to 1.5°C. Meeting this challenge would require a rapid escalation in the current scale and pace of change. This report brings a new urgency and increased demands in our corporate engagements.

Another report (2020: A Clear Vision For Paris Compliant Shareholder Engagement) was also issued by our partners at As You Sow. Given that the global oil and gas companies contribute 50% of GHG emissions, they must become part of the solution if we have any chance of effectively addressing climate change. After decades of engagement, none of the U.S. oil & gas companies has adopted a plan or a target to limit the GHG emissions associated with their products. This report, written before the IPCC 1.5 degree report was issued, concludes that ‘shareholder engagement must focus on one last, fit for purpose demand, seeking 2-degree assessments from companies in year one and 2-degree action plans by 2020….or investors must divest’.

Given the call for urgent action by the IPCC, we no longer have the luxury of time.

The Decade We Stopped Climate Change

The Decade We Stopped Climate Change

Chris Cox

By Aaron Ziulkowski, Walden Asset Management

A New York Times Magazine published in August included one single article: “Losing Earth: The Decade We Almost Stopped Climate Change.” The title contains the spoiler that we all already knew: We are not stopping climate change. But the focus of the article by Nathaniel Rich—a whopping 30,000 words—is a historical recounting of how close the U.S. and global community came to establishing a binding framework that would have set us on a path to limit warming to what scientists consider manageable. Several decades later, we have still not accomplished this feat.

While some readers likely found the article depressing, it gave me a bit of hope. Rich chronicled a time when the risks of climate change were appreciated and regulations to limit emissions were recognized as the prudent action to take. This knowledge was accepted and embraced by conservatives and liberals as well as leaders of business and advocacy groups. While this promising response eventually derailed, investors may be able to help return the U.S. to a 1980s context—poised to act to mitigate the worst impacts of climate change.

Here’s what we can do.      

Ask companies to set emissions reduction goals that align with climate science. While this may sound outlandish, it is not. Many companies recognize that climate change presents both risks and opportunities and are committed to doing something about it. Forty-eight percent of Fortune 500 companies have set public targets to reduce greenhouse gas emissions, improve energy efficiency, source more renewable energy, or some combination of the three. While some of these targets are not science-based (i.e., aggressive enough to reach carbon neutrality by the second half of the century), nearly five hundred companies from around the globe have publicly committed to set science-based targets, and over one hundred have already done so.

Ask companies to be more transparent about their political spending and lobbying, as well as lobbying done on their behalf by trade associations such as the U.S. Chamber of Commerce. The business community wields significant influence over public policy, for better and for worse. Transparency breeds accountability. As investors, we need to know how a company is lobbying, both because the reputational risk it might entail for the companies we invest in, as well as the risks that lobbying may create for the broader economy. According to AFSCME, more than 40 companies engaged by investors have strengthened their corporate lobbying policies, practices (e.g. a decision to end ties with a third party involved in controversial lobbying activities), and transparency.

Ask companies to proactively advocate for comprehensive climate legislation. While at the federal level it is unlikely there will be an opportunity in the near-term to pass comprehensive climate legislation, there is important groundwork that needs to be done to prepare for when the political moment is right. There are also numerous opportunities to influence state- and local-level policies related to climate change. We should ask companies, especially those that are setting their own goals and targets to reduce emissions, to support legislative and regulatory efforts that are consistent and indeed facilitate achieving their goals. For example, recently, in my home state of Massachusetts, the business community successfully mobilized to support strengthening climate legislation, including the sourcing of renewable energy. Groups like the Business for Innovative Climate and Energy Policy (BICEP), organized by Ceres, can help companies identify and participate in such efforts.

What we did not achieve in the past provides us our current goal and focus. The business community can be a supportive partner in fighting climate change, and investors have an important role in catalyzing that action.

EPA Rolls Back Auto Fuel Efficiency Standards

EPA Rolls Back Auto Fuel Efficiency Standards

Chris Cox

By Frank Sherman

Yesterday, the EPA announced a long awaited rollback of federal fuel economy standards for cars and light-duty trucks in the U.S. (Vox, Aug 2, 2018). (See a previous blog post about it here.) The proposal, released Thursday morning by the EPA and the US Department of Transportation, called the Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule freezes the fuel economy standard for model years 2021-2026. The rule also revokes California’s waiver to set its own rules under the Clean Air Act, a waiver also followed by 13 other states and the District of Columbia, representing approximately 35% of the vehicle market.

The transportation sector has taken over from electric power generation as the largest greenhouse gas emitter in the United States. This short-sighted move not only undermines one of the most significant steps the U.S. has taken to address climate change, but also hurts the global competitiveness of the U.S. auto industry at a time when the world is demanding cleaner, more efficient vehicles. The Union of Concerned Scientists estimated that this rollback would add 570 million metric tons of greenhouse gas emissions by 2030, equivalent to 140 typical coal-fired power plants for a year. The Environmental Defense Fund (EDF) found that the proposal would result in nearly 200 billion gallons of cumulative additional gasoline consumption by 2040. According to Margo Oge, former head of the EPA’s Office of Transportation and Air Quality, the fuel savings alone through 2025 would add up to $1.7 trillion. Ceres estimated the proposal would result in the loss of $20 billion in sales by auto parts suppliers between 2021 and 2025.

The EPA argues that the proposed changes would save money and lives. The agency reported that the prior standards would cost $500 billion over the next 50 years. They claim that people will continue to drive older, less safe cars to avoid the cost of air pollution equipment installed in new cars. “More realistic standards can save lives while continuing to improve the environment,” said EPA Acting Administrator Andrew Wheeler in a statement.

But many question the EPA’s rational. “At first glance, this proposal completely misrepresents costs and savings. It also relies on bizarre assumptions about consumer behavior to make its case on safety,” said California Air Resources Board Chair Mary D. Nichols in a statement. The existing CAFE fuel standards would add an additional $2,340 to the overall ownership costs of a new vehicle or an additional $468 per year over five years. Given that air pollution from vehicles is responsible for 30,000 premature deaths annually, it stands to reason that the lives saved by improving efficiency and reducing air pollution outweigh the lives saved by potential car buyers on the margins upgrading to safer cars.

California plans to fight back. “The Trump Administration has launched a brazen attack, no matter how it is cloaked, on our nation’s Clean Car Standards,” wrote California Attorney General Xavier Becerra in a statement. “The California Department of Justice will use every legal tool at its disposal to defend today’s national standards and reaffirm the facts and science behind them.”

A 60-day comment period will begin once the proposal is published in the Federal Register. Ceres will be organizing investor comments during that time. Buckle your seat belts…