Competitive Enterprise Institute v. National Highway Traffic Safety Administration
United States Court of Appeals for the District of Columbia Circuit
956 F.2d 321 (1992)
- Written by David Bloom, JD
Facts
The National Highway Traffic Safety Administration (NHTSA) (defendant) had the authority to regulate the corporate average fuel economy (CAFE) standard for motor vehicles produced by manufacturers. Pursuant to the Energy Policy and Conservation Act (EPCA), manufacturers were held to the standard of 27.5 miles per gallon (mpg) for car models made in 1985 and each subsequent model year. NHTSA had the discretion to change the CAFE standard each year. The Competitive Enterprise Institute (CEI) (plaintiff) urged NHTSA to lower the CAFE standard, asserting that for manufacturers to produce larger, safer cars under the 27.5-mpg standard would not be economically feasible. NHTSA agreed to lower the CAFE standard to 26.5 mpg in 1989. NHTSA reinstituted the EPCA’s 27.5-mpg standard for 1990 without providing any genuine explanation for that decision. NHTSA also did not consider whether the intended fuel savings from the higher standard outweighed the safety risks associated with having a short supply of larger cars available to consumers. No dispute was presented that larger cars were generally safer than smaller cars. CEI petitioned the court to review NHTSA’s decision, arguing that the higher fuel-economy standard would force car makers to produce smaller, less safe cars and make affording larger, safer cars more difficult for consumers.
Rule of Law
Issue
Holding and Reasoning (Williams, J.)
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