The Consumer Federation of America appreciates the opportunity to provide the Environmental Protection Agency (EPA) with our views on the Final Determination of the Mid-term Evaluation by the EPA and the California Air Resources Board (CARB) which support the standards adopted in National Program for model-years 2022-2025.

Throughout its 50 years of existence, CFA has been a vigorous and continuous participant in the process of setting regulations to improve the efficiency of energy-using consumer durables and lower the cost of energy borne by consumers. Transportation fuels, the source of energy most directly affected by EPA as well as DOT regulations, are a major household expenditure, representing over 3 percent of total expenditures, one of the 6 largest subcategories listed in the consumer expenditure survey. Factoring in indirect expenditures on fuels consumed by commercial fleets, which consumers pay for in the price of goods and services, would push transportation fuel consumption above 5%, making it the third or fourth largest household expenditure.

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