In this report, submitted as comment to the National Highway Traffic Safety Administration (NHTSA), a NERA team analyzes the costs and benefits of proposed Corporate Average Fuel Economy (CAFE) standards for model year 2011–2015 cars and light trucks. The report includes an independent analysis of consumer valuation for fuel economy improvements based on a model of new vehicle market demand developed by the NERA team. The team also reviews NHTSA’s estimates of external costs and benefits of the proposed CAFE regulations and developed alternative estimates of various components, where appropriate. The report was supported by the Alliance of Automobile Manufacturers.