Auto Innovators submitted comments on September 20 on NHTSA’s Supplemental Notice of Proposed Rulemaking on civil penalties. This is in support of Auto Innovators’ fall 2020 petition that NHTSA set civil penalties for model years 2019-2021 at $5.50 per tenth of a mile per gallon, and at $14 for model years 2022 and beyond. Auto Innovators provided legal analysis and economic information in support of this request.