The Truth About NHTSA's Revised Corporate Average Fuel Economy Figures
On Friday, Senator Carl Levin condemned a draft Commerce Committee bill revising federal Corporate Average Fuel Economy (CAFE) standards. The bill would raise the required average to 28.5 mpg by 2015 and 35 mpg by 2020, with four percent annual increases thereafter. The Michigan Democrat threatened to filibuster the bill. In fact, Levin should shut the Hell up. If passed as is, the Commerce bill would create The Mother of All Loopholes.
Part of the proposed Commerce bill directs the National Highway Safety Traffic Administration (NHTSA) to change passenger car fleet averages to a system based on a given vehicle’s “footprint” (wheelbase times width divided by 144).
To understand the implications of this change, consider the impact of the same “reformed system” on light truck CAFE standards, which take effect this year (albeit on an opt-in basis until 2010).
Light truck footprint-based fuel economy standards are based on a sliding scale. Simply put, smaller vehicles must be significantly more frugal than big ones, and every light truck within that spectrum must meet a size-specific mpg target.
But there is no requirement to create a mix of vehicles whose combined fuel economy adheres to a federally mandated overall average. In other words, according to the new rules, the sliding scale IS the Corporate Average Fuel Economy standard, NOT a manufacturer's fleet-wide light truck average.
The change has freed light truck manufacturers from any obligation to build a “mixed fleet” of vehicles that meet an overall fuel economy average. I repeat: Ford, GM, Dodge, Toyota, etc. can build any size truck they like as long as it meets its size-specific fuel efficiency target.
If cars switch to this same system, they’ll be subject to a similar curve as their light truck counterparts: small cars will have to meet much higher fuel efficiency standards than mid and large-sized cars. And domestic manufacturers will be under no obligation to build a mix of vehicles that achieves an overall average. As long as any given passenger car meets the appropriate size-related standard, they’re good to go.
The United Auto Workers (UAW) appreciates the enormous implications of this rule change. The UAW’s legislative director told the House Commerce committee that his employer vehemently opposes changing passenger car CAFE requirements to a footprint calculation. lan Reuther said the move would lead The Big 2.5 to completely abandon the small car market to foreign manufacturers (eliminating union jobs in the process).
True dat. It’s an open secret that Detroit only makes econoboxes to meet CAFE standards. They’re a “loss leader” that allows them to sell large, large-profit vehicles. Without a federal obligation to build uncompetitive, unprofitable small cars, Detroit would cut bait and fish.
And if you thought that higher CAFE standards would lead to more people buying smaller cars, think again. In fact, basing standards on vehicle footprints could lead consumers in the opposite direction.
In a document outlining the impact of “reformed” standards on light trucks, the Department of Transportation noted “Downsizing of vehicles is discouraged under Reformed CAFE since as vehicles become smaller, the applicable fuel economy target becomes more stringent.”
If that doesn’t make the new bill on federal fuel economy standards all Detroit’s Christmases rolled into one, the new proposed CAFE legislation also includes a "get out jail free" card: NHTSA can lower fuel economy mandates if the agency determines they’re not “cost effective” or “feasible” in a given model year.
It’s a mostly forgotten fact that Congress has already charged NHTSA with setting CAFE standards. They’re supposed to do so at the “maximum feasible level” according to “economic practicability, technological feasibility, the effect of other standards on fuel economy and the need of [sic] the nation to conserve energy.”
Obviously, Congress has usurped NHTSA’s authority. Worse, the new proviso or “off ramp” turns NHTSA’s theoretical CAFE evaluations into an all-too-real politically-charged adjudication.
When an automaker or group of automakers ask the agency for a CAFE wavier based on poverty or technical challenges, how would NHTSA make its decision? Does Congress seriously expect NHTSA to examine an automaker’s books or R&D labs to determine whether to waive CAFE compliance?
But wait there’s more! Under the proposed legislation, Detroit automakers would be able to use CAFE credits to meet fuel economy mandates for five years (two more than currently). AND they’d be able to buy and sell credits amongst fellow manufacturers.
I’m having trouble getting my head ‘round all this. Unless the Senate strips off all these little goodies, Detroit’s bitching about a federal bill that will nearasdammit remove their unprofitable CAFE commitments.
Perhaps they’re getting the media to focus on illusory CAFE numbers so they won’t consider the fine print that renders them largely meaningless. Is Detroit really that devious? If they are, how did they get themselves into this mess in the first place?
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