Anyone Can Comment on the Proposed CAFE Changes

Proposed standards are open to comment through the National Highway Traffic Safety Administration.

An Automotive News report tipped us off to a comment recently filed by BMW regarding the proposed change in CAFE standards for model years 2011-2015. Through the magic of public records, we took a look at what BMW and other manufacturers, as well as the general American public, had to say.

Announced on Earth Day earlier this year, the proposed standards will use vehicle ‘footprints’ (basically the ground area covered by a car or truck) to determine the average fuel economy each company needs to meet. Without getting into the specific formula, the legislation can be summed up as requiring vehicle lines with smaller footprints to get better fuel mileage than those with large footprints. That much is intuitive – generally speaking, a large vehicle tends to weigh more and use a larger engine that will get lower fuel mileage.

In its comment, BMW cites the high feature density of its lineup – many of its safety, convenience, and handling systems add weight – as one reason why the footprint model fails. The comment also notes that this footprint system would create a disincentive for adding any advanced technology, while conversely providing incentive for automakers to increase the size of vehicles. BMW mentions that specific efficiency – a vehicle’s fuel economy divided by its weight – should be increased, but that this plan might have the opposite effect.

As an alternative to the new standards, BMW has proposed “an optional uniform standard for those manufacturers that due to their specific range of product portfolio have to increase their fuel economy excessively under NHTSA’s current CAFE proposal, or increase the size of their vehicle fleet.” This plan would allow BMW and similar companies to instead improve fuel economy by 4.5 percent each year, starting in 2010.

Ferrari posted its comments today, and also took issue with the footprint system. The Italian manufacturer notes that a vehicle can be sold with two or more completely different powerplants, while all variations would have the same footprint. Not surprisingly, Ferrari “strongly supports the introduction in the CAFE final rule of specific provisions for small-volume manufacturers (SVMs) which have more; difficulties to implement new technologies, change models frequently, due to limited technical and; financial resources, along with the availability of suppliers which sometimes refuse to sell compliant systems and components because the limited production numbers.”

GM’s 15-page comment states that the company is “fundamentally supportive of reforming the CAFE program to create a system that more equitably treats competing vehicles in the marketplace.” It also takes issue with the distribution used for the footprint system, suggesting an adjustment to the scale. NHTSA requested input regarding the treatment of tow vehicles, and GM suggests that a “heavy-tow capable” classification be created. This would apply to vehicles with a tow weight rating greater than 7700 pounds and compensate for the added weight of hardware necessary for towing.

And then there are the average Joes and Janes who’ve seen fit to throw in their two cents. One commenter, who wished to remain anonymous, said only “Get Real…gas is now over $4 per gallon…”

Public commentary on the Notice of Proposed Rulemaking closes today, though the site also notes that late comments will be accepted.

Source: Automotive News


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