CAFE Craziness

Mary Peters, the secretary of the Department of Transportation, chose Earth Day to announce the new proposed Corporate Average Fuel Economy (CAFE) standards for passenger cars and light trucks for model years 2011 through 2015.

The proposal calls for a fleet average of 31.6 mpg by 2015 (35.7 mpg for passenger cars, 28.6 mpg for light trucks). Wanting to learn more than what I could find in the daily newspapers, I went to the NHTSA Web site, located the document containing the proposed regulations, and downloaded it to my desktop. Here’s what you need to know about government proposals: They’re extremely wordy, high on technical jargon, and low on user-friendliness. This particular document is 417 pages long and contains paragraphs such as the following:

“For both passenger cars and light trucks, the agency is proposing CAFE standards estimated, as for the previously-promulgated reformed MY2008-2011 light truck standards, to maximize net benefits to society. However, as discussed in Section V, the agency considered and analyzed modified approaches to calibrating the continuous function and fitting the data in order to address characteristics of the data (vehicles with outlying fuel economy, footprint, and or sales), and to address the issues of backsliding, steepness of the curve, and curve crossings from one model year to the next.”

Undaunted, I slogged on, trying to find some useful nuggets of information. For instance: “The total costs for manufacturers just complying with the standards for MY 2011-2015 passenger cars would be approximately $16 billion compared to the costs they would incur if the standards remained at the adjusted baseline.” And that’s just for passenger cars; you need to add another $31 billion for complying with the standards for light trucks. So we’re talking about $47 billion in manufacturer costs to an industry that, especially in the U.S., is struggling to stay afloat.

I also came across the following: “The resulting vehicle price increases to buyers of MY 2015 passenger cars would be recovered or paid back in additional fuel savings in an average of 56 months, assuming fuel prices ranging from $2.26 per gallon in 2016 to $2.51 per gallon in 2030.” If only I could find a gas station that would sell me a gallon of gas for $2.26 a gallon today, much less in 2016.

And then there was this paragraph, which referred to reductions in CO2 emissions and increases in fuel economy since 1975: “In 1975, passenger cars manufactured for sale in the U.S. averaged only 15.8 mpg (562.5 grams of CO2 per mile or 562.5 g/mi of CO2). By 2007, the average fuel economy of passenger cars had increased to 31.3 mpg, causing g/mi to CO2 to fall to 283.9. Similarly, in 1975, light trucks averaged 13.7 mpg (648.7 g/mi of CO2). By 2007, the average fule economy of light trucks had risen to 23.1 mpg, causing g/mi of CO2 to fall to 384.7.”

Call me skeptical, but those 2007 mpg figures seemed suspect. So I went to and did a search for vehicles with a combined EPA rating of at least 30 mpg. The only ones that filled the bill were, in alphabetical order: Ford Escape Hybrid, Honda Civic Hybrid, Honda Fit, Mazda Tribute Hybrid, Mercury Mariner Hybrid, MINI Cooper, Nissan Altima Hybrid, smart fortwo, Toyota Camry Hybrid, Toyota Corolla, Toyota Prius, and Toyota Yaris. In a market that numbers more than 200 different vehicles, that means only 12 of them return more than 30 mpg. So how is it possible that the 2007 average is 31.7? Obviously, the system is being gamed. And, one assumes, it will continue to be gamed in the future, so that the new mark can be met.

Environmentally speaking, better fuel economy and lower emissions is an honorable goal. But after spending an afternoon with the proposed CAFE regulations, it seems like there must be a better way to get there…


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