Corporate Average Fuel Corporate Average Fuel Economy (CAFE) StandardsEconomy (CAFE) Standards

Jennifer AlexanderJennifer Alexander

Spring 2008Spring 2008

Outline Outline

Energy Policy Conservation Act of 1975Energy Policy Conservation Act of 1975 CAFE Program and how it is administeredCAFE Program and how it is administered How standards are calculatedHow standards are calculated Light Truck programLight Truck program New Light truck standardsNew Light truck standards Energy Independence and Security Act of Energy Independence and Security Act of

20072007

EnergyEnergy Policy Conservation Act Policy Conservation Act 49 USC 32949 USC 329

-Passed in 1975, in response to Arab oil embargo

-In 1974, average passenger car fuel economy was 12.9 mpg

-Title V: “Improving Automotive Efficiency”

- Established CAFE standards for passenger cars for model year (”MY”) 1978-MY1980 and 1985 and beyond, and for light trucks beginning in MY1979.

-Standards in 1978 were to be 18 mpg, 19 mpg in 1979, 20 mpg in 1980 and 27.5 in 1985, which has remained constant until today

-Secretary of Transportation (DOT) set standards for interim years of 81-84

-Goal was to double new car fuel efficiency by 1985

Who Administers the Program?Who Administers the Program?• EPCA granted National Highway Transportation EPCA granted National Highway Transportation

Safety Administration (NHTSA), part of the Safety Administration (NHTSA), part of the Department of Transportation, the authority to Department of Transportation, the authority to administer the CAFE program. administer the CAFE program.

• EPCA (Congress) set standards for passenger EPCA (Congress) set standards for passenger cars.cars.

• NHTSA has the authority to set standards for other NHTSA has the authority to set standards for other classes of vehicles, including light trucks. classes of vehicles, including light trucks.

After 1985, Secretary of Transportation has After 1985, Secretary of Transportation has discretion to adjust passenger car standard within discretion to adjust passenger car standard within range of 26.0 and 27.5mpg. An increase above or range of 26.0 and 27.5mpg. An increase above or below requires Secretary to issue amendment below requires Secretary to issue amendment which is in force until Congress disapproves.which is in force until Congress disapproves.

Secretary has much broader discretion with Secretary has much broader discretion with regards to light trucks. Congress set no specific regards to light trucks. Congress set no specific standards, and left it up to DOTstandards, and left it up to DOT

NHTSA also does things such as: establishes and NHTSA also does things such as: establishes and amends standards, promulgates regulations amends standards, promulgates regulations regarding CAFE procedures, enforces standards, regarding CAFE procedures, enforces standards, considers petitions for exemptions, collects considers petitions for exemptions, collects manufacturers reports, and more.manufacturers reports, and more.

EPA has responsibility for calculating fuel EPA has responsibility for calculating fuel economy for each manufacturereconomy for each manufacturer

““Maximum Feasible Fuel Economy Maximum Feasible Fuel Economy Standards”Standards”

EPCA dictates that DOT’s determination to EPCA dictates that DOT’s determination to change standards must be made in change standards must be made in consideration of 4 factors:consideration of 4 factors:

1)1) Technological FeasibilityTechnological Feasibility2)2) Economic PracticabilityEconomic Practicability3)3) Effect of other standards on fuel economy; Effect of other standards on fuel economy;

andand4)4) Need of the nation to conserve energyNeed of the nation to conserve energy

49 USC 32902(a)49 USC 32902(a)

Cafe Standard is:Cafe Standard is:– ““a performance standard specifying a minimum level of average a performance standard specifying a minimum level of average

fuel economy applicable to a manufacturer in a model year”fuel economy applicable to a manufacturer in a model year”

49 USC 32901(a)(6)49 USC 32901(a)(6)

Automobile is defined:Automobile is defined:– ““A four wheeled vehicle that is propelled by fuel, or by alternative A four wheeled vehicle that is propelled by fuel, or by alternative

fuel, manufactured primarily for use on public streets, roads, and fuel, manufactured primarily for use on public streets, roads, and highways…and rated at –highways…and rated at – Not more than 6,000 lbs gross vehicle weight, orNot more than 6,000 lbs gross vehicle weight, or More than 6,000 pounds GVW, if the secretary decides by More than 6,000 pounds GVW, if the secretary decides by

regulation that-regulation that-– An average fuel economy standard under this chapter is feasible, An average fuel economy standard under this chapter is feasible,

andand

– […] the vehicle is substantially used for the same purposes as a […] the vehicle is substantially used for the same purposes as a vehicle rated at not more than 6,000 lbs GVR”vehicle rated at not more than 6,000 lbs GVR”

49 USC 32901(a)(3)49 USC 32901(a)(3)

Passenger Automobile:Passenger Automobile:– ““Automobile that the Secretary decides by regulation is manufactured Automobile that the Secretary decides by regulation is manufactured

primarily for transporting not more than 10 individuals, but does not include primarily for transporting not more than 10 individuals, but does not include an automobile capable of off-highway operation that the Secretary decides an automobile capable of off-highway operation that the Secretary decides by regulation-by regulation- Has a significant feature (except 4-wheel drive) designed for off-Has a significant feature (except 4-wheel drive) designed for off-

highway operation; andhighway operation; and Is a 4-wheel drive automobile or is rated at more than 6,000 pounds Is a 4-wheel drive automobile or is rated at more than 6,000 pounds

GVWRGVWR””49 USC 32901(a)(16)49 USC 32901(a)(16)

Light truck: Light truck: (set out in regulations, not EPCA)(set out in regulations, not EPCA)

– Automobile other than a passenger automobile which is either designed for Automobile other than a passenger automobile which is either designed for off-highway operation, oroff-highway operation, or

– Is rated at more than 6,000 lbs GVW; and Is rated at more than 6,000 lbs GVW; and

– That has at least four of the following characteristics [affecting off road That has at least four of the following characteristics [affecting off road capability relating to approach angle, breakover angle, departure angle, capability relating to approach angle, breakover angle, departure angle, running clearance, and front and rear axle clearance]running clearance, and front and rear axle clearance]

CAFE CalculationCAFE Calculation

““Two-Fleet Rule”: Domestic and foreign produced cars Two-Fleet Rule”: Domestic and foreign produced cars measured separately, each must meet standardmeasured separately, each must meet standard

No such two-fleet rule for light trucksNo such two-fleet rule for light trucks Fleet average is a sales weighted meanFleet average is a sales weighted mean Compliance is measured by using harmonic mean Compliance is measured by using harmonic mean

calculation calculation

Fleet’s Fleet’s Fuel Fuel Economy Economy ==

How is fuel economy determined?How is fuel economy determined? 3 sets of calculations: NHTSA’s figures, EPA’s unadjusted dynamometer 3 sets of calculations: NHTSA’s figures, EPA’s unadjusted dynamometer

values, and EPA’s adjusted on-road values. values, and EPA’s adjusted on-road values. EPA does laboratory tests that measure emissions, and based on amount EPA does laboratory tests that measure emissions, and based on amount

of carbon emitted during the test they determine the fuel economy.of carbon emitted during the test they determine the fuel economy. Adjusted values are the ones currently listed on new car labels, they are Adjusted values are the ones currently listed on new car labels, they are

adjusted for a number of factors.adjusted for a number of factors. EPA used to perform tests in 75* weather, with acceleration and speeds EPA used to perform tests in 75* weather, with acceleration and speeds

lower than average driver uses, and without accessories turned on (AC, lower than average driver uses, and without accessories turned on (AC, radio).radio).

Ann Arbor, MIAnn Arbor, MI

Chevy Silverado being tested Chevy Silverado being tested in dynamometerin dynamometer

EPA’s new fuel economy stickersEPA’s new fuel economy stickers

New test methods (appearing on MY2008 stickers) will New test methods (appearing on MY2008 stickers) will

bring estimates closer to actual fuel economy bybring estimates closer to actual fuel economy by factoring factoring in 1) high speeds and quicker accelerations, 2) air in 1) high speeds and quicker accelerations, 2) air conditioning use, 3) and driving in cold temperatures, as conditioning use, 3) and driving in cold temperatures, as well as road conditions, tire pressure, load, and different well as road conditions, tire pressure, load, and different fuels. fuels.

Beginning in 2011, labels will be required on certain Beginning in 2011, labels will be required on certain vehicles up to 10,000 lbs GVWR vehicles up to 10,000 lbs GVWR

Labels are redesigned to make it easier for consumers to Labels are redesigned to make it easier for consumers to compare vehiclescompare vehicles

In 2011, more vehicle specific testing to be done, for In 2011, more vehicle specific testing to be done, for vehicles most sensitive to the 3 new adjustments vehicles most sensitive to the 3 new adjustments

PenaltiesPenalties

If average fuel economy of a manufacturer’s fleet falls If average fuel economy of a manufacturer’s fleet falls below the standard, manufacturer must pay penalty of below the standard, manufacturer must pay penalty of $5.50 per 0.1 mpg below the standard, times the total $5.50 per 0.1 mpg below the standard, times the total number of vehicles in fleet for that model year in violationnumber of vehicles in fleet for that model year in violation

Since 1983, over $675M in penalties paidSince 1983, over $675M in penalties paid Most European manufacturers regularly pay, Asian and the Most European manufacturers regularly pay, Asian and the

big domestic companies have never paid fines. big domestic companies have never paid fines. In 2006, Maserati, BMW, Porsche, Volkswagen, and In 2006, Maserati, BMW, Porsche, Volkswagen, and

DaimlerChrysler ($30M) all paid fines in excess of $1M DaimlerChrysler ($30M) all paid fines in excess of $1M (and Ferrari paid $850K)(and Ferrari paid $850K)

OffsetsOffsets

Manufacturers can earn credits for any year they exceed Manufacturers can earn credits for any year they exceed the standard for that fleetthe standard for that fleet

Credits can be “banked” for up to three yearsCredits can be “banked” for up to three years Offsets can be used to cover penalties up to three yearsOffsets can be used to cover penalties up to three years The amount of credit a manufacturer earns is determined The amount of credit a manufacturer earns is determined

by multiplying the tenths of a mile per gallon that the by multiplying the tenths of a mile per gallon that the manufacturer exceeded the CAFE standard in that model manufacturer exceeded the CAFE standard in that model year by the amount of vehicles they manufactured in that year by the amount of vehicles they manufactured in that model year model year

““Carry Back Plan” – can be used to avoid penalties when Carry Back Plan” – can be used to avoid penalties when manufacturer is in violation and has no credits. Must submit manufacturer is in violation and has no credits. Must submit plan to NHTSA detailing what manufacturer plans to do in plan to NHTSA detailing what manufacturer plans to do in the next 3 years to make up the current deficitthe next 3 years to make up the current deficit

Alternative Fuel VehiclesAlternative Fuel Vehicles

49 USC 32905- 49 USC 32905- Manufacturing incentives for Manufacturing incentives for alternative fuel automobilesalternative fuel automobiles

Dual fuel calculation used as incentive to Dual fuel calculation used as incentive to develop alternative fuel vehicles. develop alternative fuel vehicles.

Dual fuel vehicles can take advantage of Dual fuel vehicles can take advantage of this credit, even though less than 1% of the this credit, even though less than 1% of the fuel used in E85 capable vehicles is E85.fuel used in E85 capable vehicles is E85.

Alternative Fuel VehiclesAlternative Fuel Vehicles

-- For vehicles that use only an alternative fuel, For vehicles that use only an alternative fuel, fuel economy is calculated by dividing its fuel fuel economy is calculated by dividing its fuel economy in equivalent miles per gallon of economy in equivalent miles per gallon of gasoline or diesel fuel by 0.15. So a Car that gets gasoline or diesel fuel by 0.15. So a Car that gets 15 mpg alternative fuel is equal to 100 mpg gas15 mpg alternative fuel is equal to 100 mpg gas- Dual Fuel Vehicles – average of fuel Dual Fuel Vehicles – average of fuel economy on gasoline/diesel with fuel economy on alternative fuel, economy on gasoline/diesel with fuel economy on alternative fuel,

divided by 0.15. divided by 0.15. 1/{0.5/(mpg gas) + 0.5/(mpg alt fuel)} = 1/{0.5/25 + 1/{0.5/(mpg gas) + 0.5/(mpg alt fuel)} = 1/{0.5/25 + 0.5/100) = fuel economy for duel fuel vehicle0.5/100) = fuel economy for duel fuel vehicle

Natural gas vehicles - weighted average on using natural gas and Natural gas vehicles - weighted average on using natural gas and gasoline/diesel. Alternative Motor Fuels Act says that 100gasoline/diesel. Alternative Motor Fuels Act says that 1003 3 ft of ft of natural gas is equal to 0.823 gallons of gasoline. Same 0.15 natural gas is equal to 0.823 gallons of gasoline. Same 0.15 equivalency to gasoline for natural gas. For a car that gets 25 mpg equivalency to gasoline for natural gas. For a car that gets 25 mpg for natural gas:for natural gas:– CAFE FE = (25/100) * (100/.823)*(1/0.15) = 203 mpgCAFE FE = (25/100) * (100/.823)*(1/0.15) = 203 mpg

Light TrucksLight Trucks Originally light trucks were up to Originally light trucks were up to

6,000 lbs gross vehicle weight rating 6,000 lbs gross vehicle weight rating (GVWR). (GVWR).

As of 1980 light truck standards are As of 1980 light truck standards are for trucks up to 8,500 lbs GVWRfor trucks up to 8,500 lbs GVWR

Before 1992, there was a “two-fleet Before 1992, there was a “two-fleet rule” for LDTs – 4-wheel drive and 2-rule” for LDTs – 4-wheel drive and 2-wheel drive LDTs measured wheel drive LDTs measured seperately. seperately.

In MY1979, first year of LDT In MY1979, first year of LDT standards, standard was 17.2 for 2-standards, standard was 17.2 for 2-wheel and 15.8 for 4-wheel drive. wheel and 15.8 for 4-wheel drive.

Standard progressively increased to Standard progressively increased to 20.7 in 1996, when DOT 20.7 in 1996, when DOT Appropriations included a prohibition Appropriations included a prohibition against making any adjustments past against making any adjustments past 20.7mpg 20.7mpg

Change in LDT standardChange in LDT standard

In conference on 2001 DOT appropriations bill, Senate In conference on 2001 DOT appropriations bill, Senate insisted the freeze on LDT CAFE standard be droppedinsisted the freeze on LDT CAFE standard be dropped

This opened the way for NHTSA to begin rulemaking to This opened the way for NHTSA to begin rulemaking to increase LDT standard againincrease LDT standard again

In December 2002, believing that “some manufacturers In December 2002, believing that “some manufacturers may be able to achieve higher CAFE performance than may be able to achieve higher CAFE performance than they currently projectthey currently project”1”1, NHTSA proposed a rule increasing , NHTSA proposed a rule increasing LDT CAFE to 21.0 mpg in MY2005, 21.6 mpg in MY2006, LDT CAFE to 21.0 mpg in MY2005, 21.6 mpg in MY2006, and 22.2 mpg in MY2007. and 22.2 mpg in MY2007.

On April 3, 2003, NHTSA adopted this proposed rule. On April 3, 2003, NHTSA adopted this proposed rule.

New Light Truck Rules (MY2008-New Light Truck Rules (MY2008-2011)2011)

In April 2006, NHTSA issued a Final Rule In April 2006, NHTSA issued a Final Rule increasing stringency of LDT program standards, increasing stringency of LDT program standards, and restructuring the way the standards are and restructuring the way the standards are calculated – calculated – “Reformed Standards“Reformed Standards””

First phase of new rules was to be MY2008-2011. First phase of new rules was to be MY2008-2011. Before 2011, manufacturers can choose to use Before 2011, manufacturers can choose to use

reformed or unreformed standards to calculate reformed or unreformed standards to calculate compliance. Unreformed standards use current compliance. Unreformed standards use current system of single average mandated for entire fleet.system of single average mandated for entire fleet.

For the first time, medium-duty passenger For the first time, medium-duty passenger vehicles, vehicles between 8,500 GVW and vehicles, vehicles between 8,500 GVW and 10,000 GVW will be subject to CAFE standards. 10,000 GVW will be subject to CAFE standards.

Unreformed CAFE standards up to 2011Unreformed CAFE standards up to 2011

Reformed Standards for LDT’sReformed Standards for LDT’s

Fuel Economy standard no longer one uniform number, but Fuel Economy standard no longer one uniform number, but based on based on “footprint”“footprint” of car- product of vehicle’s of car- product of vehicle’s wheelbasewheelbase (distance between the centers of the axels) and its (distance between the centers of the axels) and its track track widthwidth (distance between center line of the tired) (distance between center line of the tired)

Using continuous mathematical formula, in which a target Using continuous mathematical formula, in which a target fuel economy would be set for each increment in footprintfuel economy would be set for each increment in footprint

Incremental fuel economy standard in final rule

Smaller footprint trucks had higher targets, larger Smaller footprint trucks had higher targets, larger footprint trucks had lower fuel economy targetsfootprint trucks had lower fuel economy targets

Manufacturer’s mandated fuel economy is Manufacturer’s mandated fuel economy is calculated based on sales weighted average of calculated based on sales weighted average of targets for each vehicle line. targets for each vehicle line.

Manufacturers who make more small trucks would Manufacturers who make more small trucks would have to meet a higher standard, and those who have to meet a higher standard, and those who make primarily large trucks would have to meet a make primarily large trucks would have to meet a lower overall standardlower overall standard

No particular overall standard a manufacturer had No particular overall standard a manufacturer had to meet. No specific vehicle is required to meet to meet. No specific vehicle is required to meet specific fuel economy, only required that average specific fuel economy, only required that average meets standard that is based on the overall fleet meets standard that is based on the overall fleet mixmix

Proposed Reformed CAFE Standards (miles per gallon)(from Notice of Proposed Rulemaking, but not actually adopted.)

Category 1 2 3 4 5 6

Range of vehicle footprint (in square feet)

<=43.0

>43.07–47.0

>47.0–52.0

>52.0–56.5

>56.5–65.0

>65.0

MY 2008 targets 26.8 25.6 22.3 22.2 20.720.4

MY 2009 targets 27.4 25.6 23.5 22.7 21.021.0

MY 2010 targets 27.8 26.4 24.0 22.9 21.620.8

MY 2011 targets 28.4 27.0 24.5 23.3 21.721.2

Source: National Highway Traffic Safety Administration, Notice of Proposed Rulemaking, "Average Fuel Economy Standards for Light Trucks Model Years 2008-2011," 49 CFR Parts 523, 533 and 537, Docket no. 2005-RIN2127-AJ61.

Challenge to NHTSA Final RuleChallenge to NHTSA Final Rule 11 states, DC, NYC, and four public interest organizations 11 states, DC, NYC, and four public interest organizations

filed petition for review of final rule for LDT MY2008-filed petition for review of final rule for LDT MY2008-MY2011, in MY2011, in Center for Biological Diversity v. NHTSA, Center for Biological Diversity v. NHTSA, 508 508 F.3d 508 (9th Cir. 2007). F.3d 508 (9th Cir. 2007).

Challenged final rule under EPCA and NEPA. Challenged final rule under EPCA and NEPA. EPCA Arguments:EPCA Arguments:

– Arbitrary and capricious and contrary to EPCAArbitrary and capricious and contrary to EPCA– Agency did not set CAFE standards at “maximum feasible” levels. Agency did not set CAFE standards at “maximum feasible” levels. – Cost-benefit analysis done by NHTSA gave no benefit to reducing Cost-benefit analysis done by NHTSA gave no benefit to reducing

COCO2 2 emissions, emissions, – Using vehicle attributes to set fuel economy standard means there Using vehicle attributes to set fuel economy standard means there

is no “backstop”, or floor fuel economy to meet for a given year. is no “backstop”, or floor fuel economy to meet for a given year. This will encourage manufacturers to make bigger vehicles.This will encourage manufacturers to make bigger vehicles.

– Did not address “SUV loophole”- allows these vehicles to meet Did not address “SUV loophole”- allows these vehicles to meet lower CAFE standard even though many are built on car platforms lower CAFE standard even though many are built on car platforms and serve same function as passenger cars. and serve same function as passenger cars.

Argued under NEPA that the final rule failed Argued under NEPA that the final rule failed to take a “hard look” at the GHG implications to take a “hard look” at the GHG implications of its rulemaking and they failed to look at of its rulemaking and they failed to look at rule’s cumulative impact. rule’s cumulative impact.

NHTSA must prepare EIS, not just EANHTSA must prepare EIS, not just EA

99thth Circuit overturns NHTSA rules Circuit overturns NHTSA rules Court found rules “arbitrary Court found rules “arbitrary

and capricious” and and capricious” and contrary to EPCAcontrary to EPCA

Court agreed with Court agreed with possibility of having no possibility of having no backstop on truck size backstop on truck size would continue to permit would continue to permit upsizing, and failed to upsizing, and failed to prevent trucks from prevent trucks from emitting more COemitting more CO2 2 than in than in previous yearsprevious years

The decision not to The decision not to address the “SUV address the “SUV loophole” was arbitrary loophole” was arbitrary and capricious, it was and capricious, it was contrary to the language of contrary to the language of the law. the law.

NHTSA incorrectly set value of NHTSA incorrectly set value of $0 to global warming damage $0 to global warming damage caused by truck usagecaused by truck usage

NHTSA rules also failed to promulgate fuel economy NHTSA rules also failed to promulgate fuel economy standards for vehicles weighing 8,500-10,000 lb GVW, nor standards for vehicles weighing 8,500-10,000 lb GVW, nor did they show that there was a “validly reasoned basis” for did they show that there was a “validly reasoned basis” for not doing so. not doing so.

Environmental Assessment done was inadequateEnvironmental Assessment done was inadequate These rules may in fact have a significant impact on the These rules may in fact have a significant impact on the

environmentenvironment 99thth Circuit returned the rules to NHTSA, saying that they Circuit returned the rules to NHTSA, saying that they

must make new standards as “expeditiously as possible” must make new standards as “expeditiously as possible” and fully evaluate the impacts of these standards on the and fully evaluate the impacts of these standards on the environmentenvironment

Energy Independence and Security Energy Independence and Security Act of 2007Act of 2007

P.L. 110-1040P.L. 110-1040 Omnibus energy policy Omnibus energy policy

law aimed as law aimed as increasing energy increasing energy efficiency and efficiency and renewable energy renewable energy availability.availability.

Titles I-XVITitles I-XVI

President Bush signed President Bush signed EISA into law EISA into law December 19, 2007December 19, 2007

.

Highlights of EISAHighlights of EISA

Title I- Energy Security Through Improved Vehicle Fuel Title I- Energy Security Through Improved Vehicle Fuel EconomyEconomy

Title II – BiofuelsTitle II – Biofuels Title III - Standards for appliances and lightingTitle III - Standards for appliances and lighting Title VI – Research and DevelopmentTitle VI – Research and Development Title VII – Carbon Capture and SequestrationTitle VII – Carbon Capture and Sequestration Title X – Green JobsTitle X – Green Jobs Title XI – Energy Transportation and InfrastructureTitle XI – Energy Transportation and Infrastructure Title XII – Small Business Energy ProgramsTitle XII – Small Business Energy Programs

Title I – Fuel EconomyTitle I – Fuel Economy

Statute sets a 35 mpg standard for both Statute sets a 35 mpg standard for both passenger cars and light duty trucks by 2020passenger cars and light duty trucks by 2020

Although cars and trucks must meet the same Although cars and trucks must meet the same standard, they are still measured separately. standard, they are still measured separately.

Can use attribute-based standards, which Can use attribute-based standards, which Bush administration says will ensure increased Bush administration says will ensure increased fuel economy doesn’t come at the expense of fuel economy doesn’t come at the expense of safetysafety

April 22 UpdateApril 22 Update(Earth Day…coincidence?)(Earth Day…coincidence?)

Administration announced interim standards for 2015 of Administration announced interim standards for 2015 of 31.5 mpg (combined)31.5 mpg (combined)

Will force auto makers to speed up their development of Will force auto makers to speed up their development of more fuel efficient vehicles. more fuel efficient vehicles.

4.5 percent increase per year from 2011-20154.5 percent increase per year from 2011-2015 Would be a 25 percent increase by 2015 (EISA requires Would be a 25 percent increase by 2015 (EISA requires

40% by 2020)40% by 2020) DOT took carbon dioxide into account in its costs and DOT took carbon dioxide into account in its costs and

benefits analysisbenefits analysis Manufacturer standard would be based on type of vehicles Manufacturer standard would be based on type of vehicles

they sell, based on vehicle “attributes”they sell, based on vehicle “attributes” Manufacturers can sell credits Manufacturers can sell credits

Conclusions and Implications for Conclusions and Implications for FutureFuture

Do regulations affect consumer choice? Or do gas prices?Do regulations affect consumer choice? Or do gas prices? Will better fuel economy mean more driving, possibly Will better fuel economy mean more driving, possibly

negating advances in fuel economy?negating advances in fuel economy? How much will auto industry to do prevent further How much will auto industry to do prevent further

increases, since they make more money off larger cars?increases, since they make more money off larger cars? Safety Impacts? Are smaller cars really inherently less Safety Impacts? Are smaller cars really inherently less

safe? Or do lower fuel economy standards for trucks just safe? Or do lower fuel economy standards for trucks just allow automakers to make heavier cars, making it less safe allow automakers to make heavier cars, making it less safe for drivers of small cars? Will increased standards help for drivers of small cars? Will increased standards help move towards evening out auto weights across fleet lines?move towards evening out auto weights across fleet lines?

Implications and thoughts (cont’d.)Implications and thoughts (cont’d.)

Should the timetable set have been shorter? Are auto Should the timetable set have been shorter? Are auto manufacturers given too much time to comply?manufacturers given too much time to comply?

Will a uniform standard for passenger cars and light trucks Will a uniform standard for passenger cars and light trucks mean the end of SUVs and minivans? These cars were mean the end of SUVs and minivans? These cars were created in response to CAFE standards, because created in response to CAFE standards, because standards for light duty truck were lower and these autos standards for light duty truck were lower and these autos could fit into this new category.could fit into this new category.

Is it possible that rather than causing all the “doomsday” Is it possible that rather than causing all the “doomsday” situations opponents of tighter standards predict, that these situations opponents of tighter standards predict, that these standards will finally force automakers to increase the standards will finally force automakers to increase the technology of engines, something many say should have technology of engines, something many say should have been done years ago, and actually effectively effectuate been done years ago, and actually effectively effectuate Congress’s goals?Congress’s goals?