Comment on NHTSA's Proposed Small Increase In SUV Fuel Economy Standards by Mothers For Clean and Safe Vehicles' Co-Director
In January and February 2003, the National Highway Transportation Safety Administration (NHTSA) held a public comment period on its proposal to increase Corporate Average Fuel Efficiency standards by 0.5 mpg per year for two years. Thousands of public comments, including several by Don't Be Fueled! supporters, were submitted urging NHTSA to do more. Detroit opposed even this small increase, claiming as usual that a CAFE increase would result in economic harm and job losses. Ford Motor Corp. submitted a 100-page objection. NHTSA's final rule, published in April, was in synch with the proposed rule.
Lynn Fuller's comment is published below.
February 9, 2003
Administrator Dr. Jeffrey Runge
National Highway Traffic Safety Administration
Docket Operations/Docket 11419
400 7th Street SW
Box #PL401
Washington, DC 20590
Re: Light Truck Average Fuel Economy Standards Model Years 2005-07/
Docket No. 2002-11419
Dear Dr. Runge,
I am the full-time mother of four children. I live in San Francisco, California. My family owns two vehicles: a 1997 Chevrolet Suburban and a 2002 Toyota Prius. I have reviewed NHTSA's proposed rule regarding light truck fuel economy standards for Model Years 2005 07 and I submit this formal comment. I bring to this comment a mother's special concern for the future consequences of this rule what it will mean for the America our children will inherit.
The proposed rule recommends increasing the CAFE standard for light trucks from 20.7 mpg currently to 21.0 mpg for MY 2005, 21.6 mpg for MY 2006 and 22.2 mpg for MY 2007. The proposed rule suggests that NHTSA might even set the final fuel economy standards for these model years lower than those proposed.
It is in our nation's best interest to decrease our overall consumption of petroleum as vehicle fuel for a number of reasons, of which I will list four:
• The refining and distribution of petroleum as fuel is the leading source of toxic, especially cancer-causing air pollution in urban areas.
• Vehicle emissions pollute the air everywhere vehicles go, which is almost everywhere. This is especially true of light trucks, which are allowed to emit up to 5.5 times the ozone-precursor pollutants that passenger cars are allowed to emit. Despite three decades of efforts to clean up the air, California now has six of the ten most ozone-polluted counties in the nation, and most of this pollution is from vehicles. Asthma is nearly epidemic in these and other California counties. Emissions-control equipment can only do so much. The most direct way to reduce pollution from vehicles is to reduce the amount of fuel they consume. California's clean air program is hamstrung by the states' inability to regulate fuel economy, which is reserved by law to the federal government.
• Global warming. Corporate and governmental denials and related spin campaigns have failed to undermine the growing body of credible scientific evidence that human activities are increasing the earth's atmospheric temperatures and have already warmed the oceans, with potentially drastic and inherently unforeseeable consequences for future generations.
• National security. The United States possesses about two percent of the world's oil reserves and consumes 25% of the world's petroleum output; meanwhile, 60-70% of the world's oil is in the Middle East. Unless America reduces its consumption of petroleum drastically in the years to come, my children and grandchildren can look forward to endless diplomatic compromises and/or military adventures to ensure America's continued access to oil fields controlled by some of the world's most anti-democratic, retrogressive and unsavory regimes.
Instead of reducing our consumption of petroleum, however, America has been consuming more and more fuel, especially in the last ten years. The rapid proliferation of SUVs and other light trucks on our roads is a big part of the reason for this, because NHTSA has allowed light trucks to be held to a lower fuel economy standard than cars, and has failed to increase the fuel economy standard for either cars or trucks for at least a decade. Meanwhile, the number of vehicle miles traveled in the country nearly doubled during the same period and gas-guzzling light trucks were taking over the passenger vehicle market.
None of the Detroit auto manufacturers have ever exceeded the CAFE standards (while the Japanese have consistently done so by wide margins). In the unfortunate culture that prevails in Detroit, CAFE is a ceiling, not a floor. A mandatory light truck CAFE standard that rapidly closes the fuel-economy gap between cars and light trucks therefore seems imperative if there is to be any progress toward reducing America's consumption of petroleum. This proposed rule does not give America that standard. It is too little, too late. It will allow millions and millions more gas-guzzling light trucks onto our roads, each of which has a lifespan of at least fifteen years. The proposed rule fails to address the urgent energy-conservation needs of our nation, but merely caters to the short-term interests of the automobile industry which unfortunately are exactly opposite to America's best interests. This rule will continue to allow major increases in our nation's consumption of petroleum, and our air quality, our children's health, our climate and our national security will suffer.
The proposed rule discusses at length the technological feasibility of improving fuel economy in light trucks. I own both an old-fashioned gas-guzzler of the kind the proposed rule favors (the Chevy Suburban) and the kind of vehicle this rule should be promoting, but isn't (the Toyota Prius). At the University of California, Davis, researchers produced a 40 mpg Suburban using hybrid technology. NHTSA should be pushing the reluctant auto industry down this road. But hybrid technology is not the only method of improving fuel economy. The auto makers have a whole bag of tricks they could use to double fuel economy almost overnight such as:
Unfortunately, the Detroit auto manufacturers are unwilling to employ these technologies for the benefit of the consumer to improve fuel economy voluntarily. The fuel economy problem is not technological; it is political.
This weak proposed rule is part of the continuing story of the excessive political influence the Detroit auto manufacturers enjoy in Washington, and of how little concern Washington has for America's genuine best interests. The proposed rule contains the following sentence: "NHTSA estimates the average incremental cost per vehicle needed to meet the proposed standards to be $14 for MY 2005, $28 for MY 2006, and $47 for MY 2007." This rule is apparently designed to make sure that Detroit spends no more than a pittance on fuel economy for the next three years, and Americans get no benefit at all as consumers or as citizens. I paid thousands more for my Prius because I wanted a vehicle that would not compromise America's security and the health of our children and the environment. Let the auto manufacturers pay more than $50 per vehicle to make America safer, healthier and more secure. Let them pay whatever it costs it will scarcely dent the handsome profits they enjoy from light truck sales.
Given the serious air-quality, climate and national security interests at stake, the proposed rule is too little, too late and should be scrapped. Instead, I and countless other Americans would like to see a proposed rule that closes the fuel-economy gap between cars and light trucks within five years an increase of something like 2 mpg per year. At the same time, CAFE standards should be steadily increased for both cars and trucks. The politically-motivated stagnation in fuel economy standards that has prevailed for fifteen years is a national disgrace that has endangered Americans and jeopardized its children's future. What a shame it is that NHTSA stands poised to squander this opportunity to end this sorry chapter in America's public life.
Yours sincerely,
Lynn D. Fuller
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