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Fuel Economy Improvements Model

A UCS letter to the National Highway Traffic Safety Administration

The following is a letter to the National Highway Traffic Safety Administration (NHTSA) regarding UCS modeling on the feasibility of fuel economy improvements in the nation's auto fleet.

April 20, 2005

National Highway Traffic Safety Administration
400 Seventh Street, SW
Washington DC, 20590

Attn: Julie Abraham and Peter Feather

We are writing to follow up on our March discussion regarding analysis of the stringency of fuel economy standards for non-passenger automobiles.  This analysis supercedes the preliminary work we discussed with you.

Attached you will find a memo providing a conservative assessment of non-passenger automobile fuel economy standards for future years.  You will also find an attempt to recreate what may have gone into NHTSA's analysis of fuel economy potential.   Our analysis is based on conventional technologies and their associated fuel economy potential as presented in two different reports (one by us and one by the National Research Council/National Academy of Sciences1).  Our findings are as follows:

• UCS modeling indicates that a 40-mpg fleet of cars and trucks is feasible within 10 years, and that non-passenger automobiles could reach at least 34.8 mpg by Model Year (MY) 2014 using conventional technologies.  A MY2010 standard of 27.6 mpg would be practical, appropriate, and in line with this potential.  These vehicles would have the same or better acceleration performance than the vast majority of cars and trucks on the road today.  They would also have equal or superior safety performance, and would more than pay for themselves, saving the owners a net of more than $2,000 over the life of the vehicle.
• UCS also performed a conservative analysis relying on technologies and associated fuel economy improvements identified by the National Academy of Sciences (NAS) as "production-intent" or technically feasible for introduction within 10 years of the 2001 NAS analysis (NAS Path 2).  This analysis accounts for increases in weight, size and acceleration performance over the last few years.  The analysis indicates that non-passenger automobiles could reach 27.8 mpg by MY2014 while maintaining acceleration performance and safety, and saving consumers thousands of dollars on gasoline.  A fuel economy standard of 24.6 mpg for MY2010 would be in line with this assessment.
• Four years have passed since the NAS work was performed, therefore an analysis of the NAS technologies should also include the potential for components identified as "emerging" or technically feasible for introduction within 10-15 years of the 2001 NAS analysis (NAS Path 3).  A conservative UCS analysis of these technologies indicates that non-passenger automobiles could reach 29.5 mpg by MY2014 while maintaining existing acceleration performance and safety, and saving consumers thousands of dollars.  A fuel economy standard of 25.3 mpg for MY2010 would be in line with this assessment.
• In light of the weaker assumptions we had to use in our attempt to recreate NHTSA's past analysis, we recommend that those or any similar assumptions not be used in your assessment.

Given the current consumer burden of increasing gasoline prices, the national burden of oil dependence and NHTSA's obligation to set fuel economy standards to the maximum feasible level, accounting for "technological feasibility, economic practicality… and the need of the United States to conserve energy," we recommend that NHTSA set non-passenger automobile standards to 24, 25.8, and 27.6 mpg in MY2008, MY2009, and MY2010, respectively.

If, instead of relying on our assessment, NHTSA focuses on the NAS report, we recommend that NHTSA take into consideration our analysis of the NAS technology results.  We also recommend that NHTSA account for the fact that the Chair of the NAS panel, Paul Portney, recently testified before the House Science Committee that the panel may have been too conservative in its assessment, especially because it overlooked the potential of hybrid electric and diesel technologies to improve fuel economy.2  Allowing for the potential of hybrids and diesels would push the MY2014 maximum feasible fuel economy significantly higher than our analysis here.

We look forward to talking further with you about these issues and are available to discuss our analysis in detail.

Regards,
David Friedman and Don MacKenzie 

Notes:
[1] Monahan, Patricia and Friedman, David.  The Diesel Dilemma: Diesel's Role in the Race for Clean Cars. Union of Concerned Scientists, 2004; National Research Council.  Effectiveness and Impact of Corporate Average Fuel Economy (CAFE) Standards.  National Academy Press, 2002.
[2] Portney, Paul R. Statement before the House Science Committee, February 9, 2005.