Reforming the Automobile Fuel Economy Standards Program; (CAFE) Advance Notice of Proposed Rulemaking

Filed on regulations.gov — full text not in the inline record.

Overall, NRDC¿s comments are as follows: 1.NHTSA should not proceed further on the structural rulemaking without proposing actual standards. This is required to make any changes transparent and to fulfill the agency¿s basic obligations under the Energy Policy and Conservation Act. Anything else denies the public the opportunity to comment meaningfully on the rulemaking and avoids NHTSA¿s statutory duty to set fuel economy standards at the maximum feasible level. 2.The Energy Policy and Conservation Act requires NHTSA to set maximum feasible fuel economy standards. NHTSA must not ignore this obligation. NHTSA must act now to address America¿s growing oil dependence by making progress towards increasing combined passenger car and light truck fuel economy to 40 miles per gallon within a decade, which is technically feasible and economically practicable. 3.Increasing vehicle fuel economy can be undertaken while improving vehicle safety, U.S. manufacturing employment, and consumer choice. 4.Vehicle safety is an important consideration in and of itself. NHTSA should use its legal authority to improve vehicle safety standards and address important public safety considerations. 5.NHTSA¿s reliance on studies that relate increased safety to increased vehicle weight is inappropriate in light of the serious flaws in those studies. A large body of evidence suggests that other factors besides vehicle weight have critical implications for vehicle safety. NHTSA should remedy its failure to incorporate the findings of studies that address the critical role played by factors such as design and size in vehicle safety. (These studies have been submitted to the Administration in response to previous requests for public comment.) 6.If NHTSA chooses to go forward with a proposal for structural changes, at the very minimum they must be accompanied by a mechanism to guarantee that NHTSA will not worsen the status quo on fleet fuel economy. NHTSA should require automakers to continue to meet the existing light truck standard or any later increased standard as a backstop to protect against any erosion of the truck fleet fuel economy resulting from any modifications. Further, any set of standards should incorporate an automatic adjustment mechanism to ensure that projected fleetwide fuel economy increases are realized. 7.Weight-based standards should not be used as the foundation for reforming CAFE standards. Weight-based standards can create incentives to add weight or sell more heavy vehicles, resulting in lower fuel economy and increased oil dependence. Moreover, weight-based standards may reduce or eliminate incentives to use cost-effective technologies, such as high-strength steel, aluminum and other materials, to increase fuel economy in heavy vehicles. 8.NHTSA should change the current vehicle class definitions to prevent manufacturers from classifying vehicles clearly being used primarily for passenger transport as ¿light trucks,¿ including crossover vehicles, SUVs, and minivans. The simplest such system would require the combined fleet of vehicles under 10,000 pounds gross vehicle weight to meet a single fleet average standard. NHTSA should modify the CAFE program to include all vehicles with a gross vehicle weight rating between 8,500 and 10,000 pounds. Including these vehicles while maintaining existing performance is feasible and compelling on the basis of energy conservation and reduced fuel costs for users of such vehicles, including farmers and small businesses.