New "Light Truck" Gas Mileage Rules Reason to Celebrate "Liberally."
On March 29th, 2006, the National Highway Traffic Safety Administration (NHTSA) threw us liberal "energy hawks" a big ol bone. In a headline that should have started "Hell freezes over..." The trade rag Automotive News reported "24mpg CAFE standard for light trucks adopted." Hallelujah and Huzza! George Bush is making trucks thrifty? Yes. How about three cheers for W? Hip hip wait this is C.A.F.E. well have 1.2 cheers for MY 2009, 1.8 for MY 2010, and 2.4 for MY 2011. In fact, the best way to characterize the new NHTSA rule change is to say, the glass isnt just half full, its 0.625 full depending on how you drive of course. Yet its the revolutionary new way NHTSA is formulating truck gas mileage rules that is even better news. The changes dont go far enough, but as Garrison Keillor would say, It could have been worse. While summing up the 371 page NHTSA directive in a single blog entry is literally impossible, suffice it to say that up till now, there was one fixed number that applied to the fleet average of every maker. It was based on the least capable makers ability to conform. In most cases it was G.M., because it had sold the most big trucks. Makers like Honda and Toyota, who made more small trucks cleaned up on CAFÉ credits by exceeding average fleet gas mileage standards then they could apply the credits to future model years.
Now that both Toyota and Nissan are jumping into the V8 SUV and pickup market with both feet, NHTSAs report says in front of God and everybody that GM and Ford were trembling in fear that Toyota would be able to sell fuel swilling pickups with no C.A.F.E. fines piling up at the end of the year. Even though GM leads in full size fuel economy (little known fact: Chevys Silverado V8 pickup is a bit thriftier than Toyotas Tundra V8 pickup, despite having more horsepower) Chevy might accrue fines due to the sheer volume of big trucks it sells. On the other hand Toyota has both credits built up from years they didnt sell a V8 truck, plus credits on a current year basis from such popular economy soft roaders as the 4cylinder RAV 4.
With the continuous sizing system derived from the totally new NHTSA bracketed logistic gas mileage/size ratio curve, all makers will have to make yearly improvements in light truck fuel economy. The system uses a new metric called footprint. Measured out in good old American square feet, the footprint is the wheelbase multiplied by the tread width. For a big honkin SUV like the Lincoln Navigator, it works out to 55.4 square feet, while the compact Ford Escape is a mere 43.5. Yet even this size-centric curve is an improvement on what could have been. In August 2005 NHTSA proposed six new size categories. The sticky wicket inherent in categories is obvious. Makers could simply expand the track or wheelbase of certain models that were right on the border of each category, in order to shove them into a higher size class. So the first could have been worse good news is that NHTSA instead developed a continuous curve rather than stepped categories to prevent makers from gaming the system. In fact the NHTSA report also states that Toyota and my kindred spirits over at the Rocky Mountain Institute (RMI) successfully argued that further gaming would occur if truck characteristics like hauling or towing capability were used as additional rationales to water down economy standards (newly designated as targets). Chevy could just tack on a towing package to every mega SUV it sells, because it would be much cheaper than adding new fuel saving technology like 6 speed transmissions or hybrid drive-trains. Thanks to stormin Norman Manetas new continuous bracketed logistical size/mileage ratio curve, (just trips off the tongue doesnt it?) each maker will end up having its own precise target like 23.28 mpg instead of using a universal rounded number standard like 22.5mpg that applies to all. This new number is determined by calculating the harmonic average of all the makers vehicle mileage targets, weighted by the distribution of the makers production volumes among the foot print increments.
Yet I can just hear the Talking Points Memo cognoscenti screaming, their hands clenched with fists of rage because of, A: the favorable treatment toward domestic makers (Secretary Maneta is in GMs hip pocket!) and B: the new systems way of rewarding big SUVs and punishing small ones. Actually those two things are great for energy hawks. Why? Firstly, because the new continuous sizing system eliminates the heinous practice of producing ringer trucks based on compact car chassis to offset the Big Gulp mega SUVs. For example the Ford Escape will get a 2011 target mpg of 27.32 thats nearly the same as the passenger car standard of 27.5mpg. Its also a pretty big increase from the current models 24mpg 4 cylinder and 22mpg six cylinder average. Although domestic makes do get a break, remember that Toyota and Honda have been upsizing on a continuous basis for the past 25 years. Even Honda has a full sized pickup now. Under the unreformed system, there would have been nothing preventing Honda from introducing a 5mpg monster truck. This is because NHTSA couldnt levy CAFE fines due to these Japanese makers many accrued credits from past years. Another light truck ringer culprit is that darling of NPRs Car Talk tappet brothers, Subaru. They make a lot of station wagons, but because of a slightly higher ride height and that flat loading floor many of their relatively small cars only have to make the dismal light truck standard thats going to change for the better.
More could have been worse sentiment applies to the idea of enshrining footprint size in the system. Why? They could have enshrined weight instead. For more than a decade the auto lobby has hammered away on the idea that downsizing cars is akin to murdering people. When you know the history of the auto lobbys not so noble efforts to prevent seat belts and collapsible steering columns from being mandated in the 1960s, then their 1970s and 1980s recalcitrance against an air bag mandate, its easy to accuse the auto lobby of crying wolf. On the other hand, there is Newtonian physics to consider. 6000lbs worth of Chevy Suburban is going to play holy hell with a 2600lb Honda Civic. In fact, in crashes between light trucks and passenger cars 80% of fatalities occur in the poor saps in the car. There are extenuating circumstances mainly centering around disparate bumper heights, but hey, three tons is three tons. So if the weight difference is the problem, why not mandate lighter trucks? Well, the footprint metric could do that. Thanks to the fine efforts of the aluminum lobby in the new rules formulation, the biggest trucks could use more composite plastic, aluminum and, if Amory Lovins RMI gets its way, carbon fiber, to retain the same size yet decrease weight and thereby increase gas mileage and decrease the kinetic energy hazard to lighter cars. For safety hawks like Saint Joan Claybrook, NHTSA director under President Carter and now head of the consumer watchdog group Public Citizen, extra track width generates an acute case of the warm n fuzzies. This is because more track width (and wheelbase for that matter) makes the vehicle more stable and less likely to roll over. This is particularly important for high centered trucks, which have proven far more likely to succumb to fatal rollovers than low slung cars.
The half full news for the rationality of the auto market is that although there will be less regulatory incentive for makers to shift from passenger cars to light trucks, it remains true that simply by having a lower truck standard at all, the incentive isnt completely eliminated. Already 4200lb bruisers like the Dodge Magnum R/T (basically a station wagon) are classed as light trucks, and just this year Dodge has replaced its compact Neon sedan with the Magnums nom-de-firearm little brother crossover called the Caliber. The retention of the truck standard is particularly vexing when you look at the NHTSA document, because it spends so much time talking about how rollovers are terrible and heavy weight and wide track width is going to save you from harm. Yet NHTSA uses high ride to determine what a truck is. In reality commercial vehicles dont have to be high riding. In fact a low loading height would be ideal for something like a pickup. With respect to weight and how great the automakers say it is for saving precious lives, why cant cars have a little too? Particularly since much of the problem in head to head crashes can be attributed to weight difference, why isnt bringing truck weight down and maybe bringing car weight up not such a noble goal? This would be the effect of simply jettisoning the light truck category altogether and adopting a universal 27.5mpg standard. Even going by the NHTSA documents own logic, there is no reason this wonderful life saving weight should be defined as uniquely truck while cars are defined as light weight vehicles that kill you.
The new NHTSA light truck C.A.F.E. rule is indeed a major step in the right direction. Secretary Maneta deserves praise for improving the gas mileage of light trucks, and especially for revising the system to reduce gaming of it. He has restored some market rationality to the system and eliminated major incentives for ringer light trucks. However, the whole idea of a separate standard for trucks should be eliminated. While Maneta has carried us about 2/3rds of the way to restoring market rationality, the best thing to do is to simply merge the passenger car standard and the light truck standard together. Boost the light truck footprint mpg targets up to passenger car standards, and completely eliminate the truck category.




