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September 8, 2005
Docket Management Facility
U.S. Department of Transportation
400 Seventh Street, S.W.
Nassif Building, Room PL-401
Washington, D.C. 20590-001
Via: http://dms.dot.gov
to the U.S. Department of Transportation
National Highway Traffic Safety Administration
In response to Notice of Proposed Rulemaking
49 C.F.R. Part 523, 533, and 537
Docket Number 2005-22223
RIN 2127-AJ61
Average Fuel Economy Standards for Light Trucks
Introduction
Consumers Union (CU), publisher of Consumer Reports Magazine, submits the attached documents to inform the agency of its recently completed analysis of vehicle fuel economy. Attached is: (1) A report entitled, “An In-Depth Comparison of Consumers Union’s Passenger Vehicle Average MPG Estimates With Those Published by EPA and NHTSA” (August 11, 2005); and (2) “Fuel Economy, Why you’re not getting the MPG you Expect” (Consumer Reports, October 2005), based in part, on the above report.
Key Findings of August 11, 2005 Study
In a study of 303 cars and trucks, model years 2000 to 2006, Consumer Reports testing revealed that shortfalls in overall mpg occurred in 274 vehicles. According to these numbers, 90 percent of the cars we tested appear to have EPA stickers that over promise fuel economy. The largest discrepancies involved city driving, with some models falling short of claimed mpg by 35 to 50 percent. Our review found that EPA ratings were inaccurate, and concluded, in part, that EPA testing procedures do not accurately reflect today’s consumer driving habits. In addition, the study finds that the EPA’s “adjusted numbers,” while inaccurate, were more accurate than Congressionally mandated unadjusted EPA numbers used by NHTSA for CAFE purposes.
Urgent Need for reform of CAFE Standard
According to the results of the Consumer Reports study, only one in ten of the vehicles consumers drive actually achieve fuel economies at or above that advertised on window-stickers. The vast majority of consumers therefore typically pay hundreds of dollars more per year to operate their vehicles than promised. This shortfall, coupled with daily increases in gas prices, is becoming an unsustainable burden for many consumers. The study findings also indicate that car makers fail to meet CAFE levels because of the EPA’s unrealistic data and NHTSA’s inappropriate methods of calculation. We believe that if more accurate mpg figures were used by NHTSA to rate CAFE compliance, most automakers likely would fail to meet the standards.
CU currently is reviewing NHTSA’s Notice of Proposed Rulemaking to reform CAFE, NHTSA Docket No. 2005-22223, 70 Fed. Reg. 52413 (August 30, 2005). “Light Trucks, Average Fuel Economy; Model Years 2008-2011.” Upon completion of our analysis, we may elect to provide additional technical comments during the comment period.
Respectfully submitted,
Janell Mayo Duncan
Legislative and Regulatory Counsel
Washington Office