Letter to House and Senate Calling for Greater Transparency for Heavy Duty Pickup Fuel Economy

September 20, 2017

Consumers Union, the policy and mobilization division of Consumer Reports, writes to urge you to authorize and appropriate additional funds to the National Highway Traffic Safety Administration (NHTSA) and the Environmental Protection Agency (EPA) to make fuel economy, emissions, and fuel cost information publicly available for heavy-duty pickup trucks.

Based on new data from testing at Consumer Reports,^[1] these heavy-duty diesel pickups cost about $35,000 to fuel over the first 15 years of the vehicles’ lives.^[2] Further, they can cost $7,000 to $10,000 more to fuel than their light-duty gasoline counterparts over that same time.² Without information like this, consumers are powerless to make informed decisions when shopping for these vehicles for their businesses or family.

While new light-duty trucks and passenger vehicles carry window sticker labels that display important consumer information about the vehicle’s fuel economy, emissions, and expected average fuel costs, no such label is available for heavy-duty pickup trucks. Further, consumers can easily find light-duty vehicle fuel economy information online at fueleconomy.gov thanks to the public availability of the information. Easy access to information NHTSA and EPA already have for heavy-duty pickups would empower consumers to consider the cost of fueling their vehicles alongside other attributes. It would also encourage competition on fuel economy among automakers.

When I was the Deputy and Acting Administrator of NHTSA, I recognized the value of public fuel economy information and the benefits it would provide in the heavy-duty truck market, which covers annual sales of hundreds of thousands of vehicles. However, when we were looking to fulfill NHTSA and EPA’s intention to consider consumer information as we developed the next round of standards,^[3] there was insufficient funding at the agency to dedicate the staff and resources needed.^[4]

As NHTSA continues to work on fuel economy standards for light-duty vehicles for MY 2022-2025, which are very important to consumers,^[5] resources for expanding public availability of the data likely remain tight. We therefore encourage the authorizing and appropriating committees to dedicate sufficient new funding to NHTSA and EPA programs with the express purpose of making fuel economy information for heavy-duty pickup trucks publically available and more accurate, first through fueleconomy.gov and then through a label affixed to the window. Thank you for your consideration.

Sincerely,

David Friedman,

Director of Cars and Product Policy and Analysis

Consumers Union

202-462-6262

cc:

Members of the U.S. House Committee on Appropriations

Members of the U.S. House Energy and Commerce Committee

Members of the U.S. House Transportation and Infrastruture Committee

Attachment A: Fuel Economy Results and Fuel Cost Estimates

Based on Consumer Reports’ Testing Data

^[1] Consumer Reports. Heavy Duty Pickup Truck Fuel Economy Numbers You Can’t Find Anywhere Else. September 20, 2017. Available at: https://www.consumerreports.org/pickup-trucks/heavy-duty-pickup-truck-fuel-economy/

^[2] See Attachment A for details and methodology.

^[3] As stated in the 2011 rulemaking establishing the first-ever fuel efficiency and greenhouse gas standards for medium- and heavy-duty vehicles. Federal Register, Vol. 76 Thursday,

No. 179, September 15, 2011.

^[4] While the 2011 Senate Appropriations report directed the Department of Transportation to prioritize a rulemaking for heavy-duty pickup fuel economy labels, additional funds were not provided to do so. Senate Report 112–83 for “Transportation and Housing and Urban Development, and Related Agencies Appropriations Bill, 2012,” September 21, 2011, at 63, accessed at https://www.congress.gov/112/crpt/srpt83/CRPT-112srpt83.pdf on September 18, 2017.

^[5] Consumer Reports’ June 2017 public survey show that 73% of the American public support the U.S. government setting strong fuel economy standards and enforcing them.

^[6] Consumer Reports performs its own fuel-economy tests, independent of the government’s often-quoted EPA figures and the manufacturers’ claims. Using a precise fuel-flow measuring device spliced into the fuel line, Consumer Reports tests run on two separate circuits. One is on a public highway at a steady 65 mph. That course is run in both directions to counteract any terrain and wind effects. A second is a simulated urban/suburban-driving test done at the Consumer Reports auto test track. It consists of predetermined acceleration, and deceleration rates, as well as idle time. Consumer Reports’ overall fuel-economy numbers are derived from those fuel consumption tests. More information about Consumer Reports testing can be found at: cr.org/autotest.

^[7] Assuming $2.50 per gallon of diesel and $2.40 per gallon of regular unleaded gasoline.

^[8] Assuming nearly 174,000 miles over the first 15 years of ownership, based on vehicle miles traveled data from Figure VI-6 in Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles—Phase 2, published in Federal Register Vol. 81, No. 206, Tuesday, October 25, 2016, Page 73764. Assumes a 3% real discount rate consistent with a 5% new car loan and 2% inflation. Diesel and gasoline prices based on EIA’s Annual Energy Outlook available at https://www.eia.gov/outlooks/aeo/ as of 9/18/2017 (EIA forecasts that, over the next 15 years, diesel prices will vary from $2.90-$3.86 and gasoline prices will vary from $2.26-$3.11). Fuel expenses while towing or carrying a payload will likely be higher than indicated by CR’s tests, while the cost differential will vary depending on the vehicle.