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NHTSA Releases Final EIS on New Fuel Economy Rules With Alternative Scenarios; Most Aggressive Reaches 42 MPG by 2015

The NHTSA FEIS concludes that the most extreme technology scenarios combined with higher economic inputs could deliver or beat the 2020 CAFE target by 2015. Click to enlarge.

The National Highway Traffic Safety Administration (NHTSA) has released the final environmental impact statement (FEIS) on the new CAFE rules for light-duty vehicles from model years 2011 to 2015. This period represents the first stage of a series of CAFE increases that are to result in a minimum new vehicle fleet average of 35 mpg by 2020.

Under Council on Environmental Quality (CEQ) National Environmental Policy Act (NEPA) regulations, NHTSA must compare the potential environmental impacts of its proposed action and a reasonable range of alternatives. In fulfillment of this requirement, NHTSA analyzed the impacts of six “action” alternatives and the impacts that would be expected if NHTSA imposed no new requirements (the No Action Alternative).

In April, NHTSA issued a Notice of Proposed Rulemaking for new vehicle fuel economy standards that would bring the US average to about 31.6 miles per gallon in 2015 (35.7 mpg cars, 28.6 mpg trucks). (Earlier post.) Under the Energy Independence and Security Act of 2007 (EISA), NHTSA, the agency that “owns” fuel economy regulations, can establish standards for a maximum of five model years at one time. Hence, the initial proposed rulemaking covers model years 2011-2015.

In response to criticisms of the draft EIS released earlier this year (which also worked with the seven alternatives), the FEIS examines how the alternatives are affected by variations in the economic assumptions input to the computer model NHTSA uses to calculate the costs and benefits of various CAFE standards (the Volpe model)—e.g., a higher fuel price ($3.33/gallon in the high scenario, compared to $2.41 in the reference case), and a higher global price on carbon of $33 per tonne.

The alternatives, run with both reference case and higher input scenarios, in order of increasing stringency, are:

  • No action. The No Action Alternative assumes that average fuel economy levels in the absence of CAFE standards beyond 2010 would equal the higher of a manufacturer’s product plans or the manufacturer’s required level of average fuel economy for MY 2010.

  • 25% below optimized. Combined industry-wide average fuel economy for all passenger cars and light trucks would range from 29.4 mpg for the Reference Case to 32.9 for the High Scenario.

  • Optimized: NHTSA’s preferred alternative, this is the level at which marginal costs equal marginal benefits. In MY 2015, the combined industry-wide average fuel economy for all passenger cars and light trucks would range from 29.6 mpg for the Reference Case to 33.6 for the High Scenario.

  • 25% above optimized. In MY 2015, the combined industry-wide average fuel economy for all passenger cars and light trucks would range from 29.8 mpg for the Reference Case to 34.2 for the High Scenario.

  • 50% above optimized. In MY 2015, the combined industry-wide average fuel economy for all passenger cars and light trucks would range from 30.0 mpg for the Reference Case to 34.8 for the High Scenario.

  • Total costs equals total benefits. This alternative requires manufacturers to apply technologies until total costs equal total benefits, yielding zero net benefits. In MY 2015, the combined industry-wide average fuel economy for all passenger cars and light trucks would range from 30.4 mpg for the Reference Case to 36.0 for the High Scenario.

  • Technology exhaustion. The most stringent, this alternative represents the level at which vehicle manufacturers apply all feasible technologies, while recognizing that some must still be installed as part of a vehicle freshening or redesign. Alternative 7 would yield negative net benefits, according to NHTSA’s analysis.

    NHTSA developed the Technology Exhaustion Alternative by progressively increasing the stringency of the standard in each model year until every manufacturer (among those without a history of paying civil penalties) exhausted technologies estimated to be available during MY 2011-2015. The combined industry-wide average fuel economy for all passenger cars and light trucks would be 42.0 mpg in MY 2015 under all input scenarios.

Thirty days after the EPA publishes a notice of availability of this FEIS in the Federal Register, NHTSA will publish a final CAFE rule.




"This period represents the first stage of a series of CAFE increases that are to result in a minimum new vehicle fleet average of 35 mpg by 2020."

We're going all DIESEL!


"35 mpg by 2020" is an effing joke. The minimum should be at least 35mpg by 2015.


"We're going all DIESEL"

Will never happen, California CARB will never allow that to happen.

John Taylor

This is a joke right?

The only question should be ... how soon can Battery Electric Cars become a marketed commodity.


The only question that remains is: who listens to peak oil'ers when oil is going towards $ 50 per barrel?

stas peterson

The nouveau-religious, intolerant Greens and assorted true believers insist on pushing the state of the art, at unrealistic paces, for largely symbolic improvements.

At the last minute after months of legislative debates, about four hours before final vote, the crazies, increase the limits in legislation from all autos meeting 35 mpg to all vehicles, including trucks, meeting 35 mpg, by 2020.

They do this with no concern to the laws of physics or reality or reasonableness.

Then the yahoos decide they don't have to wait; they don't have to pay for the investments, they demanded the automakers do it, "for free".

After all the evil, capitalist, automakers have infinite resources to do what the ambitious schedule demands, if they only open their vast hoards of money; so bleed them even some more.

So the co-religionists esconsced in the EPA bureaucracy, insist that the schedule be accelerated even more, from 2020 that Congress set, to 2011 or a few years later by decree. They even dream up some mumbo-jumbo to show the mythical benefits are great.

The automotive industry Goose that has always laid the golden eggs, is sickly. No matter, install the even quicker, even tougher, mandates.

The Golden Goose dies, and the Greenie yahoos and know-nothing bureaucrats immediately say, we didn't do it. Besides it serves them right. We'll just have to raise some more taxes because the industry that used to pay them, doesn't exist any more.

Yes that is the way things have worked since the seventies. Then "Big Law" tort lawyers will be glad to sue to pick over the automotive industry carcass, for fines and compensation for the remnants of the business, that used to provide livelihoods for millions, not meeting the arbitrary mandates.

It's the American way.

Will S

Stas, you crack me up! You do stand-up on the side, eh?

>The automotive industry Goose that has always laid the golden eggs, is sickly.

Gagging on their own poison.

The Prius gets 48 mpg. The Escape Hybrid SUV gets 35 mpg. The mark is easy to hit, it's just that the Big 3 (Big 2?) want to continue pushing oversize vehicles. When the Aptera, Loremo, and VW 1-liter come out (getting 130, 157, and 235 mpg respectively), will the Big 2 will still be trying to make a losing business model work? Trucks have to become a very small piece of the pie, and the sooner they learn that and change their business model, the better the chance they have of staying in the market.

stas peterson

GM and Ford produce lots of pregnant roller skates in Europe and around the world. They just haven't brought them here, or emphasized the ones the have. There are a few "B" class autos offered by the Japanese here, Yaris and Fit but collectively they don't add up to 100,000 sales total. GM already brings the obsolescent Suziki "B" class Aveo here, and Ford will begin building the new generation Fiesta here next year, too.

Every automaker in the North American market is bleeding badly. And that includes Toyota, Honda and especially Nissan. Toyota is abandoning their extensive plans for the Tundra. Nissan has completely given up on building trucks for NA, and is contracting that out to Chrysler. Honda may kill the Ridgeline, its tepid entry into trucking.

As regards your ridiculous gullibility, and love of press releases from tiny companies that hope to build a few crude concepts, someday. Most have poorer "mass manufacture" backgrounds than mighty and always loved Tesla. Three years into "mass production", Tesla just congratulated itself on producing it 9th car. Chuckle, Chuckle. Next year they will get to double digits. Maybe even #10, or #11. I'd recommend that you buy a "sub-A" class "Peapod". At least Chrysler has sold 30,000 of them around the world.

Meanwhile the crazies are just waiting to accelerate the 2020 CAFE to 2011-2014; CARB is aching to impose CO2 impossible limits in 2011, and other assorted crazies have other ideas too. NHTSA has a bunch of new safety measures that it wants yesterday, all nice to have certainly, but all add to weight and subtract from mileage. All will take engineering talent and attention away from the industry's decision to build electric vehicles that customers are demanding.

Hold on, why would safety measures increase the weight of a car. Last I heard Mazda designers managed to shed over 200kg from the new 2 in order to increase its safety. Not only will it change direction quicker and prevent an accident in the first place but even if it does there's less momentum hurling you into that wall. Crash safety cells and crumple zones as well as EBD electronics and pre-tensioned seatbelts and airbags save lives, not lobbing a couple pieces of lead in the car and hoping for the best.

Cars are not light nowadays anyway, they are no more light cars that exist, but at least it may have plateau'd now.

Roger Pham

I do share your sentiment regarding gov.'s over regulation and red tapes in certain sectors, thus stiffling the economy. Yet, in other sectors, lack of regulation or oversight, or deregulation, can lead to instability and economic collapse.

Now is the time to move away from the laissez-faire economic model and embrace the government-managed economy model like that of Japan, Inc. and other East Asian industrial powerhouses in the last several decades.
The government will target certain industries as being vital for the health of the nation and therefore "untouchable", like the auto industry, which must be protected at all cost. Other emergent future industry like the "green" fossil-fuel-replacing technologies should be pushed by the government so that the USA will remain competitive as an industrial powerhouse well thru the 21st century, instead of wholesale surrendering of our industrial & manufacturing base to the Far East.

High-efficiency automobile technology will be the key to the survival of the American auto industry, and must be pushed by the government at all cost!!! PNGV was a start, but more pushing and mandates with firm, non-negotiable benchmarks, goals and time table must be legislated in order to save the American auto industry. They have been given a free reign to produce gas-guzzling behemoths for too long and to their detriment.

We need good and strong government that is not afraid to lead America toward a properous industrial and green future.


Those South east asian economies push coal, not green taxations. Go to Hong Kong and Guangzhou please, before you say wrong statements. And guess what : they are getting richer and richer.

Roger Pham

Your observation is spot on. That's why America must lead the world with a green agenda to grow our economy and empower our future the right way, instead of follow their path of environmental destruction. America must still be the beacon of hope and righteousness for the rest of the world to follow. It can be done. Just need good leadership and vision.


Euh I didn't say that.


Clearly you don't know any Chinese. I don't speak cantonese eather, but I have talked tho Chinese people in the Canton/Guandong province (some speak English). Their economic vision is clear: lower taxes, very cheap labour (ridiculously cheap), no environmental laws at all. And they are proud about their economic rise. They even asked me: "Are you gonna learn Mandarin?" A Chinese will never understand there are Sierra Club lawyers in the US that block economic progress. I know his/her answer already : "But it discourages people to invest in industries, why you have this system? Why don't you change the system?" The same with pesticides. The same with all the rest.

Will S

And they are gagging on their pollution and teetering on recession. Making a quick buck the dirty was one way we got ourselves into this mess. Look at their polluted rivers, their eroding clearcut hills, the air that you can almost feel lumps in. Then tell me that's the way you want your children to live...

Roger Pham

Western Europe and the USA have learned the hard way since the dawn of industrial age about the harmful effects of industrial pollution and the effect of capitalist exploitation of the workers. Before 1929, immigrants arrived at New York Harbor by the boatloads to work in sweat shops and dangerous factories. They worked 14-16 hr-day without OSHA standard, without injury benefits, since they are easily replaceable. The government was controlled by the Robber Barrons of the time and could not care less about the plight of the little people. There were over-production of goods due to over-investment since labor was so cheap, but, since the people worked so hard and were paid so little, they cannot afford the products they made. So, came the big depression and deflation. Prices dropped and all investments were lost, all banks failed...

Laws were made to protect the environment and the workers and the economy and the banking system. FDR had the New Deal to put people to work by building our great (once great!) infrastructure..until disrupted by the capitalists recently with nothing but dollar signs in their head.

Sound familiar today? Except that the East Asians are still subsidizing the trade deficits so that the consuming West can still buy their products and averting the looming great deflation...but the situation is not sustainable...


You didn't mention how much environmental restrictions cost to our economy, and give away to the Chinese. So if you sell a good to say Brasil: who will they pick? The super effective high yield pesticide from China or something (there is no technologial green revolution...never has been) "new to replace it, that in fact gives less yield" from the West? They pick the Chinese one.

Roger Pham

Establish free-trading blocks of countries with similar environmental standards, labor laws etc...while impose tariff to countries with lax EPA and labor and OSHA regulations in order to remove their unfair trade advantage, thereby protecting our vital industries and our technological base.

If Brazil has lax environmental laws, then don't expect to export stuffs to them, nor to trade much with them. However, our farmers are highly subsidized anyway, and with our highly mechanized highly productive farming practice, our farm products will remain highly competitive world-wide.

EPA and labor laws must be cost-effective by using the most efficient methods for environmental protection in order to cause undue economic trade disadvantage. Smart engineering practice can result in low pollution yet still maintain high productivity. If all workers drive to work with 55-mpg cars, then our economy can produce goods using much less petroleum consumption than if they drive F-150 pick-up trucks or Tahoe SUV's!
Encouraging car pooling to work and proper zoning to prevent urban sprawl will result in a much more cost-competitive work force while preserving the environment and reduction of pollution at the same time!


"There are a few "B" class autos offered by the Japanese here, Yaris and Fit but collectively they don't add up to 100,000 sales total. GM already brings the obsolescent Suziki "B" class Aveo here..."

The Yaris alone will sell around 120k in the US this year. The Fit will end up around 85k.

The Aveo is designed and manufactured by Daewoo. It is only sold as a Suzuki in the Canadian market.

Thank you for your correction on "B" class sales, in this year's crazy marketplace, where mileage is king. But even in this reduced market, and despite the large increase in sales of tiny cars, that number represents but 1.3% of the reduced market.

I stand by the comment that comaparatively few "B" class cars are sold in North America.

Besides that market window is fleeting, and going away, as we speak. When there was little other ways to get better oil consumption; then extreme down-sizing was what was done.

The Prius is a mid-size auto and gets better mileage than any of the "B" segment pregnant roller skates. It, and its copycats, which are coming in a flood, and even surpassing it, with such as the Volt, will sound the death knell for these vehicles within a decade or less.


Safety equipment has run up the weight of a midsize car from under 3000 pounds to almost 4000 pounds in the last thirty years, despite every attempt to pare weight. All the things you speak of have already been implemented and I'm not questioning their efficacy or worth. I'm merely pointing out the reality of conflicting aims.

In fact I can think of little safety equipment that was detrimental except for Ralph Nader's "Killer Special" airbag design. He refused to listen to the SAE and the automotive safety engineers about inflation charateristics of air bags. He was a lawyer but untrained engineer and he just knew better. Overpowered airbags would make up for people not buckling their seatbelts.

They warned him over ansd over to no avail, and he used his political influence with Carter's dingbat NHTSA fool, to mandate the overpowered air bag expanders. One SAE safety engineer was so thoroughly vilified in Congressional testimony, and descrtibed as in league with the devil, that he was driven to commit suicide.

Well, as predicted, people sitting too close too close to the the over powered aitbags were killed. Several hundred little old ladies and kids. That happened before the automakers were alowed to pull the overpowered air bag bombs from the US airbags and insert the proper inflators they used in all all their models sold overseas.

In a just world, Ralph Nader should have been sued for deadly hubris and for practicing engineering without a license, and stripped of every nickel he ever had. But "Big Law" ambulance chasers protect their own. He was never even named is a single lawsuit by the estates of the deceased people that that he killed with his stubborn jug-headed pride. To this day he remains a hero to many, despite his spree of killing several hundred to no good purpose.

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