Fuel Consumption


Agency Administrative Actions




Fuel Consumption

Prorating Fuel Consumption
Bill Shoots I, a Texas-based member of our Grassroots Network, has proposed an innovative approach to measuring fuel economy. Mr. Shoots has proposed that fuel economy measurement be based on "passenger miles and/or per unit time." Mr. Shoots' recommendation recognizes that understanding fuel economy means looking at more than just miles per gallon. The approach recommended by Mr. Shoots recognizes that not only do vehicles have different carrying capacities but also that a person's fuel consumption is highly dependent not just on the vehicle but on how much it is driven.

  • Click to read Prorating Fuel Consumption.

  • Now With More Facts Than Ever: Christina Marrs Responds to Gregory Hudgins and Ed White
    Christina Marrs, a member of both the Grassroots Network and the acclaimed music ensemble, The Asylum Street Spankers, provides an extensive and reasoned response to criticism of her previous discussion of SUVs. Ms. Marrs' detailed commentary discusses environmental, safety, fuel economy and sociological issues associated with sport utility vehicles. To ensure that Federal officials consider all substantive viewpoints as they deliberate CAFE Reform proposals, FuelEconomyIn.US will include the complete text of the Marrs-Hudgin/White debate as part of our response to NHTSA's Advance Notice of Proposed Rulemaking on reforming CAFE.

  • Click to read Christina Marrs' letter
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  • FuelEconomyIn.US Launches Stakeholder Dialog with NHTSA
    FuelEconomyIn.US is initiating a substantive dialog between our Grassroot Network members and NHTSA (the National Highway Traffic Safety Administration). We are asking our members to write us discussing the questions, comments and issues you want to raise with NHTSA regarding SUVs, pickup trucks, and minivans. We will provide the letters to federal officials and report back to you with their responses as well as our own analysis. We will also be making space available on our FuelEconomyIn.US for important safety messages from NHTSA.

    To encourage substantive discourse, $50 Amazon gift certificates will be awarded to the writers of the twenty best letters. You must be a registered member of our Grassroots Network to participate. All letters should be e-mailed to comments@FuelEconomyIn.US.

  • Click to read FuelEconomyIn.US letter to NHTSA
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  • The Minivan of Evil?
    If Albany's Times Union opposes consumers having the right to choose the minivan, pickup truck or sport utility vehicle that they believe best meets the needs of their family or business, the paper should at least be forthright enough to say so directly. Instead, in its recent editorial, “SUVs, still guzzling,” the paper attempts to hide its anti-consumer, anti-truck views. The editorial castigates, albeit inaccurately, SUVs but doesn't even mention other types of light trucks such as minivans or pickup trucks. Why? According to the most recent data on the federal government's website, there are 32 SUVs from seven different manufacturers that get better city gas mileage than the highest mileage minivan. There are also an additional 10 SUVs that match the highest city mileage minivan. This is not to say that minivans are not fuel efficient, simply that they serve certain specific consumer needs (transporting families, friends, pets, groceries, etc.), just as pickup trucks serve a variety of personal and business needs. However, given that there are more than 40 SUVs from 10 manufacturers that are at least as fuel efficient as the highest mileage minivan, why is the Times Union not excoriating the owners of minivans? Why not complain about the owners of pickups? If the Times Union is going to decide what types of vehicles consumers should be able to buy, the paper needs to explain the basis for their decision. Of course, the editors should also explain why their views should replace the judgment of millions of consumers.

    However, if the Times Union is going to focus only on SUVs, than at least they should get their numbers right. For example, the editorial claims that SUVs account for 48% of all vehicle sales today... However, according to the February 2003 edition of J. D. Power and Associates' The Power Report, the actual sales share of SUVs for 2002 was 23.62%.

    The editorial claims that SUVs are heavyweight vehicles, with high-horsepower engines that guzzle gasoline... Not only are there a very wide range of SUVs available to meet a wide range of consumer needs (just as there are many different sizes and styles of pickup trucks and minivans) but many of those SUVs are smaller vehicles. Furthermore, small SUVs are a hot growth segment. Even back in 2001, USA Today, in an article Small SUVs catch on, especially with women, noted Sales of small sport-utility vehicles are roaring up 37% this year from last, on track to hit 1 million while the rest of the new vehicle market is idling.

    Although there were a number of serious factual flaws in the Times Union editorial, none compared with their assertion that, If SUVs are so popular with consumers, they will likely buy them even if the price tag were to rise... Thus, it is apparently the view of the newspaper's editors that consumers are able to afford what they like, regardless of price; an unreality completely in keeping with the rest of the editorial. Before making unfounded assumptions about consumers, the Times Union may want to try a little research, such as speaking with SUV owners. The paper could start with the Sport Utility Vehicle Owners of America, Perhaps a little education would go a long way to erasing the Times Union's stereotypes about the owners of SUVs and other light trucks.
  • Click to read "The Power Report", February 2003
  • Click to read USA Today, "Small SUVs catch on, especially with women"
  • Click to read Times Union, "SUV's, still guzzling"

  • Two Pro-SUV Grassroots Members Respond to Christina Marrs
    Gregory Hudgins continues his lucid defense of SUVs in his response to Christina Marrs. A key issue Mr. Hudgins expounds on are the differences between various vehicles classified as SUVs. Although Mr. Hudgins and Ms. Marrs have diametrically opposed viewpoints on SUVs, both are committed to substantive and courteous debate on this important public policy issue. As previously noted in this space, the Hudgins-Marrs dialog is essential reading for all interested stakeholders – including federal officials. Ed White, a new Grassroots Network member, also responds to Ms. Marrs' letter and discusses SUV emissions.
  • Click to read Gregory Hudgins' letter
  • Click to read Ed White's letter
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  • A Grassroots Response to Gregory Hudgins
    Christina Marrs, a Texas-based member of the Grassroots Network, provides a thoughtful and detailed rebuttal to Gregory Hudgins' defense of SUVs. In a point-by-point analysis addressed to Mr. Hudgins, Ms. Marrs discusses the environmental and safety drawbacks associated with SUVs. The letters by Ms. Marrs and Mr. Hudgins combine to provide the public with a superb overview of both sides of the SUV debate. Policy officials and other stakeholders should consider the Hudgins & Marrs letters as required reading.
  • Click to to read Christina Marrs's comments
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  • A Grassroots Network Member Protects His Children and Responds to Anti-SUV Voices
    In one of the most insightful and substantive critiques of the SUV debate written to date, Gregory Hudgins, a California-based member of the FuelEconomyIn.US Grassroots Network, discusses the importance of safe transportation for his family. He also refutes published allegations regarding poor SUV fuel economy and explains how he achieves surprisingly good mileage through proper maintenance and moderate driving. In addition to responding to anti-SUV critics, Gregory places concerns regarding SUV mileage in context and opens a broader debate on fuel economy.
  • Click to to read Gregory Hudgins' article
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  • A Grassroots Network Member Responds to FuelEconomyIn.US' Analysis of the Rebound Effect
    David Joyal, a member of the FuelEconomyIn.US Grassroots Network, disagrees with our analysis of the "rebound" effect, the expected increase in driving that would result from a decrease in cost per mile driven resulting from a new CAFE standard. David explains that an increase in fuel taxes would negate the rebound effect.

  • Click to read David Joyal's comments
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  • Automotive Alliance Questions NHTSA's Estimate of the "Rebound Effect"
    The Alliance of Automobile Manufacturers, in their comments to NHTSA on the proposed light truck CAFE rule, disagreed with the agency's estimate of the rebound effect from higher mileage standards. The term "rebound effect" refers to the increase in miles driven as a result of higher CAFÉ standards reducing the cost of each mile driven. NHTSA estimated the rebound effect at 15%, i.e. a 7.25% increase in fuel mileage would result in a 1.09% increase in miles driven. The Alliance noted that, in 1994, a Federal Advisory Committee estimated the rebound effect as being 35%. The Alliance recommended that NHTSA use 35% as the rebound effect with a sensitivity analysis of 20%-50%.

    The rebound effect issue is critical to the rulemaking since the level of the effect would have significant impacts on:

    1. Fatalities. The level of rebound effect will significantly affect the increase in injuries and fatalities resulting from an increase in light truck CAFÉ due to the increase in miles drive. The Alliance states that, using a 15% rebound effect rate, fatalities would increase by 124 during the 2005-2007 model year period. Using the Alliance's recommended range for the rebound effect, the increase in fatalities resulting from effect would be between 164-289 over the same period.

    2. Congestion. Increasing vehicle miles traveled would increase traffic congestion, particularly in urban areas. The increase in congestion would have several impacts which need to be accurately factored into NHTSA's environmental and economic analyses including:
    3. Fuel consumption. Increased traffic congestion would increase idling and travel times for all vehicles on the road in the affected areas. Thus, calculations of fuel savings from an increase in CAFE need include increased fuel consumption by all vehicles, including cars and heavy trucks, due to increased traffic congestion. The impact of the increased fuel consumption on petroleum imports also should be examined as part of the analysis.

      Pollution. Along with increased fuel consumption would come increased air emissions from automobiles, light trucks and heavy trucks. These emissions need to be modeled, both on a macro level and on a regional level. Particular attention should be given to whether the increase in traffic congestion would place any metropolitan areas in non-attainment with air standards and potentially affect their highway funding.

      Loss of productivity. Increasing the time is takes for trucked goods to reach their destination and extended commutes for workers would reduce economic productivity. The decline in productivity from higher CAFÉ standards needs to be factored into NHTSA's economic analyses.

    4. Road wear. Increasing the number of vehicle miles traveled will increase the wear and tear on roads. The increased maintenance costs on federal, state and local governments needs to be analyzed.

    NHTSA's estimate of the rebound effect, and the analyses incorporating this estimate, are subject to the Department of Transportation's Data Quality Guidelines. DOT's Guidelines contain detailed and well thought out instructions for developing and analyzing data. The Guidelines also provide stringent data quality standards for use in risk assessments. Thus, NHTSA needs to ensure that their estimate of the rebound effect, and the analyses incorporating this estimate, are consistent with the Department's Data Quality Guidelines.

    A Marketing Campaign Only A Terrorist Could Love

    Terrorism Sells. At least that's the hope of the producers of a new series of television ads claiming that SUV purchases support terrorism. Just as the allure of sex is used to sell merchandise, the ads' producers are using the threat of terrorism to sell public policy recommendations. However, the likelihood that a consumer will help prevent terrorism by not buying an SUV is about the same as their getting a date with a supermodel (or turning into one) as a result of using the right brand of toothpaste.

    The thrust of the ads is that the gasoline in SUVs comes from Middle Eastern countries which support terrorism. The notion that driving and SUV aids terrorism is factually incorrect. First, US oil imports from the Persian Gulf (Kuwait, Saudi Arabia, Bahrain, Iran, Iraq, Qatar and the United Arab Emirates) accounted for just under 20% of Persian Gulf exports to OECD (industrialized) nations in the most recent period for which data is available (3rd Quarter of 2002). [Source: Energy Information Administration] By contrast, Europe accounted for 24% of Persian Gulf exports and Japan took in about 37% of Persian Gulf exports. Second, the ads fail to account for how small a share of Persian Gulf oil is actually consumed by SUVs. Of total US oil consumption, only about 45% goes for gasoline. [Source: Energy Information Administration] Thus, US gasoline consumption accounts for about 9% of Persian Gulf exports. In that SUVs make up about 20% of new vehicle sales, it is clear that their total fuel consumption, even if they were 20% of the vehicles on the road (they are nowhere close to this number), would account for maybe 2% of Persian Gulf exports. Therefore, replacing SUVs with other vehicles or even radically changing the fuel efficiency of all SUVs on the road would have result in, at most, a de minimus (<1%) reduction in Persian Gulf oil exports to the US, far less than virtually any other factor or normal market fluctuations.

    Crafting public policy requires analyzing large amounts of scientific data, considering the interests of diverse stakeholders and weighing complex trade-offs. Its hard work. Far harder than lobbing incendiary and misleading charges on television. American servicemen and women are risking their lives around the world in the fight against terrorism. They and their families and friends know the fight is to protect American lives and freedom. The ad campaign's producers and financial backers want to convince them they are risking their lives to protect SUVs. It's a marketing campaign only a terrorist could love.

    If Americans give up the vehicles they need for family and business because of a misguided campaign, the terrorists will have won.

  • Click here to read New York Times article
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  • CRE Launches FuelEconomyIn.US: Recommends NHTSA Defer New CAFE Standards Until Long Term Strategy Plan Completed

    The Center for Regulatory Effectiveness recommended that NHTSA defer the short-term action of establishing new CAFE standards for light trucks until the agency develops a long term strategy. CRE recommended that the agency's CAFE strategy should be based on the thirteen elements contained in the Levin-Bond amendment, passed by the Senate, which delineated policy issues which must be addressed when establishing CAFE standards. One of the directives included in the Levin-Bond amendment was a requirement that the agency address the structural flaws identified by the National Research Council in their comprehensive study of the CAFE program.

    CRE created FuelEconomyIn.US to provide NHTSA and other federal agencies with a wide range of stakeholder views on the key issues raised in the Levin-Bond amendment and National Research Council study. FuelEconomyIn.US has established an Interactive Public Docket to provide a mechanism for collecting and disseminating stakeholder comments. To this end, CRE encourages all stakeholders to provide FuelEconomyIn.US with their views on CAFE to NHTSA and CRE.
  • Click to read CRE comments to NHTSA
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