01 Jul 2006 CAFE Standards Kill: Congress’ Regulatory Solution to Foreign Oil Dependence Comes at a Steep Price, by Ryan Balis
On the heels of the Arab oil embargo, in 1975 Congress enacted Corporate Average Fuel Economy (CAFE) standards as a regulatory solution to reduce the United States’ dependence on foreign oil and gasoline consumption.1 CAFE standards mandate that vehicles sold in the U.S. meet fuel efficiency – or “fuel economy” – standards. Current standards require an average of 27.2 miles per gallon (mpg) for cars and 21.6 mpg for light trucks.2
Beginning in 2008, “one-size-fits-all” CAFE standards for light trucks will be phased out. New regulations will divide light trucks into six categories based on vehicle size – each category having its own mpg target.3 However, the fuel economy for these vehicles will be raised from the current 22.2 mpg to 24.0 mpg in model year 2011.4
According to a National Highway Traffic Safety Administration (NHTSA) estimate, implementing this change will cost American consumers over $6.71 billion in added vehicle expenses from 2007-2011.5 Yet Marlo Lewis, a senior fellow at the Competitive Enterprise Institute, calculates that the fuel savings will be a mere 0.44 billion gallons of gasoline annually.6 On average, U.S. cars and light trucks consume some 11 billion gallons of gasoline each month.7
Despite the new regulatory “reform,” high gas prices have lawmakers in Washington debating, once again,8 whether to impose even steeper CAFE standards. For instance, Senators Dianne Feinstein (D-CA), Olympia Snowe (R-ME) and Dick Durbin (D-IL) proposed burdensome across-the-board legislation to increase CAFE standards to 35 mpg on both light trucks and cars by model year 2017.9 Senators Lisa Murkowski (R-AK) and Maria Cantwell (D-WA) have also recently called for CAFE increases.10
But such increases have unintended safety consequences for the safety of drivers and passengers. The reason is because carmakers build lighter and smaller cars that burn less fuel to comply with CAFE standards.11 The trade-off is these lighter, smaller cars fare much worse in violent crashes, resulting in greater rates of death and injury for occupants.
A number of studies have documented the lethal consequences of requiring carmakers to improve fuel standards.
* According to a 2003 NHTSA study, when a vehicle is reduced by 100 pounds the estimated fatality rate increases as much as 5.63 percent for light cars weighing less than 2,950 pounds, 4.70 percent for heavier cars weighing over 2,950 pounds and 3.06 percent for light trucks. Between model years 1996 and 1999, these rates translated into additional traffic fatalities of 13,608 for light cars, 10,884 for heavier cars and 14,705 for light trucks.12
* A 2001 National Academy of Sciences panel found that constraining automobile manufacturers to produce smaller, lighter vehicles in the 1970s and early 1980s “probably resulted in an additional 1,300 to 2,600 traffic fatalities in 1993.”13
* An extensive 1999 USA Today analysis of crash data found that since CAFE went into effect in 1978, 46,000 people died in crashes they otherwise would have survived, had they been in bigger, heavier vehicles. This, according to a 1999 USA Today analysis of crash data since 1975, roughly figures to be 7,700 deaths for every mile per gallon gained in fuel economy standards.14
* The USA Today report also said smaller cars – such as the Chevrolet Cavalier or Dodge Neon – accounted for 12,144 fatalities or 37 percent of vehicle deaths in 1997, though such cars comprised only 18 percent of all vehicles.15
* A 1989 Harvard-Brookings study estimated CAFE “to be responsible for 2,200-3,900 excess occupant fatalities over ten years of a given [car] model years’ use.” Moreover, the researchers estimated between 11,000 and 19,500 occupants would suffer serious but nonfatal crash injuries as a result of CAFE.16
* The same Harvard-Brookings study found CAFE had resulted in a 500-pound weight reduction of the average car. As a result, occupants were put at a 14 to 27 percent greater risk of traffic death.17
* Passengers in small cars die at a much higher rate when involved in traffic accidents with large cars. Traffic safety expert Dr. Leonard Evans estimates that drivers in lighter cars may be 12 times as likely to be killed in a crash when the other vehicle is twice as heavy as the lighter car.18
In addition to the above studies, the following quotes provide a quick reference point of safety experts’ results and statements on the consequences of CAFE regulations as they relate to vehicle safety.
* “The negative relationship between weight and occupant fatality risk is one of the most secure findings in the safety literature.”
-Dr. Robert W. Crandall, Brookings Institution, and John D. Graham, Ph.D., Harvard School of Public Health19
* “Why Does CAFE kill? It does so because it constrains the production of larger cars and, in most modes of collision, larger, heavier cars are more protective of their occupants than are small cars.”
-Sam Kazman, Competitive Enterprise Institute20
* “[I]n terms of just the total number of lives, when I purchase a larger car, there is a reduction of risk. I’m safer, and so is society overall… We can conclude, beyond any reasonable doubt, that when weight is reduced, as it must be under CAFE, we will increase casualties.”
-Dr. Leonard Evans, physicist, author of Traffic Safety and president of Science Serving Society21
* “During the past 18 years, the office of Technology Assessment of the United States Congress, the National Safety Council, the Brookings Institution, the Insurance Institute for Highway Safety, the General Motors Research Laboratories and the National Academy of Sciences all agreed that reductions in the size and weight of passenger cars pose a safety threat.”
-National Highway Traffic Safety Administration22
* “If you want to solve the safety puzzle, get rid of small cars.”
-Brian O’Neill, Insurance Institute for Highway Safety23
* “CAFE is a solution in search of a problem.”
-Dr. Robert W. Crandall, Brookings Institution24
* “The evidence is overwhelming that CAFE standards result in more highway deaths.”
-Charli E. Coon, J.D., Heritage Foundation25
* “The conclusion is that CAFE has caused, and is causing, increased deaths…. CAFE kills, and higher CAFE standards will kill even more.”
-Dr. Leonard Evans, physicist, author of Traffic Safety and President of Science Serving Society26
Ryan Balis is a policy analyst for The National Center for Public Policy Research.
1 Charli E. Coon, “Why the Government’s CAFE Standards for Fuel Efficiency Should Be Repealed, Not Increased,” Backgrounder No. 1458, The Heritage Foundation, Washington, D.C., July 11, 2001, available at http://www.heritage.org/Research/EnergyandEnvironment/BG1458.cfm as of June 23, 2006.
2 Title 49 U.S. Code, Chapter 329, Nov. 2000, sec. 32902, National Highway Traffic Safety Administration, Washington, D.C., available at http://www.nhtsa.dot.gov/nhtsa/Cfc_title49/ACTchap321-331.html#32902 as of June 23, 2006. The classification for light trucks includes pickups, minivans and SUVs weighing not more than 8,500 pounds. For current fuel economy regulations on light trucks, see “Light Truck Average Fuel Economy Standards: Model Years 2005-2007,” Docket No. 2002-11419; Notice 3, p. 28, National Highway Traffic Safety Administration, Department of Transportation, Washington, D.C., available at http://www.nhtsa.dot.gov/cars/rules/rulings/CAFE05-07/Index.html as of June 23, 2006.
3 Andrzej Zwaniecki, “United States To Raise Fuel-Economy Standards for Light Trucks,” U.S. State Department, Washington, D.C., August 24, 2005, available at http://usinfo.state.gov/gi/Archive/2005/Aug/25-936784.html as of June 23, 2006; NHTSA final regulation available at http://www.nhtsa.dot.gov/staticfiles/DOT/NHTSA/Rulemaking/Rules/Associated%20Files/2006FinalRule.pdf as of June 23, 2006.
4 “Average Fuel Economy Standards for Light Trucks: Model Years 2008-2011,” Docket No. 2006- 24306, p. 12, National Highway Transportation Safety Administration, Department of Transportation, Washington, D.C., available at http://www.nhtsa.dot.gov/staticfiles/DOT/NHTSA/Rulemaking/Rules/Associated%20Files/2006FinalRule.pdf as of June 23, 2006.
5 “Average Fuel Economy Standards for Light Trucks: Model Years 2008-2011.”
6 Marlo Lewis, “CAFE For Dummies,” Competitive Enterprise Institute Open Market, April 11, 2006, available at http://www.ceiopenmarket.org/openmarket/2006/04/cafe_for_dummie.html as of June 23, 2006.
7 Figure from American Petroleum Institute cited in U.S. State Department release. See Andrzej Zwaniecki.
8 In 2003, Senators Feinstein and Snowe introduced legislation to require that SUVs have the same fuel standards as passenger cars. See “Senators Feinstein and Snowe Introduce Legislation to Increase Fuel Efficiency Standards,” Office of Senator Diane Feinstein, January 30, 2003, available at http://www.senate.gov/~feinstein/03Releases/r-cafe03.htm as of June 23, 2006. In 2002, Senators John Kerry and John McCain proposed raising CAFE standards on all vehicles to 36 mpg by 2015. See Cat Lazaroff, “Senate Rejects Mandatory Fuel Efficiency Proposal,” Environment News Service, March 15, 2002, available at http://www.ens-newswire.com/ens/mar2002/2002-03-15-06.asp as of June 23, 2006; Gretchen Randall, “Fuel Efficiency Standards: What to Do Next?,” National Policy Analysis No. 393, The National Center for Public Policy Research, Washington, D.C., February 2002, available at http://www.nationalcenter.org/NPA393.html as of June 23, 2006.
9 “Senators Feinstein, Snowe, Durbin Call for Raising Average Fuel Economy Standards for All Vehicles to 35 mpg by Model Year 2017,” Office of Senator Diane Feinstein, May 10, 2006, available at http://feinstein.senate.gov/06releases/r-cafe-announc.pdf as of June 23, 2006.
10 H. Josef Hebert, “White House Pressured to Increase Auto Fuel Economy,” Miami Herald (Associated Press), May 10, 2006, available at http://www.charlotte.com/mld/miamiherald/news/nation/14540962.htm?source=rss&channel=miamiherald_nation as of June 23, 2006; Dana Milbank, “Going a Short Way to Make a Point,” Washington Post, April 27, 2006, available at http://www.washingtonpost.com/wp-dyn/content/article/2006/04/26/AR2006042602307_pf.html as of June 23, 2006.
11 “CAFE unquestionably leads to lighter vehicles, because fuel is consumed in ways that are intimately related to mass. The energy required to accelerate a body from rest to 30 mph is directly proportional to the mass of the body. So the heavier the vehicle, the more fuel you must use, other things being equal.” Remarks by Dr. Leonard Evans, “Does CAFE Kill? Oral Remarks By Dr. Leonard Evans,” A Discussion of the Report on CAFE of the National Research Council of the National Academies of Sciences, Competitive Enterprise Institute, Washington, D.C., January 17, 2002, available at http://www.cei.org/gencon/027,02350.cfm as of June 23, 2006; Gretchen Randall.
12 Charles J. Kahane, Ph.D., “Vehicle Weight, Fatality Risk and Crash Compatibility of Model Year 1991-99 Passenger Cars and Light Trucks,” National Highway Traffic Safety Administration, Department of Transportation, Washington, D.C., October 2003, p. 11-13, available at http://www.nhtsa.dot.gov/cars/rules/regrev/evaluate/pdf/809662.pdf as of June 23, 2006.
13 Paul R. Portney, et. al, “Effectiveness and Impact of Corporate Average Fuel Economy (CAFE) Standards (2002), The National Academy of Sciences, Washington, D.C., 2002, p. 3, available at http://darwin.nap.edu/books/0309076013/html/3.html as of June 23, 2006.
14 James R. Healey, “Death by the Gallon,” USA Today, July 2, 1999.
15 “Small cars – those no bigger or heavier than Chevrolet Cavalier or Dodge Neon – comprise 18 percent of all vehicles on the road, according to an analysis of R.L. Polk registration data. Yet they accounted for 37 percent of vehicle deaths in 1997 – 12,144 people – according to latest available government figures. That’s about twice the death rate in big cars, such as Dodge Intrepid, Chevrolet Impala, Ford Crown Victoria.” See Ibid.
16 Robert W. Crandall and John D. Graham, “The Effect of Fuel Economy Standards on Automobile Safety,” Journal of Law and Economics, Vol. 32:1, p. 97-118, April 1989, available at http://www.fortfreedom.org/s51.htm as of June 23, 2006.
18 Dr. Leonard Evans.
19 Crandall and Graham.
20 Remarks By Sam Kazman, “CAFE Standards: Do They Work? Do They Kill?,” The Heritage Foundation, Washington, D.C., February. 25, 2002, available at http://www.cei.org/gencon/027,02414.cfm as of June 23, 2006.
21 Dr. Leonard Evans.
22 Quoted in James R. Healey, “Death by the Gallon,” USA Today, July 2, 1999.
24 Remarks by Dr. Robert W. Crandall, “Fuel Economy Standards: Do they Work? Do they Kill?,” WebMemo No. 85, The Heritage Foundation, Washington, D.C., March 8, 2002, available at http://www.heritage.org/Research/EnergyandEnvironment/WM85.cfm as of June 23, 2006.
25 Charli E. Coon.
26 Dr. Leonard Evans