Comments on the Joint Proposed Rulemaking to Establish Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards PDF Download

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I appreciate the opportunity to provide comments on the joint rulemaking to establish greenhouse gas emission and fuel economy standards for light-duty vehicles. My comments are directed at the choice of vehicle footprint as the attribute by which to vary fuel economy and greenhouse gas emission standards, in the interest of protecting vehicle occupants from death or serious injury. I have made several of these points before when commenting on previous NHTSA rulemakings regarding CAFE standards and safety. The comments today are mine alone, and do not necessarily represent the views of the US Department of Energy, Lawrence Berkeley National Laboratory, or the University of California. My comments can be summarized as follows: (1) My updated analysis of casualty risk finds that, after accounting for drivers and crash location, there is a wide range in casualty risk for vehicles with the same weight or footprint. This suggests that reducing vehicle weight or footprint will not necessarily result in increased fatalities or serious injuries. (2) Indeed, the recent safety record of crossover SUVs indicates that weight reduction in this class of vehicles resulted in a reduction in fatality risks. (3) Computer crash simulations can pinpoint the effect of specific design changes on vehicle safety; these analyses are preferable to regression analyses, which rely on historical vehicle designs, and cannot fully isolate the effect of specific design changes, such as weight reduction, on crash outcomes. (4) There is evidence that automakers planned to build more large light trucks in response to the footprint-based light truck CAFE standards. Such an increase in the number of large light trucks on the road may decrease, rather than increase, overall safety.