CAFE: Who Are We Kidding? (Part 3)

There are many more issues with this regulation, but I'll leave you with these:

We were particularly encouraged that Reformed CAFE will confer no compliance advantage if vehicle makers choose to downsize some of their fleet as a CAFE compliance strategy...

Another fallacy. The agency says larger, heavier vehicles are safer vehicles (for passengers). They say lighter vehicles are more efficient. So the fuel economy regulation is now based on vehicle footprint. This is even more of an unnecessary attempt at classifying vehicles (see Part 2).

...requiring improvements in fuel economy necessarily has the effect of requiring reductions in tailpipe emissions of CO2 emissions.

This one line of thinking probably has more to do with why CAFE was initiated in the first place and demonstrates that the whole program is based on a flawed assumption.

They missed the global view, focusing on the proportional relationship between CO2 emissions and fuel consumption. Did it not occur to legislators (the agency shouldn't take all the blame - they're doing what they were directed to do) that improving fuel economy encourages people to drive more thus NOT reducing the amount of fuel used, even if fuel economy was improved?

The answer is yes because the rulemaking goes on to further contradict itself.

... the rebound effect from higher fuel economy will increase emissions of these pollutants. Thus, the net effect of stricter CAFE standards on emissions of each pollutant depends on the relative magnitudes of its reduced emissions in fuel refining and distribution, and increase in its emissions from vehicle use.

In other words, CAFE will work if people don't drive much more. But when fuel cost goes down vehicle miles go up. Hmmm....

The 2002 Effectiveness and Impact of Corporate Average Fuel Economy (CAFE) Standards report by the National Academy of Sciences (NAS) report cited in the rulemaking states:

While raising CAFE standards under the existing structure would reduce fuel consumption, doing so under alternative structures 'could accomplish the same end at lower cost, provide more flexibility to manufacturers, or address inequities arising from the present' structure.

Here is a report written at the behest of Congress and acknowledged by NHTSA that CAFE is not the best way to go about improving fuel economy and efficiency. So what does the government collectively do? More of the same.

What they should do is tax the fuel and cancel this complicated and ineffective program. Stop trying to make a pig fly.