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DOT Docket No. NHTSA 2002-11419
Docket Management
U.S. Department of Transportation
Room PL-401
400 Seventh Street, SW
Washington, DC 20590

  Comments of Public Citizen Regarding:
Request for Comments; National Academy of Science Study and Future Fuel Economy Improvements, Model Years 2005-2010

I. Introduction

The National Highway Traffic Safety Administration (NHTSA) has requested comments on the recommendations of the National Academy of Sciences (NAS) report, "Effectiveness and Impact of Corporate Average Fuel Economy (CAFE) Standards." The NAS report contains several useful recommendations regarding possible improvements in the CAFE system. However, the majority opinion also posits a relationship between fuel economy standards and safety that has never been conclusively demonstrated and has been controverted by more recent studies. The agency should be confident that new CAFE standards need not negatively impact safety. Public Citizen’s decades of research and advocacy aimed at improving vehicle safety make us certain about this point.

Public Citizen’s overall message to NHTSA is twofold:

Our comments discuss these two points and then answer the agency’s specific questions.

II. The NAS study’s safety conclusions include unsubstantiated implications

The NAS panel majority conclusion regarding safety stated that:

This statement implies three separate causal relationships:

1. CAFE requirements have constrained the size of motor vehicles
2. CAFE requirements have constrained the weight of motor vehicles
3. Size and/or weight constraints have lead to additional injuries and fatalities

In order to understand the problems with the position taken by the majority panel, each of these statements must be examined independently. Public Citizen will demonstrate that none of the three assertions can be conclusively proved in the way the NAS panel asserted, and consequently we will show that the conclusions of the NAS majority are in error.

A. Raising CAFE standards need not impact the size of most vehicles – lightweight materials will allow manufacturers to retain size while improving fuel economy

Vehicle size, as distinct from weight, is pertinent to safety, and confounds the analysis of fuel economy effects for several reasons. Larger vehicles provide additional room for occupants’ torsos and limbs to avoid contact with the area of crash impact, and there is space inside them to design the vehicle frames of large vehicles to better absorb crash forces, so that occupants’ bodies do not.

Manufacturers may choose to reduce the weight of their heaviest vehicles to improve fuel economy performance, but this need not come at the expense of significant size. A properly designed vehicle made with lightweight materials can offer ample room for passenger protection without sacrificing fuel economy performance. The perfect example of this is NHTSA’s Research Safety Vehicle (RSV).

The RSV was built in the 1970s under a contract with Minicars, Inc., lead by Don Friedman, a former GM engineer who won a NHTSA competition for the contract against much larger companies. The finished vehicle weighed 2,450 lbs., got 32 miles to the gallon in 1978, and safely protected its occupant in severe crash tests.(3)

The vehicle was able to protect its occupants in a full frontal barrier impact at 50 miles per hour (mph) and in side impact and rollover crashes at 40 mph without significant risk of occupant injury. Current statements from Friedman indicate that, if equipped with the hybrid engine technology currently being used in the Honda Insight, this vehicle would achieve a fuel economy today of between 50 and 60 mpg.(4)

The RSV achieved this remarkable performance using a tubular steel frame with a foam core. This design caused it to crumple during crash tests, absorbing crash energies and reducing their severity for occupants. The technology to build a vehicle of this sort has existed for a generation and has since been enhanced by developments in materials technology. The American Iron and Steel Institute recently announced the result of a study of advanced high-strength steels that "will provide an unprecedented, high level of crash safety performance at no cost increase."(5) The automotive industry has access to these technologies and could easily take advantage of them if it were required to meet higher CAFE standards.

There is a wide disparity in fuel economy performance among the vehicles in today’s fleet. In response to testimony from Ford, Honda submitted a letter to the Senate Commerce Committee on December 19, 2002, pointing out that its vehicles achieve substantially better fuel economy than comparable Ford vehicles. This was true for subcompacts, compacts, midsize cars, minivans and SUVs.(6)

There is no compelling reason for CAFE standards to reduce vehicle size. Smaller, better designed vehicles will outperform larger, more poorly designed vehicles in protecting their occupants and delivering high fuel economy performance. If NHTSA maintains strong standards for crashworthiness, manufacturers will adjust vehicle design to accomplish both goals.

B. Raising CAFE standards may affect the distribution of vehicle weights, but there is no need to fear that the weight of small- or mid-sized vehicles will be reduced

The historical record on CAFE does not bear out Ford’s dire predictions. The link between CAFE standards and reductions in vehicle weight at the low end of the vehicle weight range simply does not exist: while the heaviest vehicles were put on a diet following the initial imposition of CAFE standards, the lightest vehicles today are considerably heavier than their pre-CAFE counterparts. As was pointed out in the December 6, 2001, testimony of Clarence Ditlow of the Center for Auto Safety, the original passage of CAFE standards did not result in light cars becoming lighter or less safe. In fact, the Honda Civic gained 800 lbs. and went from failing NHTSA crash tests to receiving the best possible rating for crashworthiness – 5 stars. Moreover, the Ford Pinto and Chevrolet Chevette, notably unsafe vehicles, were replaced by the safer models of the Ford Escort and Chevrolet Nova.(8)

Looking at the CAFE-weight relationship more broadly, as fleet fuel economy increased over time, vehicle weights did not move in any one direction. Because automakers could get proportionally more fuel savings from reducing the weight of the heaviest class of cars, it was more cost-effective to make them the targets for fuel economy improvements. Interestingly, production numbers for cars in the lightest class actually decreased in the 1980s.

In 1975, cars weighing less than 2,500 lbs. made up 10.8 percent of the new-car fleet, but by 2000 this category had shrunk to only 2.6 percent of new cars. Similarly, cars in the over 4,500 pound weight class made up 50 percent of the new-car fleet in 1975 but only 0.9 percent in 2000. These data show that CAFE standards did not cause a uniform reduction in vehicle weight at the light vehicle level (although CAFE may have caused a reduction in average weight, as more cars were built in the 2,500-4,500 pound category).(9)

Any improvement in the CAFE standards made today will likely have a similarly small impact on the weight or production levels of the smallest cars. It is not cost-effective to reduce the weights of smaller cars by very much, given the limited fuel economy improvement from doing so and the relatively higher cost of vehicle redesign. It is instead far more likely that manufacturers will reduce the weight of their heaviest vehicles, improving passenger safety. As the Insurance Institute for Highway Safety testified before the Senate on January 24, 2002, there is a "diminishing protective effect as vehicle weight approaches 3,500 to 4,000 pounds" and "beyond about 4,000 pounds, increasing vehicle weight results in a net increase in fatalities, as the risk to other road users more than offsets the increased occupant protection afforded by the additional weight." (10)

The assumption that higher CAFE standards will lead to reductions in vehicle weight across the fleet is neither historically accurate nor prospectively astute. While the average vehicle may get lighter under a new CAFE regime, the way in which this adjustment is achieved would be through weight reductions among the heaviest vehicles.

C. Major improvements in fuel economy are possible using currently available technology without any reduction in safety protection

A study performed for the Society of Automotive Engineers concluded that 85 percent of the fuel economy gains made from 1974 to 1991 came from improvements in vehicle technology rather than weight reduction.(11) The evidence, in both vehicles already on the road and unused technologies, strongly suggests that similar technological leaps are currently available or just around the corner.(12)

The Union of Concerned Scientists (UCS) pointed out in a report released in 2001 that today’s vehicles could become more fuel efficient at a price that would easily be made up in savings on fuel costs, and the necessary changes would have no negative impact on safety. Technologies currently used in portions of today’s fleet, if adopted fleetwide, could make vehicles far more streamlined, less fuel intensive, and more efficient. A partial list of these technologies includes the following:

The UCS has not limited its research to the hypothetical realm. With technologies currently used in mass production by at least one company, and basing their design on the current Ford Explorer, the UCS designed a new vehicle that increased the real world fuel economy of the Explorer by 50 percent while improving zero to sixty performance by 1.7 seconds and saving 4 percent ($1,577 in gasoline costs) over the lifetime cost of the unimproved vehicle (See Table 1). Adding technologies currently entering the market to their design, they were able to improve fuel economy by 75 percent, creating a vehicle that would test at 34.1 mpg and save 6 percent ($2,163) over the lifetime cost. (14)

Table 1: Union of Concerned Scientists’ Greener SUV

Ford’s Explorer currently fails to meet the very modest 20.7 mpg CAFE standard for light trucks, getting just 19 mpg. With the improvements implemented by the UCS using currently available technology, the same vehicle surpassed the current 27 mpg CAFE standard for passenger cars. Given the challenge of a higher CAFE standard to meet, auto manufacturers, with their considerably larger resources, could certainly far surpass the 34.1 mpg performance achieved by UCS by 2010.

Even if it was certain that vehicle weights would have to be reduced across the fleet to comply with new CAFE requirements, a supposition that Public Citizen rejects, the impact of these weight reductions on safety is far from clear and could very likely be positive as a net effect. A study that demonstrated the likely effects of large weight reductions from the heaviest vehicles in the fleet while leaving the weights of the smallest vehicles unchanged (a more realistic scenario) would undoubtedly show an improvement in overall safety.

D. The relationship between vehicle weight and safety is poorly understood. The study that undergirds NAS’s safety argument is a poor predictor of actual impact and has been refuted by more recent work

The primary study upon which the NAS panel majority based its conclusions about the weight-safety relationship, prepared in 1997 by Charles Kahane of the National Highway Traffic Safety Administration (NHTSA), has several problems.

Some members of the panel that published the July 2001 NAS report on fuel economy contend that raising CAFE standards would increase occupant fatalities in crashes due to a connection between vehicle weight and fatality crash rates. As was pointed out, however, in a strong NAS panel dissent by David Greene and Maryann Keller, since joined by other critics, this conclusion is problematic. In addition to the failure to make assumptions that reflect the history of vehicle change and extricate vehicle size and weight from each other, as discussed above, the panel’s analysis, and the Kahane study upon which it relied, suffer from three other major flaws.

1. The Kahane study relied on old data about vehicle safety and failed to take crashworthiness improvements into account when making assumptions about the future

The data used in the Kahane study cited by the NAS is from 1993 and before, and therefore fails to account for recent advances in occupant protection from new government standards, such as dynamic side impact protections, dual air bags, and head injury protections.

In holding crashworthiness constant, the panel overlooked crucial, compensating safety improvements that are possible in the areas of rollover and aggressivity (two areas of particular concern given the proportion of SUVs in today’s vehicle fleet) thus overstating the negative safety effects.

In addition, Kahane hypothesized that the largest increase in fatalities by CAFE would come from deaths in small vehicle rollover crashes. This oversight is particularly troubling given the high potential survivability of rollover crashes, deaths that would be avoidable with proper crash protections, as discussed below.

NHTSA has announced plans to issue standards for improving rollover crashworthiness, though these plans have never been carried out. In 1994, NHTSA terminated its work on a rollover propensity standard by promising that a series of improvements in rollover crashworthiness and consumer information were forthcoming.(15) Were NHTSA to issue these standards, the predictive powers of the Kahane study concerning rollover fatalities would be necessarily diminished.

2. The Kahane study is too old to contain mounting evidence regarding aggression and incompatibility and the NAS panel did not attempt to include this data

The panel overlooked the results from several studies, performed since the Kahane study was completed, which suggest that disparities among vehicle weight are the cause of devastating crashes, thus suggesting that instead of causing harm, any convergence effect on vehicle weights from CAFE standards would actually yield safety benefits.

3. The Kahane study makes a historically inaccurate assumption about fleet weight reduction

The Kahane study assumed that all vehicles in the fleet would made lighter by an identical amount (100 lbs.), when in fact, historically, the heaviest vehicles got lighter and the lightest vehicles got heavier from 1975 to 1985 in response to initial CAFE legislation and rules, to the benefit of safety. This point is discussed at length above. The NAS panel used this historically baseless assumption to extrapolate the number of fatalities that have been caused by CAFE increases, ignoring evidence about the actual shift in fleet weights that took place in the 1970s and 1980s.

Other studies of this issue have faced similar problems to those encountered by Kahane. The General Accounting Office released a study of the weight-safety relationship in 1992, determining that "the pattern of our findings is consistent with an interpretation that automobile weight reductions have a net effect on total highway fatalities that is close to zero." They attempted to link declines in average vehicle weights during the 1970s and 1980s with fatality rates, but found that these reductions "did not have the dire consequences for safety that would be expected if fatality rates were simply a function of car weight."(16)

E. New research contradicts the findings of Kahane

Honda presented its results of an updated version of the Kahane study, performed by Dynamic Research Inc., to the Senate Commerce Committee on January 24, 2002. Using more recent safety and vehicle prevalence data and the Kahane methodology, the researchers found that there was no likelihood of a net increase in fatalities if vehicle weight was reduced across today’s fleet. The Honda study improved upon the Kahane study by using more recent model years, thus accounting for developments in light truck market share and fleetwide passenger protection enhancements, such as the requirement for passenger side air bags.

Kahane cited an increase in deaths caused by crashes between light trucks and cars, which problem has grown because the fuel economy standard for light trucks is barely higher than when Joan Claybrook left her position as NHTSA administrator 21 years ago. Since that time, light truck-type vehicles have proliferated. Stricter congressionally mandated fuel economy standards for these vehicles would result in a vehicle fleet that is more compatible and thereby safer for all drivers. Indeed, the Honda/ DRI study shows a statistically significant decrease in total fatalities in light truck-car crashes when the average weight of vehicles in the light truck fleet is decreased by 100 lbs.(17)

Marc Ross of the University of Michigan and Tom Wenzel of Lawrence Berkeley National Laboratory recently completed a study for the Department of Energy of driver death rates grouped by both vehicle type and model. They found that while the safest midsize cars were as safe as the safest SUV, "SUVs impose a greater risk on drivers of other vehicles than do all types of cars." Pickup trucks, a vehicle category that is on average larger, heavier, and stiffer than passenger cars, have a combined risk to their drivers and occupants of other vehicles that "is much higher than that for other vehicle types." They conclude that the "argument that the low weight of cars with high fuel economy has resulted in many excess deaths is unfounded."(18)

David Greene of the Oak Ridge National Laboratory has studied the vehicle size-weight-safety question for many years and has concluded that "the more carefully one controls for confounding factors [like driver and environmental characteristics], the more the ‘weight effect’ fades away, or even reverses." As he points out, there is no correlation between NHTSA crash test performance and weight. Moreover, Greene found that braking distances increase with vehicle weight, suggesting that lighter vehicles may avoid crashes better than heavier ones. For all these reasons, he was unwilling to support the majority opinion in the NAS study.(19)

Public Citizen understands that NHTSA is planning to update the Kahane study using new data and improved techniques. Any update must take into account the criticisms we raise above, and should strive to offer a realistic picture of the historic and likely future effects of CAFE increases on vehicle weight.

III. Eliminating the light truck loophole would be the best way to fix CAFE and reduce traffic fatalities

The current structure of CAFE contributes to highway deaths not because vehicles are too light, but because of the dual standard created for cars and light trucks, including SUVs. The current system of CAFE standards pretends that there are two vehicle fleets: cars, which must meet a statutorily required 27.5 mpg standard, and "light trucks" and their progeny which meet the 20.7 mpg standard set by NHTSA. The safety consequences of the bifurcation of the standard have been disastrous, as manufacturers have marketed heavier and heavier SUVs as family vehicles.

Erosion of CAFE’s effectiveness will continue as manufacturers keep ramping up SUV size to produce truly massive passenger vehicles in the absence of new fuel economy standards. For just the latest example, in February 2001, DaimlerChrysler announced that the company would be marketing a new mega-vehicle, named the "Unimog," that will be 20 feet long and nearly two feet wider than a typical car, weigh 12,500 lbs., and get 10 mpg on diesel fuel.(20)

To fully eliminate the light truck loophole, Congress must change the law governing CAFE. However, NHTSA can effectively close the loophole by setting a schedule for fuel economy standards for light trucks that substantially increases them over the next decade, forcing light trucks to comply with standards that are similar to those of passenger cars.

A. Light trucks, particularly SUVs, are very dangerous for other drivers on the highway

Study after study shows that heavier vehicles, especially SUVs, are a threat to other drivers in vehicles they hit, especially in their heaviest and most aggressive versions. A 1998 report by Hans Joksch for the Department of Transportation (DOT) showed: 1) that the risks imposed by heavier cars on lighter car occupants outweigh the safety benefits to the heavier car occupant across the entire vehicle fleet on the highway and 2) that greater variability in the distribution of weights increases fatalities.(21) A paper by Alexandra Kuchar of the DOT’s Volpe Institute concluded that shifting the fleet from cars to light trucks – at each increment of the shift – increases serious injuries and fatalities, partly because of the greater stiffness of light trucks.(22)

Despite the perception that light trucks are safer for the occupant, total highway safety is made worse by the presence and weight of these vehicles. Over 11,000 light truck-type vehicle occupants were killed in crashes in 1999, and crashes involving light trucks killed another 4,896 people, for a ratio of .44 non-truck occupant fatalities for every 1 light truck occupant fatality. This should be contrasted with passenger cars, which killed just .08 non-occupants in crashes for each passenger car occupant killed.(23) The NAS report last year concluded that a reduction in the mass of the light truck fleet would result in a net reduction in the number of fatalities on our highways, because the reduced-mass light trucks would kill fewer of the occupants of the other vehicles involved in the crash.(24)

All the research points to conclusions that are precisely the opposite of the myths promoted by manufacturers who use the 1997 Kahane study to justify their position regarding CAFE and safety. Unfortunately, these views were accepted and repeated by the NAS majority.

As David Greene has argued, the risk to other drivers posed by SUVs and other larger vehicles is a way of "exporting" risk as a market externality that should be corrected by government action. Given the high societal costs of automobile crashes – over 230 billion dollars per year according to the DOT’s May 2002 study - the increased fatalities and injuries that result are costs that all of us bear.(25) Closing the light truck loophole and new requirements under CAFE would likely have the happy consequence, as did those passed in 1975, of increasing the number of mid-sized vehicles and bringing about greater convergence in vehicle weight across the fleet, thus improving safety.

IV. Basic improvements in rollover crashworthiness could result in huge reductions in occupant fatalities

Rollovers now kill more than 10,000 people each year, a sum that is fully one-third of all vehicle deaths, yet the causes of death in such a crash are largely preventable. The forces exerted in a rollover crash are small, less than 10 mph in many cases. If vehicle occupants are sufficiently protected from the hazards of a rollover crash they can escape death or serious injury.

The auto industry has been so laggard over the years, causing thousands of needless deaths and injuries, that federal motor vehicle crashworthiness standards are needed. One of the primary elements of protecting occupants in a rollover crash is a roof that is resistant to crushing as the vehicle rolls. Currently, roof crush standards do not adequately measure the way a roof is likely to respond in a real world rollover crash because:

• The test used by NHTSA is static rather than dynamic;
• The force measured for passage is less than that actually experienced in a rollover;
• The windshield, which breaks on the first roll in an actual crash, is left in place for the test and supplies about one-third of the measured strength of the roof in the test NHTSA uses.

With protections, rollovers are highly survivable crashes with low gravitational forces. The following measures would provide basic occupant protection in rollovers:

• A dynamic roof crush standard, which measures roof crush without the windshield in place;
• Safety belt pretensioners which trigger in a rollover crash;
• Improved seat structure to keep occupants in position during a roll, including seat belt anchors on the seat structure;
• Side impact head protection air bags which are triggered in a rollover crash and reduce the ejection of occupants;
• Roof injury protection to protect occupants in the event of contact with the roof structure;
• Improved door locks and hinges to keep doors from becoming ejection portals in a rollover.

A disproportionate share of the expected increases in fatalities Kahane found in his study came from deaths in rollovers. Improving rollover crashworthiness will make these crashes survivable for occupants of all sizes of vehicles.

V. Answers to NHTSA’s specific questions from the request

Above, we provide the context and broad themes that in many respects answer the questions posed in the agency’s rulemaking. In addition, we below briefly address each of the agency’s questions directly.

1. Is the safety impact [of the CAFE program] overstated or understated [by the NAS majority]?

   As our comments above make clear, we believe the NAS majority has greatly overstated the effects on safety of mandated improvements in fuel economy. The primary basis for their conclusion in this area, a study performed by Charles Kahane in 1997, was flawed in its approach and has been refuted by more recent work using more recent data. There is no evidence that raising fuel economy standards would cause additional traffic fatalities, and there is strong evidence that raising fuel economy standards for light trucks would reduce fatalities. In addition, the agency is long overdue in issuing rollover crashworthiness and aggressivity standards which would address key safety problems in the current fleet. These standards, combined with increased fuel economy standards, would together improve both safety and fuel economy.

2. Would the NAS’s proposed changes to CAFE reduce this safety penalty?

   Since there is no "safety penalty" to raising CAFE standards, the question is not entirely relevant. However, eliminating the bifurcated fleet system by combining light trucks and passenger vehicles in a single CAFE number for each manufacturer would have a positive impact on safety by improving fleet compatibility.

   Public Citizen is concerned about the NAS panel’s recommendation regarding an attribute-based system. We believe that breaking the fleet into weight categories and assigning separate fuel economy standards to each category could have the same negative impacts of the current split between light trucks and passenger cars: gaming by the manufacturers as they add or remove weight to vehicles in order to affect the performance of each fleet, and a system whereby the heavier class(es) of vehicles becomes a hazard to the lighter class(es). The current light truck loophole has produced vehicles like the PT Cruiser, which is classified as a truck despite the fact that it has no off-road or towing capabilities, and thereby escapes meeting the passenger car fuel economy standards.

3. Could CAFE standards be modified so that manufacturers are encouraged to achieve improved fuel economy through application of technology instead of through downsizing and downweighting?

   Given the results of the Society of Automotive Engineers’ study of the original CAFE standards and our knowledge of available technology catalogued by the UCS and implemented by manufacturers such as Honda, Public Citizen is convinced that manufacturers would for cost and marketing reasons design their vehicles so that the majority of fuel economy gains will be accomplished through technology rather than weight reduction. This is what manufacturers did in the late 1970s and early 1980s. Where weight reduction occurs, it will be in the heaviest vehicles, representing a safety benefit to society.

4. We note that the NAS found that if future weight reductions occur in only the heaviest of the light-duty vehicles, that can produce overall improvements in vehicle safety. If there would be adverse effects, how could they be mitigated?

There would be no adverse effects to weight reductions in our heaviest vehicles. Many light truck vehicles are substantially overpowered for the ways they are used and would still be able to meet consumers’ needs in lighter, less powerful incarnations.

As a final note, we ask that the agency adopt the multi-year standard-setting exercise it seems to contemplate in this rulemaking. If the agency sets standards each year, giving automakers just 18 months of notice, it will never be able to adopt standards that upgrade the performance of the US fleet.

1. The centerpiece of this research is the 1997 NHTSA study performed by Charles Kahane. We discuss the study at length below, but would like to point out here that it relies upon an unrealistic assumption about vehicle weight - that all vehicles would shed an equal amount of weight (100 lbs) - to reach its conclusions. Because of these unrealistic parameters, the study was clearly not designed to predict the likely consequences of future or past CAFE improvements and should not have been used in this way
2. National Research Council, Effectiveness and Impact of Corporate Average Fuel Economy (CAFE) Standards, (Washington, DC: National Academy Press, 2001) 29.
3. Minicars Inc, Research Safety Vehicle promotional material (Santa Barbara, CA 1978).
4. Conversations with Don Friedman and Carl Nash, January 2002.
5. American Iron and Steel Institute, "New Steels can help Vehicles Achieve Five-Star Crash Rating, Double Fuel Economy at no Additional Cost," (30 January 2002); available online at http://www.autosteel.org/press_release_output.php3?prjob_num=1222.
6. Edward Cohen, Letter to Senator John Kerry, December 19, 2002.
7. Sen. John Kerry, Congressional Record, Sept. 25, 1990, at S13696 (citing Ford).
8. Clarence Ditlow, Testimony before the Senate Committee on Commerce, Science, and Transportation, December 6, 2001, Washington, DC.
9. Union of Concerned Scientists, Drilling in Detroit, (Cambridge, MA:UCS Publications June 2001) 51, 53.
10. Adrian Lund, Testimony before the Senate Committee on Commerce, Science, and Transportation, January 24, 2002, Washington, DC.
11. Donald Friedman and Keith D. Friedman, "The Relationship between Safety and Fuel Economy," SAE Technical Paper Series 921055, (April-May 1992) 4.
12. Union of Concerned Scientists, Drilling in Detroit, (Cambridge, MA:UCS Publications June 2001).
13. Union of Concerned Scientists, Drilling in Detroit 18, Appendix B.
14. Union of Concerned Scientists, "Greener SUVs: A Blueprint for Cleaner, More Efficient Light Trucks," Summary available on the World Wide Web at http://www.ucsusa.org/vehicles/greener.SUVs.html
15. See 59 F.R. 33254, 33255 (June 8, 1994)
16. General Accounting Office, "Have Automobile Weight Reductions Increased Highway Fatalities?" GAO PEMD-92-1 (October 1991), 23-24.
17. R.M. Van Auken, J.W. Zellner, "An Assessment of the Effects of Vehicle Weight on Fatality Risk and Model Year 1985-98 Passenger Cars and 1985-97 Light Trucks," Dynamic Research Incorporated, DRI-TR-02-02 (February 2002), 4.
18. Marc Ross and Tom Wenzel, "An Analysis of Traffic Deaths by Vehicle Type and Model," U.S. Department of Energy LBNL-49675, Washington, DC (March 2002) 5-6.
19. David L. Greene, " Fuel Economy, Weight, and Safety: ‘It’s what you think you know that just isn’t so,’" Society of Plastics Engineers Automotive Composites Conference, Detroit MI (19 September 2001).
20. Keith Bradsher, "For the Megagrowth Family, Daimler to Offer a Bigger-Than-SUV," Feb. 21, 2001.
21. Hans Joksch, Vehicle Aggressivity: Fleet Characterization Using Traffic Collision Data (Ann Arbor. MI: University of Michigan Transportation Research Institute, February 1998)
22. Alexandra Kuchar, A Systems Modeling Methodology for Estimation of Harm in the Automotive Crash Environment (Cambridge, MA: Volpe National Transportation Systems Center, 2001) 10.
23. National Highway Traffic Safety Administration, Traffic Safety Facts 1999 (Washington DC: Government Printing Office 2000) 107-108. Figures include motorcycle and heavy truck occupants killed, but not pedestrians or bicyclists.
24. National Research Council, Effectiveness and Impact of Corporate Average Fuel Economy (CAFE) Standards, (Washington, DC: National Academy Press, 2001) 2-24.
25. National Highway Traffic Safety Administration, The Economic Impact of Motor Vehicle Crashes 2000, DOT HS 809 446 (Washington DC: Government Printing Office May 2002).

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