NHTSA’s Fuel Economy Impact Statement Should Be Revised to Be More Informative to Decision-Makers and Public

Oct. 30, 2009

NHTSA’s Fuel Economy Impact Statement Should Be Revised to Be More Informative to Decision-Makers and Public

Statement of Lena Pons, Policy Analyst, Public Citizen*

* Note: Lena Pons testified at today’s hearing.

The National Highway Traffic Safety Administration’s (NHTSA) proposed fuel economy standards would have the most significant positive effect on climate change of any action taken by the U.S. government to date. They would raise average fuel economy for the combined fleet of passenger cars and light trucks to 34.1 miles per gallon in 2016. No single policy can solve the climate change problem, but fuel economy standards are critical to cutting emissions in the transportation sector, which account for a third of emissions in the U.S.

 Today, NHTSA held a public hearing on its Draft Environmental Impact Statement (DEIS). The DEIS is supposed to inform decision-makers and the public about the relative impacts on greenhouse gas emissions from a range of efficiency increases in light-duty motor vehicles. It does not serve this function. The statement fails to consider all reasonably foreseeable actions to control emissions from light-duty transportation and fails to place the conclusions in a context that adequately informs the public about the differences between alternatives.   

The analysis concludes that global warming cannot be stopped by five years of fuel economy standards, trivializing the real, significant impact of the standards. It is obvious that reducing motor vehicle emissions alone will not stop global warming; we must reduce other sources of greenhouse gases as well. But NHTSA should have assessed the contribution that reductions in motor vehicle emissions could make. Instead, NHTSA estimates that in 2100, the 2012-2016 standards would reduce global greenhouse gas emissions by just 0.4 to 0.8 percent, without noting that U.S. motor vehicles are responsible for about 4 percent of global greenhouse gas emissions. Placed in this context, the reductions estimated by NHTSA are significant – 10 to 20 percent of motor vehicle emissions – as is the difference between the alternatives. 

NHTSA also failed in its charge to produce a document that is written in plain language and can be readily understood by decision-makers and the public. The DEIS is a long, complex document that is inaccessible and daunting to a layperson. For example, NHTSA discusses the annual motor vehicle CO2 reductions from 2012-2100 in terms of equivalent reductions from coal-fired power plants. This is no more meaningful or accessible to the public than discussing motor vehicle emissions directly. Presenting the impacts more clearly would significantly improve the document’s usefulness.