III.   IMPACT OF OTHER FEDERAL MOTOR VEHICLE STANDARDS ON LTV FUEL ECONOMY

Introduction

The Act requires that fuel economy standards be set at the maximum feasible level after taking into account the following criteria:  technological feasibility, economic practicability, the impact of other Federal Motor Vehicle Standards on fuel economy, and the need of the Nation to conserve energy.  This section discusses the effects of other government regulations on model year (MY) 2005-2007 light truck fuel economy.

Baseline weights

The average test weight (curb weight plus 300 pounds) of the light truck fleet in MY 2001 was 4,501 pounds.  The average test weight for General Motors, Ford, and DaimlerChrysler light trucks subject to the standard for MY 2001 was 4,627 pounds.  The average weight for these three manufacturers for MY 2007 is [   ] pounds.  Thus, overall, the three largest manufacturers of light trucks expect weight to increase slightly over the time period.  The change in weight includes all factors, such as changes in the fleet mix of vehicles, required safety improvements, voluntary safety improvements, and other changes for marketing purposes. 

Weight Impacts of Required Safety Standards

The National Highway Traffic Safety Administration (NHTSA) has issued a number of proposed and final rules on safety standards that are proposed to be effective or are effective between the MY 2001 baseline and MY 2007.  These have been analyzed for their potential impact on light truck fuel economy weights for MY 2005-2007:

1. FMVSS 138, tire pressure monitoring system (Final Rule)

2. FMVSS 139, tire upgrade (Proposed)

3. FMVSS 201, occupant protection in interior impact (Final Rule)

4. FMVSS 202, head restraints (Proposed)

5. FMVSS 208, occupant crash protection (Final Rule)

6. FMVSS 225, child restraint anchorage systems (Final Rule)

7. FMVSS 301, fuel system integrity (Proposed)

FMVSS 138, tire pressure monitoring system

As required by the Transportation Recall Enhancement, Accountability, and Documentation (TREAD) Act, NHTSA is requiring a Tire Pressure Monitoring System (TPMS) be installed in all passenger cars, multipurpose passenger vehicles, trucks and buses that have a Gross Vehicle Weight Rating of 10,000 pounds or less, effective in November 2003.  We estimate the weight that would be added consists of electrical parts that would not weigh more than half a pound  (0.23 kilograms or less). 

FMVSS 139, tire upgrade

The Transportation Recall Enhancement, Accountability, and Documentation Act of 2000 mandated a rulemaking proceeding to revise and update our safety performance requirements for tires.  A Preliminary Economic Assessment of the proposed tire upgrade indicated there would be added cost for the improved tires but no increased weight.

FMVSS 201, occupant protection in interior impact.

This standard specifies requirements to afford protection for occupants from impacts with interior parts of the vehicle.  The new amendment relates to upper pillars, front and rear headers, the side roof rails and other upper interior parts.  It applies to passenger cars and to multipurpose vehicles, trucks, and buses with a GVWR of 10,000 pounds (4,536 kilograms) or less.  Additional padding could be added or pillars could be redesigned to pass the upgraded standard.  We estimate the average weight gain would be 7.5 pounds (3.4 kilograms) for the light trucks affected by this fuel economy proposal.

FMVSS 202, head restraints.

This proposed regulation would improve front seat head restraints in passenger cars, pickups, vans, and utility vehicles and require head restraints in the rear outboard positions.  Because many pickup trucks and some vans do not have back seats, the average weight increase for this standard is lower than for automobiles.  We estimate the average weight gain across light trucks would be 4.3 pounds (1.94 kilograms).

FMVSS 208, occupant crash protection.

This rule amends our occupant crash protection standard to require that future air bags be designed to create less risk of serious air bag-induced injuries than current air bags, particularly for small women and young children; and provide improved frontal crash protection for all occupants, by means that include advanced air bag technology.  Additional weight would come from sensors, switches, indicators, and associated electrical equipment.  We estimate the average weight gain would be 3.4 pounds (1.54 kilograms).

FMVSS 225, child restraint anchorage systems.

The Final Economic Assessment (February 1999) for FMVSS 213 and 225 estimates the additional weight for improved anchorages would be less than 1 pound (0.45 kilogram).

FMVSS 301, fuel system integrity.

This proposal would amend the testing standards for rear end crashes and resulting fuel leaks.  Many vehicles already pass the more stringent standards, and those affected are not likely to be pick-up trucks or vans.  It is estimated that weight added will be only light-weight items such as a flexible filler neck.  We estimate the average weight gain across this vehicle class would be 0.24 pounds (0.11 kilograms). 

The next two tables summarize estimates made by NHTSA and the truck manufacturers regarding the weight added to institute these standards between MY 2001 and MY 2007.  Table III-1 presents the actions that are required of the manufacturers by changes in the safety standards.  Table III-2 presents voluntary actions planned by the manufacturers, which do not have to be considered in setting the fuel economy standards.  As is true in other sections of this report, figures in [  ] are confidential.

Table III-1
Weight additions due to required FMVSS regulations

1DaimlerChrysler estimated [  ] pounds, with a CAFE impact of [  ] mpg.  This figure includes weight increases from many regulations lumped together: 225, 202, 301 (which will be in place around Model Year 2005-07), Offset Frontal Protection, Improved Door Latch Integrity, and Dynamic Roof Crush (which may not be in place).  The [  ] pounds shown for FMVSS 208 must include some type of structural upgrade, which might occur with an offset frontal protection rule, but in our opinion would not be part of the advanced air bag rule. 

²Ford made a weight estimate of [  ] pounds which included strengthening to improve FMVSS 208 protection, NCAP, and offset frontal protection.

Table III-2
Weight additions due to voluntary safety improvements

² See footnote 2 from Table III-1.

³ In their response to "question 8" of the information request,  GM states the overall addition will be [  ] pounds for a full-sized truck or [   ] pounds for a full-sized van, with an effect of [    ] mpg or [    ] mpg.

⁴ Includes Frontal NCAP, Side NCAP, Rollover Ratings, Offset Frontal Protection, Head Restraint Ratings, and Bumper Performance.

NHTSA’s estimates come from Preliminary and Final Regulatory Evaluations for the respective standards.  Estimates from the vehicle manufacturers come from NHTSA’s requests for information and are confidential.  The Japanese manufacturers gave either no information or very generalized information.  Information from other manufacturers was sometimes specific but often combined several categories. 

Honda stated that they would be able to minimize additional weight due to Federal safety requirements if they were given sufficient lead time.  Toyota’s entire response is given in the tables above.  Nissan discussed known issues in fuel economy trade-offs without offering any specific or new information.  DaimlerChrysler estimates that FMVSS 208 changes will add [    ] pounds on the average, for a CAFE impact of [   ] mpg.  This effect will hold steady between 2005 and 2010.  They estimate that FMVSS 201 will add [  ] pounds on the average, for a minimal CAFE impact.  General Motors gave specific information on weights for various parts, all of which were safety related, but most of which were not required for the standards.  Ford estimates that changes to FMVSS 208 (occupant crash protection) will add [   ] pounds, for a CAFE impact of [    ] mpg.  Much of this may be due to strengthening to improve NCAP and frontal-offset crash ratings and is shown in the right hand column of Table III-2.

In summary, NHTSA estimates that weight additions required by FMVSS regulations that will be effective between the MY 2001 fleet and MY 2007 fleet to average about 17 [JW5] pounds[1].  The agency has not used weight reduction as one of the technologies available to improve fuel economy.  The agency has taken the manufacturer’s predicted weights for MY 2005-2007 and made no changes in them.  Thus, whatever assumptions the manufacturers have made for weight increases due to new safety standard requirements, or whatever voluntary safety improvements the manufacturers are planning, can occur without the manufacturers being penalized by having to reduce weight to meet a fuel economy standard. 

The Impact of Emission Standards 

1. Tier II Requirements

   On February 10, 2000, the Environmental Protection Agency (EPA) published a final rule (65 FR 6698) establishing new federal emissions standards for passenger cars and light trucks.  These new emissions standards, known as Tier 2 standards, are designed to focus on reducing the emissions most responsible for the ozone and particulate matter (PM) impact from these vehicles - nitrogen oxides (NO[  ]) and non-methane organic gases (NMOG), consisting primarily of hydrocarbons (HC) and contributing to ambient volatile organic compounds (VOC).  For new passenger cars and light trucks, rated at less than 6000 pounds GVWR, the Tier 2 standards phase-in beginning in 2004, and are to be fully phased-in by 2007.

   During the phase-in period from 2004-2007, all passenger cars and light trucks not certified to the primary Tier 2 standards must meet an interim standard equivalent to the current National Low Emission Vehicle NLEV standards for light duty vehicles.  In addition to establishing new emissions standards for vehicles, the Tier 2 standards also establish standards for the sulfur content of gasoline.

   When issuing the Tier 2 standards, EPA responded to comments regarding the Tier 2 standard and its impact on CAFE by indicating that it believed that the Tier 2 standards would not have an adverse effect on fuel economy.

2. Onboard Vapor Recovery

   On April 6, 1994, EPA published a final rule (59 FR 16262) controlling vehicle-refueling emissions through the use of onboard refueling vapor recovery (ORVR) vehicle-based systems.  These requirements applied to light-duty vehicles beginning in the 1998 model year, and phased- in over three model years.  The ORVR requirements also apply to light-duty trucks with a GVWR of 6,000 pounds or less beginning in model year 2001 and phasing-in over three model years.  For light-duty trucks with a GVWR of 6,001-8,500 lbs, the ORVR requirements first apply in the 2004 model year and phase-in over three model years.

   The ORVR requirements impose a weight penalty on vehicles as they necessitate the installation of vapor recovery canisters and associated tubing and hardware.  However, the operation of the ORVR system results in fuel vapors being made available to the engine for combustion while the vehicle is being operated.  As these vapors provide an additional source of energy that would otherwise be lost to the atmosphere through evaporation, the ORVR requirements do not have a negative impact on fuel economy.

3. Supplemental Federal Test Procedure

    On October 26, 1996, EPA issued a final rule (61 FR 54852) revising the tailpipe emission portions of the Federal Test Procedure (FTP) for light-duty vehicles (LDVs) and light-duty trucks (LDTs).  The revision created a Supplement Federal Test Procedure (SFTP) designed to address shortcomings with the existing FTP in the representation of aggressive (high speed and/or high acceleration) driving behavior, rapid speed fluctuations, driving behavior following startup, and use of air conditioning.  The SFTP also contains requirements designed to more accurately reflect real road forces on the test dynamometer.  EPA chose to apply the SFTP requirements to trucks through a phase-in.  Light-duty trucks with a gross vehicle weight rating (GVWR) up to 6,000 lbs were subject to a three-year phase-in ending in the 2002 model year.  Heavy light-duty trucks, those with a GVWR greater than 6,000 lbs but not greater than 8,500 lbs, are subject to a phase-in schedule in which 40 percent of each manufacturer’s production must meet the SFTP requirements in the 2002 model year, 80 percent in 2003, and 100 percent in the 2004 model year.

   The 2004 model year represents the final phase-in year for light trucks subject to CAFE standards.  Neither Ford nor GM indicated in their comments to the MY 2004 NPRM that the SFTP would have any impact on their ability to meet the proposed 2004 standard.

4. In their comments, DaimlerChrysler claimed that changes in the EPA test procedure would have a negative effect on the fuel economy values for light trucks.

   NHTSA has, from time-to-time, included the effects of EPA’s changes to the test procedures when setting CAFE standards for light trucks.  However, in this case, EPA has determined that the net effect on fuel economy for the recent test procedure changes is near zero. Consequently there is no need to adjust the CAFE standards for these test procedure changes.

   EPA’s decision was based on the joint recommendation of the Alliance and AIAM that the net effect of all the test procedure changes was near zero and that "no adjustment" was appropriate[2].  EPA considered the effects of four test changes: single-roll electric dynamometer with full-speed load simulation, elimination of the 10% air conditioning load factor, elimination of the 5,500 maximum test weight for cars, and improved test equipment. While some changes decreased measured fuel economy, others raised it; with the net result of a near zero effect.  This decision was based on the total fleet which is a mix of front wheel drive and rear wheel drive cars and trucks.

   Considering trucks alone is not likely to change that decision.  Trucks, as a sub-class, have a larger mix of rear wheel drive vehicles than the combined fleet.  This would lead to slightly increased effect of the single roll dynamometer and thereby slightly lower measured fuel economy.  However, the truck sub-class also has higher road load horsepower than the combined fleet.  This would lead to slightly higher effects due to the elimination of the 10% air conditioning load and thereby slightly higher measured fuel economy.  The net effect of the combined test procedure changes on the truck sub-class is still expected to be near zero.

5. California Air Resources Board LEV II

   The State of California Low Emission Vehicle II regulations (LEV II) will apply to passenger cars and light trucks in the 2004 model year.  The LEV II amendments restructure the light-duty truck category so that trucks with gross vehicle weight rating of 8,500 pounds or lower are subject to the same low-emission vehicle standards as passenger cars.  LEV II requirements also include more stringent emission standards for passenger car and light-duty truck LEVs and ultra low emission vehicles (ULEVs), and establish a four-year phase-in requirement that begins in 2004. 

   The agency notes that compliance with increased emission requirements is most often achieved through more sophisticated combustion management.  The improvements and refinement in engine controls to achieve this end generally improve fuel efficiency and have a positive impact on fuel economy.

   In summary, the agency believes there will be no impact from emissions standards on light truck fuel economy between the baseline MY 2001 and MY 2007 fleets.