Document NG2bpZBz25ZYkVqOJ2YLJZE0y
ndustry Corporate Average Fuel Economy Status
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.......................... Actual CAFE performance plateau due to low fuel prices and shift to
..................................trueks and Lilly vehicles
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"Actual Performance Actual Standard ..."Agency Projected Standard
M l 2 2M 3 014 20 IS l 91* 2 0 1 / 010 M M 2020 2021 2022 2022 2024 2020
2016 MY NHTSA CAFE performance trend is a cause for concern. EPA GHG performance trend is similar. * Better than standard performance has shifted to lower than standard performance. Low gasoline prices, muted demand for hybrids and other advanced vehicles,
increasing shift to trucks and utility vehicles affecting performance and standards.
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Sierra Club v. EPA 18cv3472 NDCA
Tiers 8&9
ED 002061 00082339-00001
Rational Consumer's Perspective on Fuel Savings
Average CAFE Fuel Economy
Annual Fuel Cost
Weekly Savings*
2017 --4 2021 32 mpg 36 mpg
$1032
$917
$2.20
2021 --- 2025 36 mpg 43 mpg
$917
$768
$2.90
2017-21 and 2021-25 MY Fuel Economy Standard improvement is worth a cup of coffee per week to the average consumer, yet cost $$ thousands up front.
This could be a reason for the less than 3% consumer take rate of electrification in the market place.
*Assumptions: 15,000 miles per year from EPA fuel economy label for annual fuel cost and savings, $2.20 per gallon, Draft TAR CAFE predicted fuel economy standards.
18cv3472 NDCA
Tiers 8&9
ED 002061 00082339-00002
Rational Consumer's Perspective on Fuel Savings Battery Electric Vehicle (BEV) vs. Gasoline
Sierra Club v. EPA 18cv3472 NDCA
Tiers 8&9
ED 002061 00082339-00003
Rational Consumer's Perspective on Fuel Savings Plug-In Hybrid Electric Vehicle (PHEV) vs. Gasoline
Sierra Club v. EPA 18cv3472 NDCA
Tiers 8&9
ED 002061 00082339-00004
Market Demand for Fuel Economy Technology
1975-2016 industry Fleet Fuel Efficiency
Fuel Efficiency
1970
1980
1990
2000
Model Year
2010
2020
Source: 2016 EPA Emi Economy Trends Report {Appendix K}
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Historical Demand for Fuel Efficiency
Agency data shows industry fuel efficiency has improved 1.6% per year from 1975-2016.
Achieving current standards require 4-5% per year for 2012-2025.
Revisions are needed in the program that would allow time for:
Continued innovation to lower the costs of technology.
Implementing methods to promote technology: Financial and non-financial incentives (e.g., HOV Lanes etc.). Put needed infrastructure in place.
Demand for electrification to develop in the market versus OEMs forcing electrification.
18cv3472 NDCA
Tiers 8&9
ED 002061 00082339-00005
ndustry Comments on Revised Determination
1. Appropriateness of 2022-25MY Standards The level of technology modeled by the Agencies is insufficient to meet the standards. More technology is needed for compliance and this level of technology is misaligned with market realities. A fully informed rulemaking is needed for 2022-25MY standards.
2. Consideration of 2021 MY Standards Assuming 2021 MY compliance ignores that industry is challenged in 2016-17MY despite implementing many of the agency-suggested technologies. Reexamination of 2021 MY requirements is appropriate to determine if amendment of those standards could achieve the goals of harmonization.
3. Use of Alternative Methodologies and Modeling by EPA DOT'S modeling system of Autonomie full vehicle simulations and CAFE Compliance and Effects (Volpe) model is more transparent and better accounts for real world factors than EPA's models. Ensuring that the Volpe and Autonomie models contain the most accurate inputs and analyses would be a more cost-efficient use of resources rather than creating yet another model.
Sierra Club v. EPA 18cv3472 NDCA
Tiers 8&9
ED 002061 00082339-00006
