Simanaitis Says

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WHAT WITH the Trump administration’s gutting, some would say streamlining, the U.S. Environmental Protection Agency, let’s examine some environmental and economic aspects of automobile regulations in the United States. This is a broad and complex topic, but I hope to clarify some of the basics.

Much discussed is the federal government’s requirement that automakers achieve a sales-weighted average of 54.5 mpg for cars and light trucks in Model Year 2025. “54.5 Mpg and the Misinformed” at SimanaitisSays gave some details. As cited there, the 54.5 mpg is to be based on raw, unconditioned data, not the numbers posted on new-car Monroney stickers.

Indeed, what with adjustments for advanced-technology credits and car/light truck “footprints,” 54.5 mpg would equate to a real fleet average of about 39 mpg. To put this in perspective, the 2016 standard delivered around 27.5 mpg in the real world.

Also, federal regulations with long-term phase-ins often have “offramps,” Midterm Evaluations to allow adjusting for changing conditions. In July 18, 2016, Automotive News cited a Technical Assessment Report issued jointly by the EPA, the National Highway Traffic Safety Administration and the California Air Resources Board: “Automakers have all the tools at their disposal to meet 54.5 mpg corporate average fuel economy targets for the 2025 Model Year, but buyer preferences for SUVs and trucks make it likely that the industry will fall short of that number.”

Let’s stress what the three agencies concluded: The coming 54.5 mpg regulation wasn’t considered a technical challenge, it was a marketing challenge.

“The report,” Automotive News continued, “also says that automakers have been able to meet the current regulations for about the same cost or even less than the government projected in 2012.”

Indeed, the three agencies concluded that 54.5 mpg by 2025 wasn’t considered to be a particular economic challenge to the automakers. Again, marketing was the problem.

The article noted that the EPA would make a final determination on the 2022 to 2025 Model Year regulations by April 1, 2018. However, matters have taken an overtly political turn, not that clean-air issues have avoided this in the past….

An overview of Midterm Evaluation details is given in an EPA release updated March 15, 2017.

Briefly, on November 3, 2016, Gina McCarthy, then EPA head, issued a Proposed Determination that 54.5 mpg should stand. She reinforced this on January 12, 2017, with a Final Determination. Let’s stress that this Final Determination was issued more than 14 months ahead of “by April 1, 2018.”

Can you say, “blind-sided”?

In particular, the Final Determination noted, “EPA’s regulations establish April 1, 2018, as the latest date for such a determination, but otherwise do not constrain the Administrator’s discretion to select an earlier determination date. The Administrator is choosing to make the Final Determination now, recognizing that long-term regulatory certainty and stability are important for the automotive industry and will contribute to the continued success of the program, which in turn will reduce emissions, improve fuel economy, deliver significant fuel savings to consumers, and benefit public health and welfare.”

But the opera ain’t over til….

Then, on March 15, 2017, Scott Pruitt, EPA Administrator, and Elaine Chao, Department of Transportation Secretary, announced that “EPA intends to reconsider the Final Determination, issued on January 12, 2017, that recommended no change to the greenhouse gas standards for light duty vehicles for Model Years 2022–2025. EPA now announces it will reconsider that determination in coordination with NHTSA.”

In October 2016, long before all this hit the fan, I put my own oar in the water. (Mix, metaphor! Mix!) As noted there, I still recognize the hard-working automotive engineer. Or is it the shortsighted people fueling their SUVs on cheap gas? Or it is the rascals in Washington, D.C.?

There’s more automotive air clearing yet to come here at SimanaitisSays. In particular, what about our traditional polluting trio HC, CO and NOx and that later culprit CO2? Regardless of where one stands on these matters, it’d helpful to have facts. ds

© Dennis Simanaitis,, 2017


  1. Mike B
    March 21, 2017

    Traditional v. CO2 – very significant. Traditional air pollutants (the big 3, plus a few others that are less mobile source and more industrial) are typically controlled by optimizing combustion for aftertreatment (catalysts, filters, etc.). That’s still important in LA, which continues to have the worst air quality in the country. That commonly reduces fuel economy, though with modern systems not by much.

    CO2 (and GHGs in general) are mainly related to the amount of fuel that passes through the gas generator aka engine. Carbon in = carbon out, essentially. So improving fuel economy is a major piece of controlling them. If you want to improve fuel economy, you have to improve the efficiency of combustion and reduce power demand (add lightness, etc.), but if that requires higher combustion temps it makes more NOx. Hybrids are a different story, and they work despite the weight penalty (example: my Prius).

    You’re right about the marketing issue, though: with cheap gas, you almost can’t give away high-mileage cars. Great deals to be had on Prius and even (my favorite in the current market) Mazda 3. Everybody wants a truck, which messes up the fleet economy. I can easily see why the carmakers with lots of trucks (not entirely US companies, btw – have you seen the size of what Toyota’s selling these days?) would want some relief, and the current crowd in charge won’t waste any time giving it to them.

    • simanaitissays
      March 21, 2017

      Yep. You’ll see several of your thoughtful points reappearing tomorrow in Part 2.

  2. carmacarcounselor
    March 21, 2017

    I was amused by an exchange between “liberal” provocateur Bill Maher and an EPA official in the opening interview for “Real Time” recently where they both decried the public expectation that “technology will create a great machine that eats CO2.” Come on guys! We already have it! It’s called FORESTS, and we’re destroying it!

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