FC: Replies to "Raise fuel efficiency standards, kill Americans?"

From: Declan McCullagh (declanat_private)
Date: Tue Mar 12 2002 - 21:10:30 PST

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    Previous Politech message:
    "Raise fuel efficiency standards, kill Americans?"
    Naturally I will forward a reply from the folks at Cato.
    From: Fred Heutte <phredat_private>
    To: <declanat_private>
    Date: Tue, 12 Mar 2002 19:56:03 -0800
    Subject: Re: FC: Raise fuel efficiency standards, kill Americans?
    As you may know, Declan, the fuel efficiency/safety debate in the current
    Senate energy bill fight is not as one-sided as Cato would prefer to believe.
    There is credible evidence that raising CAFE standards would have *no*
    effect on safety, or possibly even improve it.
    In fact, the trends in auto safety and efficiency have been going in
    opposite directions over the last four decades, as noted in a paper
    by David Greene from Oak Ridge National Lab at a California vehicle
    efficiency workshop last September.  He presented a simple chart showing
    auto fleet fuel efficiency and fatalities from the late 1960s to now.
    In general, travel has become safer over that period, while fuel
    efficiency rose from 1975 to 1985 and has since stalled.  He concludes:
       From 1967-99, there is NO correlation between
       light-duty vehicle mpg and highway fatalities.
       ZERO, NONE.
    Years of research and dozens of papers have shown that factors leading
    to increased collisions, injuries and fatalities have to do with
    vehicle weight *differentials* and driving speed *differentials*
    (particularly for highway driving).
    In that sense, the greater number of "light trucks" (SUVs in particular)
    has increased the probability and severity of crashes and injuries, as
    has reduced regulation of highway driving speeds.  When speed differentials
    on highways are 20 mph and greater -- as they are on virtually all major
    highways these days (at least ones that aren't in rush hour gridlock!) --
    this means greater potential for collisions.
    But the more important issue for the moment is vehicle weights.  Opponents
    of increasing CAFE fuel efficiency standards have used this issue in the
    most transparently slipshod way.  The National Academy of Sciences report
    on CAFE last year -- drafted by a lopsidedly industry-leaning panel and
    then revised *after* peer review when the auto makers complained that it
    still wasn't the result they wanted -- refers primarily to just *one*
    study out of literally dozens that have been done on the issue, and it
    mis-states the conclusions of that study.
    The Union of Concerned Scientists "Drilling in Detroit" report last summer
    concluded, on the other hand:
       Automakers can utilize a variety of design and technology
       options for reducing fuel consumption. The only one that could
       have a significant impact on occupant safety during a crash,
       however, is vehicle weight reduction. The auto industry has
       argued that weight reduction compromises safety and that public
       policy should not encourage further fuel economy improvements,
       since they would lead to vehicle weight reduction (as they did
       in the period from 1977 through 1985).
       Contrary to this assumption, the relationship between safety
       and the weights of vehicles in the fleet is neither direct nor
       obvious. The factors that affect public safety on the road are
       so many and varied that actual road casualties can be only
       generally predicted. In particular, the concern over the safety
       of weight reduction is driven by the poor safety performance of
       the lighter vehicles in the fleet. This performance is
       misleading since it is partly due to two factors: (1) the
       lightest vehicles in the fleet tend to be the least expensive
       and thus incorporate the fewest safety advances, and (2)
       lighter vehicles tend to be driven by younger, more aggressive
       Vehicle weight reduction is a reasonable strategy for fuel
       economy improvements if it is applied most aggressively to the
       SUVs, minivans, and pickup trucks used as private passenger
       vehicles. In addition, these weight reductions can be applied
       in combination with obvious and inexpensive safety
       Principles of elementary physics imply that in a two-vehicle
       collision, a heavier vehicle should be safer than a lighter
       one. In practice, however, that is not necessarily always the
       case. In a two vehicle crash, for example, if the heavier
       vehicle is struck in the side by the front of a lighter
       vehicle, the occupants of the heavier vehicle may be more at
       risk. Estimates show that a 10 percent reduction in vehicle
       weight could result in a 3 to 7 percent increase in fuel economy
       (NRC 1992; OTA 1991).
    David Greene of ORNL had a parallel view in his workshop report:
       The majority view on fuel economy and safety is based on two fallacies.
       1. Because I am safer in a heavier car, everyone
          would be safer if all cars were heavier.
          From a societal perspective, there is a "larger
          vehicle" externality.
       2. Existing studies adequately account for
          spurious correlations with driver and
          environmental characteristics.
          The more carefully one controls confounding
          factors, the more the "weight effect" fades away,
          or even reverses.
    Ann Mesnikoff of the Sierra Club testified to the Senate last December
    and pointed out that an overlooked factor is that SUVs are inherently
    less safe than other passenger vehicles due to rollover and other
       The current system of separate standards for cars and trucks,
       which has allowed manufacturers to move heavily into SUV
       production, compromises traffic safety. Light trucks pose
       safety dangers to their owners and occupants. SUVs are four
       times more likely to roll over in an accident. Rollovers
       account for 62% of SUV deaths, but only 22% in cars. Yet
       automakers fought new standards protecting occupants in
       rollover accidents. According to a study by the National Crash
       Analysis Center, an organization funded by both the government
       and the auto industry, occupants of an SUV are just as likely
       as occupants of a car to die once the vehicle is involved in an
       accident. This is in part because of their higher rollover
    When Andrew Card, now chief of staff in the Bush White House, was
    a newly minted executive at General Motors fresh from his stint running
    the American Automobile Manufacturers Association (AAMA), he gave
    a speech to an aluminum industry gathering where he claimed
    that the auto industry could do better on fuel efficiency and safety
    than government regulation.
    The fact of the matter is, this simply isn't so.  The auto industry
    started improving fuel efficiency when CAFE went into effect in the
    1970s, and stopped when CAFE stopped going up, and spent a great deal
    of effort in the 1990s to prevent it from rising from current levels.
    Aggregate fleet efficiency for the 2001 model year was LESS THAN that
    of the 1981 fleet.  It is incredible to think that with all the
    advances in auto technology during the last 20 years, somehow they
    just couldn't come up with anything for getting better gas mileage.
    Likewise, safety has improved only when the car manufacturers have
    been pushed by legislation and regulation.
    The question of whether increased CAFE standards would have an effect
    on safety is certainly a mandatory one to address.  But there is no
    question that the answers have been totally politicized, and that the
    real science and economics around this issue have been obscured by
    political handwaving.
    We *should* want both increased fuel efficiency and more safety.  There
    are tradeoffs, as Senator Levin said in his floor speech in the Senate
    today, but his further implication that this is a zero-sum game is
    simply incorrect.  We can find a way to do both, and the best guide
    is our own history between 1975 and 1985, when fuel efficiency and
    safety *both* significantly improved.
    Energy Coordinator
    Oregon Sierra Club
    Date: Tue, 12 Mar 2002 18:47:20 -0700 (MST)
    From: <politechat_private>
    To: Declan McCullagh <declanat_private>
    Subject: Re: FC: Raise fuel efficiency standards, kill Americans?
    On Tue, 12 Mar 2002, Declan McCullagh wrote:
     > "Environmentalists who supported an expansion of CAFE standards for
     > cars and light trucks are allowing their hostility to energy use to
     > override their common sense.  For instance, the National Academy of
     > Sciences reported last year that the current standards are directly
     > responsible for the deaths of 1,300 - 2,600 motorists a year.  That's
     > because automakers find that the cheapest way of incr easing fuel
     > efficiency is to reduce the size and weight of the cars they sell,
     > making them more dangerous to motorists in a crash. Dramatically
     > expanding CAFE standards would accelerate this trend and would
     > directly result in the deaths of hundreds, if not thousands of
     > Americans.
    Let me see if I have this straight.  Reducing emissions is a bad idea
    because cars will become smaller, and therefore offer their occupants less
    protection when they're hit by some idiot in a massive SUV.  And the
    problem is the *small* cars?
    You know, taxes on gasoline cause some people to ride bikes.  This tax is
    directly responsible for X deaths per year, since if the cyclists had been
    in a gas guzzling SUV, they'd have been better protected.
     > While the costs of expanding CAFE standards is steep, the benefits
     > are ephemer al.  Expanded standards certainly wouldn't reduce foreign
     > oil imports.  For instance, since the CAFE standards were first
     > introduced, the average fuel economy more than doubled for new cars
     > and grew by more than 50 percent for new light trucks, but imported
     > oil has increased from 35 to 52 percent of U.S. consumptio n. Reducing
     > oil demand would remove the most expensive oil sources from the mar
     > ket first, and foreign oil is the cheapest oil supply source in the
     > world. Dome stic producers, not foreign oil producers, would be hit
     > hardest if gasoline demand were to decline.
    I especially like the reasoning that the primary motivation for emissions
    controls is to reduce oil exports.  Silly me, I thought we were trying to
    reduce emissions, with the bonus of curbing consumption.  However, the
    observation that domestic oil producers would be hardest hit certainly
    clears up why the the increase didn't get very far in the senate.
    Date: Tue, 12 Mar 2002 20:36:03 -0500
    From: Jamie McCarthy <jamieat_private>
    Subject: Re: FC: Raise fuel efficiency standards, kill Americans?
    To: declanat_private
    declanat_private (Declan McCullagh) writes:
     > For instance, the National Academy of Sciences reported last
     > year that the current standards are directly responsible for the
     > deaths of 1,300 - 2,600 motorists a year.
    This is yet more CATO propaganda, Declan, and you're doing your
    readers a disservice by disseminating it uncritically.  The truth
    took me about twenty minutes to find.
    Here's the National Academy of Sciences press release summarizing
    their report:
        "But one risk of downsizing is that smaller cars involved in
        crashes with larger vehicles tend to have higher numbers of
        fatalities.  The committee estimated that the downsizing of
        automobiles in the 1970s and 1980s -- whether a result of CAFE
        standards or other market-driven needs -- may have contributed
        an additional 1,300 to 2,600 fatalities in 1993.  However, this
        area is quite controversial among analysts and the report
        includes a dissenting opinion written by two committee
        members.  They believe that the relationship between fuel
        economy and safety is not yet fully understood, and a
        reduction in vehicle weight need not adversely affect safety.
        The committee feels more analysis in this area is warranted
        and calls on the National Highway Traffic Safety
        Administration to conduct further research."
    Look at the language.  "Estimated"... "may have"... "contributed"...
    "controversial"... "dissenting opinion"... this couldn't be more
    hesitant and qualified.
    In fact the report itself says at the start of its chapter 2:
        "Isolating the effects of CAFE from other factors affecting
        U.S. light-duty vehicles over the past 25 years is a difficult
        analytical task."
    Are cars lighter now than they were in 1976 because of CAFE?
    Because people prefer smaller cars?  Or just because times are tight
    and people can only afford smaller cars?  The NAS refuses to
    On the page where the report references the "1,300 to 2,600
    fatalities" figure, the word "CAFE" does not even appear!  The NAS
    is simply playing a game of what-if with car weight:
        "The April 1997 NHTSA analyses allow the committee to reestimate
        the approximate effect of downsizing the fleet between the
        mid-1970s and 1993.  In 1976, cars were about 700 lb heavier
        than in 1993;  light trucks were about 300 lb heavier, on
        average.  An increase in mass for cars and light-duty trucks on
        the road in 1993, returning them to the average weight in 1976,
        would be estimated to have saved about 2,100 lives in car
        crashes and cost about 100 fatalities in light-truck crashes.
        The net effect is an estimated 2,000 fewer fatalities in 1993,
        if cars and light trucks weighed the same as in 1976.  The
        95 percent confidence interval for this estimate suggests that
        there was only a small chance that the safety cost was smaller
        than 1,300 lives or greater then 2,600 lives."
    You can trust the statistical hypothetical or not (read the report
    for more details on how it's drawn).  But CAFE is nowhere
    assigned responsibility for these numbers, and the NAS
    _explicitly_ refuses to draw such a connection.
    The Competitive Enterprise Institute picked this up and ran with it.
    They ran a poll in which they dishonestly summarized those findings
    and then asked people, basically, "would you still support CAFE now
    that you know it kills thousands of people"?  Forty-eight percent
    still said "yes" (!) but they ran a story in National Review calling
    this a victory over the evil federal regulators and so on.
    CEI at least kept a tenuous grip on reality, always carefully
    sticking to the weasel-words "contributed to" -- which if you think
    about it carefully disclaims any knowledge of the magnitude of the
    But CATO owes you and your readers an apology for an outright lie;
    there is simply no way to reconcile the actual NAS report with the
    words CATO attributed to them:
        "the current [CAFE] standards are directly responsible for the
        deaths of 1,300 - 2,600 motorists a year."
    Going to primary sources is always important when your news is being
    fed to you by "think-tanks" which have a vested interest in
    spreading anti-regulatory, pro-corporate propaganda.  You can read
    the NAS report here:
    The "1,300 to 2,600 lives" reasoning starts here:
    And the eight-page, carefully reasoned dissenting opinion starts here:
        "Improving fuel economy could be marginally helpful, beneficial,
        or have no impact on highway safety.  The conclusions of the
        majority of the committee stated in Chapters 2 and 4 are overly
        simplistic and at least partially incorrect.  [...]
        "The first [fallacy] results from the very intuitive, thoroughly
        documented (e.g., Evans, 1992, chapter 4, and many others), and
        theoretically predictable fact that in a collision between two
        vehicles of unequal weight, the occupants of the lighter vehicle
        are at greater risk.  The fallacy lies in reasoning that,
        therefore, reducing the mass of all vehicles will increase risks
        in collisions between vehicles.  [...]
        "The second fallacy arises from failing to adequately account for
        confounding factors and consequently drawing conclusions from
        spurious correlations.  In analyzing real crashes, it is
        generally very difficult to sort out 'vehicle' effects from
        driver behavior and environmental conditions.  Because the driver
        is generally a far more important determinant of crash
        occurrences than the vehicle and a significant factor in the
        outcomes, even small confounding errors can lead to seriously
        erroneous results.  [...]
        "Kahane's results (1997) suggest that in car-to-car or light
        truck-to-light truck collisions, if both vehicles are lighter,
        fatalities are reduced.  The signs of the two coefficients
        quantifying these effects are consistent for the two vehicle
        types, but neither is statistically significant.  Focusing on the
        crashworthiness and aggressivity of passenger cars and light
        trucks in collisions with each other, Joksch et al. (1998)
        studies fatal accidents from 1991 to 1994 and found stronger
        confirmation for the concept that more weight was, in fact,
        harmful to safety.  [...]  Studies like those of Kahane (1997)
        and Joksch et al. (1998) that take greater pains to account for
        confounding factors appear to be less likely to find that
        reducing weight is detrimental to highway safety in vehicle-to-
        vehicle crashes than studies that make little or no attempt to
        control for confounding factors.  This suggests to us that
        confounding factors are present and capable of changing the
        direction of a study's conclusions."
      Jamie McCarthy
    Date: Tue, 12 Mar 2002 19:31:42 -0500
    To: Declan McCullagh <declanat_private>
    From: Mike Godwin <mnemonicat_private>
    Subject: Re: FC: Raise fuel efficiency standards, kill Americans?
    Drive an SUV! Save lives!
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