DOT: Your car is imaginary

Bill Merchant · Jul 31, 2008

I posted this on HybridChat, but wanted it to get the wider viewing that PC offers. From Driving Change, a publication of the Union of Concerned Scientists:

Who’s Got Hybrids? DOT Says “Not You.”
Last month we criticized the Department of Transportation (DOT) for using gas price estimates that project we will be paying between $2.25 and $2.60 per gallon over the next 20 years. Using these laughable estimates in effect creates a loophole that will allow automakers to shave three to four miles per gallon off of their fuel economy requirements over the next decade.

If the gas price assumptions weren’t unrealistic enough, the DOT now seems to be playing some interesting games with hybrids as well. In its draft fuel economy rule, the DOT has to predict when advanced technologies will hit the market—a basic assumption to help them determine how fast and far the fuel economy standards can climb over time. All hybrid technologies—including the 2-mode and power-split “full” hybrid systems (such as the Prius, Escape Hybrid, and Tahoe Hybrid)—are assumed not to appear until 2014. Indeed, even simple start/stop-based systems (a.k.a. idle-off technology, as seen in the Saturn Green Line Vue) are evidently still six years away from hitting the road. So if you’re like me and driving one of the million-plus hybrids already sold in America, congratulations, you’re driving the car of the future…today!

And it doesn’t end there. Not only do they assume that the Toyota Prius, the ninth best selling car in America, does not exist, there are also assumptions in the draft DOT plan about how fast or slow these technologies will be adopted by the automakers. The draft rule assumes that hybrid technologies would see an adoption rate of 3 percent, meaning it will take roughly 33 years for hybrid technology to become ubiquitous. Given advances in hybrid technology, and the commitments not only of Honda and Toyota, but the domestic automakers as well, to increase their hybrid offerings, there is simply no valid reason to assume such slow adoption rates.

The interpretation becomes yet more absurd upon closer inspection as the rule applies the same phase-in limits to all facets of hybrid technologies, from mild start-stop hybrids to full plug-in hybrids alike. In contrast, an Environmental Protection Agency technical report, upon which the DOT relied when making their rule, essentially noted how easy idle-off technology would be to integrate, saying, “their low cost and easy adaptability to existing powertrains and platforms can make them attractive for some applications.”

I think it’s fair to say that with more than 10 years of experience from leading manufacturers, hybrids can no longer be considered niche technology. Our Setting the Standard report on the potential of existing technologies to increase fuel economy under the new CAFE standards noted that with a modest 25 percent hybrid market share in 2020, a cost-effective fleet average fuel economy of 42 mpg could be achieved. And, if the focus of the hybrid technology is on miles rather than muscle, the average could push even higher. UCS (among numerous other groups and market analysts) expects significant growth in the hybrid market over the coming years.

If you’d like to read our full list of comments and suggestions on the draft rule, you can find them here (pdf). And if you’re one of the more than 6,000 people who helped bolster our technical comments with your real-world letters during the public comment period on this rule—THANK YOU!

The article continues with specific suggestions on actions you can take. Check out the first link and consider joining the Driving Change Network, part of UCS's Hybridcenter.org.

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DOT: Your car is imaginary

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