Last Friday, the Aluminum Association’s Transportation Group (ATG) submitted comments urging the National Highway Transportation Safety Administration (NHTSA) and the Environmental Protection Agency (EPA) to pursue data-driven decision making in its final vehicle fuel economy rule-making.

The comments emphasised the proven track record of vehicle mass reduction safety, supported continued year-over-year fuel economy improvements and called on the agencies to maintain One National Program to avoid protracted litigation.

The docketed comments are in response to the proposed Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule for Passenger Cars and Light Trucks, Model Years 2021-2026.

“The agencies rightly recognised greater use of high strength, low weight materials – especially in larger cars and trucks – is a safe way to boost fuel economy and cut carbon emissions. However, the draft rule wrongly assumes automakers will reduce weight evenly across vehicle segments, to include the smallest cars. There is no data to support this assumption and a wealth of data and on-the-road examples to support the opposite conclusion,” said Heidi Brock, president & CEO of the Aluminum Association.
“We also support the president’s call for a negotiated outcome with California to maintain a single national program and avoid legal battles that will cause uncertainty across the auto industry. We strongly agree that all parties must come together to find a workable solution that fosters continual gains in fuel economy and reductions in carbon emissions,” Brock added.

Safety Background
The Aluminum Association believes the current footprint-based approach to fuel economy regulations is working, creating incentives for automakers to improve fuel economy and reduce carbon emissions by reducing the weight (not the size) of the heaviest, biggest cars and trucks. NHTSA’s assertions on lightweighting and safety as related to the small car segment, however, are not supported by NHTSA’s own data, which confirm weight can be reduced safely in more than 95 percent of light trucks and passenger cars to boost MPG, while maintaining or increasing safety. For the remaining 5 percent, those very small passenger cars weighing 3,200 pounds or less, there is not data to suggest automakers will be forced (or have reason) to lightweight them under any regulatory scenario—and automakers have made no such claims. The insurance industry and the National Academy of Sciences, among many others, are on record confirming the current, size-based standards resolve their prior concerns on lightweighting and safety. Thanks to smart design and lighter, yet highly crash-absorbent materials, from pickups like Ford’s 5-star crash rated F-150, to passenger cars like Chevrolet’s 5-star crash rated Malibu, there are countless examples of redesigned vehicles on the road today maintaining or increasing their NHTSA safety ratings while shedding hundreds of pounds to boost fuel economy and performance. Please click here to access data confirming automakers are not planning to reduce vehicle weight of small passenger cars under any regulatory scenario, and proving every aluminium-intensive vehicle is five-star crash-safety rated.

Regulatory Certainty Background
Regulatory certainty is essential to the U.S. aluminium industry, which continues to make significant investments in new products, processes and capacity to meet growing demand for automotive aluminium sheet material. Since 2013, the aluminium industry invested or committed more than $2.7 billion in U.S. manufacturing facilities—and related jobs—to support growing demand in the auto market. The industry has enjoyed two consecutive years of record demand in the automotive aluminium segment. As market conditions dictate, the aluminium industry is poised for even more such investments. The association supports a final rule that includes an augural projection covering a 10-year period from initial implementation of the final chosen alternative, with a midterm review, so automakers and suppliers can plan accordingly.

Technical Advancement Background
The Aluminum Association believes that the ‘maximum feasible’ requirement for fuel economy regulation, as mandated by law, would be satisfied at an alternative level between the proposed rule Alternative 6 (existing standards through MY 2020, then 2 percent/year increases for passenger cars and 3 percent/year increases for light trucks) and the augural standards. Recognising that the association does not have all relevant data available to it, based on the data that is available, an outcome in that range best aligns with the legislative ‘maximum feasible’ requirement. Importantly, the association supports an outcome that ensures that California and other aligned states covered by Section 177 of the Clean Air Act continue to stay engaged in the process, to ensure One National Program, whichever proposed standards are ultimately adopted.