CAFE Standards Kill: Congress' Regulatory Solution to Foreign Oil Dependence Comes at a Steep Price
by Ryan Balis
the heels of the Arab oil embargo, in 1975 Congress enacted Corporate
Average Fuel Economy (CAFE) standards as a regulatory solution to
reduce the United States' dependence on foreign oil and gasoline
standards mandate that vehicles sold in the U.S. meet fuel efficiency -
or "fuel economy" - standards. Current standards require an average of
27.2 miles per gallon (mpg) for cars and 21.6 mpg for light trucks.2
in 2008, "one-size-fits-all" CAFE standards for light trucks will be
phased out. New regulations will divide light trucks into six
categories based on vehicle size - each category having its own mpg
target.3 However, the fuel economy for these vehicles will be raised from the current 22.2 mpg to 24.0 mpg in model year 2011.4
to a National Highway Traffic Safety Administration (NHTSA) estimate,
implementing this change will cost American consumers over $6.71
billion in added vehicle expenses from 2007-2011.5
Yet Marlo Lewis, a senior fellow at the Competitive Enterprise
Institute, calculates that the fuel savings will be a mere 0.44 billion
gallons of gasoline annually.6 On average, U.S. cars and light trucks consume some 11 billion gallons of gasoline each month.7
Despite the new regulatory "reform," high gas prices have lawmakers in Washington debating, once again,8
whether to impose even steeper CAFE standards. For instance,
Senators Dianne Feinstein (D-CA), Olympia Snowe (R-ME) and Dick Durbin
(D-IL) proposed burdensome across-the-board legislation to increase
CAFE standards to 35 mpg on both light trucks and cars by model year
2017.9 Senators Lisa Murkowski (R-AK) and Maria Cantwell (D-WA) have also recently called for CAFE increases.10
such increases have unintended safety consequences for the safety of
drivers and passengers. The reason is because carmakers build
lighter and smaller cars that burn less fuel to comply with CAFE
standards.11 The trade-off
is these lighter, smaller cars fare much worse in violent crashes,
resulting in greater rates of death and injury for occupants.
A number of studies have documented the lethal consequences of requiring carmakers to improve fuel standards.
According to a 2003 NHTSA study, when a vehicle is reduced by 100
pounds the estimated fatality rate increases as much as 5.63 percent
for light cars weighing less than 2,950 pounds, 4.70 percent for
heavier cars weighing over 2,950 pounds and 3.06 percent for light
trucks. Between model years 1996 and 1999, these rates translated
into additional traffic fatalities of 13,608 for light cars, 10,884 for
heavier cars and 14,705 for light trucks.12
A 2001 National Academy of Sciences panel found that constraining
automobile manufacturers to produce smaller, lighter vehicles in the
1970s and early 1980s "probably resulted in an additional 1,300 to
2,600 traffic fatalities in 1993."13
* An extensive 1999 USA Today analysis of crash
data found that since CAFE went into effect in 1978, 46,000 people died
in crashes they otherwise would have survived, had they been in bigger,
heavier vehicles. This, according to a 1999 USA Today analysis of
crash data since 1975, roughly figures to be 7,700 deaths for every
mile per gallon gained in fuel economy standards.14
The USA Today report also said smaller cars - such as the Chevrolet
Cavalier or Dodge Neon - accounted for 12,144 fatalities or 37 percent
of vehicle deaths in 1997, though such cars comprised only 18 percent
of all vehicles.15
A 1989 Harvard-Brookings study estimated CAFE "to be responsible for
2,200-3,900 excess occupant fatalities over ten years of a given [car]
model years' use." Moreover, the researchers estimated between
11,000 and 19,500 occupants would suffer serious but nonfatal crash
injuries as a result of CAFE.16
The same Harvard-Brookings study found CAFE had resulted in a 500-pound
weight reduction of the average car. As a result, occupants were
put at a 14 to 27 percent greater risk of traffic death.17
Passengers in small cars die at a much higher rate when involved in
traffic accidents with large cars. Traffic safety expert Dr.
Leonard Evans estimates that drivers in lighter cars may be 12 times as
likely to be killed in a crash when the other vehicle is twice as heavy
as the lighter car.18
addition to the above studies, the following quotes provide a quick
reference point of safety experts' results and statements on the
consequences of CAFE regulations as they relate to vehicle safety.
"The negative relationship between weight and occupant fatality risk is
one of the most secure findings in the safety literature."
-Dr. Robert W. Crandall, Brookings Institution, and John D. Graham, Ph.D., Harvard School of Public Health19
"Why Does CAFE kill? It does so because it constrains the
production of larger cars and, in most modes of collision, larger,
heavier cars are more protective of their occupants than are small
-Sam Kazman, Competitive Enterprise Institute20
"[I]n terms of just the total number of lives, when I purchase a larger
car, there is a reduction of risk. I'm safer, and so is society
overall... We can conclude, beyond any reasonable doubt, that when
weight is reduced, as it must be under CAFE, we will increase
-Dr. Leonard Evans, physicist, author of Traffic Safety and president of Science Serving Society21
"During the past 18 years, the office of Technology Assessment of the
United States Congress, the National Safety Council, the Brookings
Institution, the Insurance Institute for Highway Safety, the General
Motors Research Laboratories and the National Academy of Sciences all
agreed that reductions in the size and weight of passenger cars pose a
-National Highway Traffic Safety Administration22
* "If you want to solve the safety puzzle, get rid of small cars."
-Brian O'Neill, Insurance Institute for Highway Safety23
* "CAFE is a solution in search of a problem."
-Dr. Robert W. Crandall, Brookings Institution24
* "The evidence is overwhelming that CAFE standards result in more highway deaths."
-Charli E. Coon, J.D., Heritage Foundation25
"The conclusion is that CAFE has caused, and is causing, increased
deaths.... CAFE kills, and higher CAFE standards will kill even more."
-Dr. Leonard Evans, physicist, author of Traffic Safety and President of Science Serving Society26
# # #
Ryan Balis is a policy analyst for The National Center for Public Policy Research. Comments may be sent to firstname.lastname@example.org.
note: Due to a production error, the first bullet point in this paper
originally misidentified a vehicle weight cutoff at 2,900 pounds when
the correct number should have been 2,950 pounds. The text has
been corrected. We regret the error.
Charli E. Coon, "Why the Government's CAFE Standards for Fuel
Efficiency Should Be Repealed, Not Increased," Backgrounder No. 1458,
The Heritage Foundation, Washington, D.C., July 11, 2001, available at
http://www.heritage.org/Research/EnergyandEnvironment/BG1458.cfm as of
June 23, 2006.
2 Title 49 U.S. Code, Chapter
329, Nov. 2000, sec. 32902, National Highway Traffic Safety
Administration, Washington, D.C., available at
of June 23, 2006. The classification for light trucks includes
pickups, minivans and SUVs weighing not more than 8,500 pounds.
For current fuel economy regulations on light trucks, see "Light Truck
Average Fuel Economy Standards: Model Years 2005-2007," Docket No.
2002-11419; Notice 3, p. 28, National Highway Traffic Safety
Administration, Department of Transportation, Washington, D.C.,
http://www.nhtsa.dot.gov/cars/rules/rulings/CAFE05-07/Index.html as of
June 23, 2006.
3 Andrzej Zwaniecki, "United States To Raise Fuel-Economy Standards for
Light Trucks," U.S. State Department, Washington, D.C., August 24,
2005, available at
http://usinfo.state.gov/gi/Archive/2005/Aug/25-936784.html as of June
23, 2006; NHTSA final regulation available at
as of June 23, 2006.
4 "Average Fuel Economy Standards for Light Trucks: Model Years
2008-2011," Docket No. 2006- 24306, p. 12, National Highway
Transportation Safety Administration, Department of Transportation,
Washington, D.C., available at
as of June 23, 2006.
5 "Average Fuel Economy Standards for Light Trucks: Model Years 2008-2011."
6 Marlo Lewis, "CAFE For Dummies," Competitive Enterprise Institute
Open Market, April 11, 2006, available at
of June 23, 2006.
7 Figure from American Petroleum Institute cited in U.S. State Department release. See Andrzej Zwaniecki.
8 In 2003, Senators Feinstein and Snowe introduced legislation to
require that SUVs have the same fuel standards as passenger cars.
See "Senators Feinstein and Snowe Introduce Legislation to Increase
Fuel Efficiency Standards," Office of Senator Diane Feinstein, January
30, 2003, available at
http://www.senate.gov/~feinstein/03Releases/r-cafe03.htm as of June 23,
2006. In 2002, Senators John Kerry and John McCain proposed
raising CAFE standards on all vehicles to 36 mpg by 2015. See Cat
Lazaroff, "Senate Rejects Mandatory Fuel Efficiency Proposal,"
Environment News Service, March 15, 2002, available at
http://www.ens-newswire.com/ens/mar2002/2002-03-15-06.asp as of June
23, 2006; Gretchen Randall, "Fuel Efficiency Standards: What to Do
Next?," National Policy Analysis No. 393, The National Center for
Public Policy Research, Washington, D.C., February 2002, available at
http://www.nationalcenter.org/NPA393.html as of June 23, 2006.
9 "Senators Feinstein, Snowe, Durbin Call for Raising Average Fuel
Economy Standards for All Vehicles to 35 mpg by Model Year 2017,"
Office of Senator Diane Feinstein, May 10, 2006, available at
http://feinstein.senate.gov/06releases/r-cafe-announc.pdf as of June
10 H. Josef Hebert, "White House Pressured to Increase Auto Fuel
Economy," Miami Herald (Associated Press), May 10, 2006, available at
as of June 23, 2006; Dana Milbank, "Going a Short Way to Make a Point,"
Washington Post, April 27, 2006, available at
as of June 23, 2006.
11 "CAFE unquestionably leads to lighter vehicles, because fuel is
consumed in ways that are intimately related to mass. The energy
required to accelerate a body from rest to 30 mph is directly
proportional to the mass of the body. So the heavier the vehicle, the
more fuel you must use, other things being equal." Remarks by Dr.
Leonard Evans, "Does CAFE Kill? Oral Remarks By Dr. Leonard Evans," A
Discussion of the Report on CAFE of the National Research Council of
the National Academies of Sciences, Competitive Enterprise Institute,
Washington, D.C., January 17, 2002, available at
http://www.cei.org/gencon/027,02350.cfm as of June 23, 2006; Gretchen
12 Charles J. Kahane, Ph.D., "Vehicle Weight, Fatality Risk and Crash
Compatibility of Model Year 1991-99 Passenger Cars and Light Trucks,"
National Highway Traffic Safety Administration, Department of
Transportation, Washington, D.C., October 2003, p. 11-13, available at
of June 23, 2006.
13 Paul R. Portney, et. al, "Effectiveness and Impact of Corporate
Average Fuel Economy (CAFE) Standards (2002), The National Academy of
Sciences, Washington, D.C., 2002, p. 3, available at
http://darwin.nap.edu/books/0309076013/html/3.html as of June 23, 2006.
14 James R. Healey, "Death by the Gallon," USA Today, July 2, 1999.
15 "Small cars - those no bigger or heavier than Chevrolet Cavalier or
Dodge Neon - comprise 18 percent of all vehicles on the road, according
to an analysis of R.L. Polk registration data. Yet they accounted for
37 percent of vehicle deaths in 1997 - 12,144 people - according to
latest available government figures. That's about twice the death
rate in big cars, such as Dodge Intrepid, Chevrolet Impala, Ford Crown
Victoria." See Ibid.
16 Robert W. Crandall and John D. Graham, "The Effect of Fuel Economy
Standards on Automobile Safety," Journal of Law and Economics, Vol.
32:1, p. 97-118, April 1989, available at
http://www.fortfreedom.org/s51.htm as of June 23, 2006.
18 Dr. Leonard Evans.
19 Crandall and Graham.
20 Remarks By Sam Kazman, "CAFE Standards: Do They Work? Do They
Kill?," The Heritage Foundation, Washington, D.C., February. 25, 2002,
available at http://www.cei.org/gencon/027,02414.cfm as of June 23,
21 Dr. Leonard Evans.
22 Quoted in James R. Healey, "Death by the Gallon," USA Today, July 2, 1999.
24 Remarks by Dr. Robert W. Crandall, "Fuel Economy Standards: Do they
Work? Do they Kill?," WebMemo No. 85, The Heritage Foundation,
Washington, D.C., March 8, 2002, available at
http://www.heritage.org/Research/EnergyandEnvironment/WM85.cfm as of
June 23, 2006.
25 Charli E. Coon.
26 Dr. Leonard Evans