Statement on 2017–25 NPRM, Vehicle CAFE/GHG StandardsJanuary 17, 2012International Council on Clean Transportation 3
Computer simulations will especially impact lightweight material design. In the past,interactions between the thousands of parts on the vehicles and their impacts on safety, ride,noise, and vibration were impossible to predict. Optimization of materials was a long, slow process of gradually changing a few parts at a time to avoid unanticipated problems. Secondaryweight reductions were similarly difficult to achieve. The recent development of sophisticatedand accurate vehicle simulations is opening up a new world. The initial use of these models wasto improve safety design. The simulations are so effective that 5-star crash ratings becamealmost universal and NHTSA had to revise their rating criteria for the 2011 model year. Thesimulations are continuing to rapidly improve, to the point where they are starting to be used tosimultaneously optimize the material composition, shape, and thickness of every individual part,including secondary weight reductions.This shift in material design capabilities also impacts the cost to reduce vehicle weight. Previouslightweight material cost studies did not assess part interactions and secondary weightreductions. While they may have accurately reflected historical costs for lightweight materials,they all overstate the cost of future vehicle weight reduction. Studies in progress by Lotus andFEV are using highly sophisticated simulation models to optimize part materials and design. Theresults of these studies will be far more accurate of future designs and must be used to assessweight reduction costs for the final rule.ICCT is also paying FEV to do additional teardown cost assessments in connection with our work in Europe. These include updating the P2 hybrid costs and new cost assessments for advanced diesel engines, basic stop-start systems, manual transmissions, and cooled EGR systems. These results will be shared with EPA and NHTSA as they become available.ICCT will address the impacts of technology benefit and cost on consumer welfare in our writtencomments.SafetyICCT will address the safety issues in more detail in our written comments, including the resultsfrom DRI’s latest safety analyses. I will just make two quick observations here. First, every timeKahane reanalyzes the impact of mass reduction on fatalities, the fatality increase goes down. InKahane’s latest study, he concluded, “potential combinations of mass reductions that maintainfootprint and are proportionately somewhat higher for the heavier vehicles may be safety- neutralor better as point estimates and, in any case, unlikely to significantly increase fatalities.”Second, and more importantly, the coefficients in Kahane’s modeling reflect the materialcomposition in historical vehicles, which is dominated by conventional steel. Thus, themodeling results implicitly assume that lighter vehicles do not change material composition.However, future weight reduction will be accomplished primarily with the use of high strengthsteel and aluminum and with better vehicle design. High strength steel and aluminum both have better crash properties than standard steel. Reducing weight of small cars using these better materials will improve their crash performance and reduce fatalities. In fact, Honda has movedaggressively towards the use of HSS in small cars in part due to the safety benefits.