Loopholes

In 2016 we're supposed to get new 35.5 mpg cars, but we will instead just get better A/C in out SUVs. [Link]

The Air Conditioner Loophole
That level of CO2 emission per mile would equate to about 35.5 MPG in fuel economy parlance. However — here's the big loophole — it's expected by the EPA and NHTSA that most manufacturers would apply air conditioning improvements to reduce GHG emissions. Air conditioning improvements do not enter into the NHTSA's calculation of MPG fuel economy.

Thus, the improvement in MPG that is equivalent to the estimated 250g of CO2/mile will actually fall well short of the 35.5 MPG mark. The gap between what the fleet CAFE will be and the widely reported 35.5, would be made up by air conditioner improvements. So basically, when you buy your supposedly more-fuel-efficient vehicle in 2016, it won't have as high of a fuel economy as it could — thanks to your car's air conditioning.

Automakers Get Lower Standards The More Large SUVs, Trucks They Build
Credit Suisse also points out in a new report released today that another key component of the proposal yesterday is that the EPA and NHTSA both intend to propose separate footprint-based standards. This is consistent with NHTSA's current approach to CAFE standards and, as such, means that there will be no set standard, with respect to either CO2 or fuel economy, for any single manufacturer or in fact for the fleet as a whole. Any standards you hear about for a given manufacturer or for the fleet as a whole are estimates.

This is because the actual MPG or CO2 "standard" for every manufacturer will vary depending on what they build. Footprint-based means the amount of CO2 emitted and the level of fuel economy will vary depending on the vehicles wheelbase multiplied by its track width. Put another way, the area between where the tires touch the road.

This quote from the proposal addresses the implications for automakers: "Under a footprint-based standard, each manufacturer would have a GHG and CAFE standard unique to its fleet, with a separate standard for passenger cars and light-trucks, depending on the footprints of the vehicle models produced by that manufacturer. Generally, manufacturers of larger vehicles (i.e. vehicles with larger footprints) would face less stringent standards (i.e., higher CO2 grams/mile standards and lower CAFE standards) than manufacturers of smaller vehicles." This clearly favors the domestic makers.

I thought it was only Republicans who were this friendly to business?