EPA Mass Reduction Analysis – Observations and Recommendations

Full Description:

In this report, CAR researchers assess the technical analysis for vehicle mass reduction performed by the Environmental Protection Agency (EPA) in the draft Technical Assessment Report (TAR). CAR’s analysis finds that the EPA’s approach is substantially incorrect and warrants significant revision. CAR’s report provides observations and recommendations designed to improve EPA’s analysis. Among the shortcomings found in EPA’s method include:

• Establishing a baseline cost curve from two different vehicles with no evidence that these two are representative of the U.S. fleet
• Extrapolating lightweighting costs (cost curve) from one vehicle to other vehicles with different, yet unknown lightweight material technology
• Assuming that all 2008 model year vehicles possess a common baseline of lightweight technology
• Relying on vehicle curb weight as a proxy for measuring the amount of lightweight material technology in a vehicle
• Adjusting curb weight only for footprint increase and previous safety regulations but not considering mass add-backs for future safety improvements and new vehicle content

CAR recommends that the EPA employ a material-based lightweighting cost analysis as recommended by the National Research Council and reevaluate the cost to lightweight the U.S. fleet based on this analysis