SUVs: The High Costs Of Lax Fuel Economy ... - Public Citizen

SUVs: The High Costs Of Lax Fuel Economy Standards for American Families

June 2003

Acknowledgments This report was researched and written by Laura MacCleery, with research assistance from Ed Ricci and Morgan Lynn. Editorial assistance and direction were provided by Joan Claybrook, Booth Gunter, Shannon Little and Angela Bradbery. Reproduction of the report was managed by Johnette Washington and Sarah Cullens. Additional research and analytical support was provided by Marc Ross, Ph.D. from the University of Michigan, Tom Wenzel from the Lawrence Berkeley National Laboratory and David Friedman, from the Union of Concerned Scientists.

About Public Citizen Public Citizen is a non-profit, 150,000-member organization based in Washington, D.C. that represents consumer interests through lobbying, litigation, regulatory oversight, research and public education. Since its founding by Ralph Nader in 1971, Public Citizen has fought for consumer rights in the marketplace, safe and secure health care, health and safety standards, fair trade, clean and safe energy sources, and corporate and government accountability. Public Citizen is active in every public forum: Congress, the courts, governmental agencies and the media.

Public Citizen 1600 20th St. N.W. Washington, D.C. 20009 (202) 588-1000 © 2003 Public Citizen. All rights reserved.

2 www.bettersuv.org Public Citizen June 2003

TABLE OF CONTENTS EXECUTIVE SUMMARY What We Know Now About the Costs and Hazards of SUVs………………………7

PART ONE New Research Shows SUVs Are Not Safe Transportation for Families and Children.......................................................................................................……….. 10 A. SUV Hype Explodes Sales.....................................................……….…….. 10 B. Methods Used in Analyzing Child Fatalities in SUVs and Other Vehicles.. 12 C. Why Are SUVs More Deadly for Children than Minivans and Mid-Size Cars? ............................................................................................................ 17 D. Trends in Child Occupancy Rates in SUVs Raise Greater Concern........................................................................………..................….18

PART TWO SUVs are Costly for Families, Who Pay Too Much at the Pump............................ 19

PART THREE Detroit Chooses While Consumers Pay: “Super-Sized” Vehicles Increase Carnage…................................................................................……….......................20 A. In the Absence of Adequate Federal Fuel Economy Standards, Automakers Increased the Weight and Acceleration Times of Light Trucks.................…22 B. SUV Boom and the Rising Threat to Others on the Highway..........………..25 C. Lost Opportunities to Improve Fuel Economy: The Bryan Bill Got it Right.27

PART FOUR Conclusion....................................................................................................................31

PART FIVE Endnotes...................................................................................................…...............32

PART FIVE Appendices....................................................................................................………. 34 A. More Information on Child Safety…………………………………………..35 B. Ross and Wenzel Top 20 Most Risky Vehicles……………………………...37 C. What Should Be Done on Safety…………………………………………….38 D. Information on Fuel Economy Standards……………………………………39 E. The Costs of Living in “SUV Country”…………………………………...…40 F. The SUV That Could Be……………………………………………………..43


“…[A]t the auto show, [] journalists and executives spent most of their time in throngs around the many SUVs on display. The large cars and minivans sprinkled around the show at various automakers’ exhibits, by contrast, might well have been invisible. Most of them had not been updated for years, and almost nobody was looking at them. This was not surprising, since sales of large cars and minivans had been slowly eroding since the late 1990s, as Americans bought SUVs instead. But it was also sad, because the large cars and minivans were safe, affordable, practical, reliable and surprisingly fuelefficient.” -- Bradsher, Keith. High and Mighty SUVs: The World’s Most Dangerous Vehicles and How They Got That Way, (2002), at 409.

“Ford Motor Company, which depends on sport utility vehicles for much of its profit…said that the vehicle contribute more than cars to global warming, emitted more smog-causing pollution and endangered motorists.” -- Bradsher, Keith, New York Times, May 12, 2000.


KEY FINDINGS ON THE HIGH COSTS OF SUVS 1. SUVs are the second-most common way to transport children (behind minivans). 2. SUVs are more risky for children than large or mid-size cars, and SUVs are twice as deadly for children as minivans. 3. Children are more at risk of death from a rollover crash in an SUV than rollovers in any other type of vehicle. 4. The number of children riding in SUVs is increasing, while the number of children riding in minivans and cars is in decline. 5. Automakers have taken advantage of the lack of critical rollover stability, roof crush and other safety standards, and of low fuel economy requirements, reaping an artificially high profit margin from SUVs while aggressively marketing them. 6. The average SUV owner paid $350 more in 2002 than they would have paid if their SUV was as fuel-efficient as a car. In sum, SUV owners in the U.S. forked over 8.89 billion in 2002 in extra money at the pump— twice as much as Americans spent on public transportation in that year. 7. Automakers failed to use engine and fuel efficiency gains since 1988 to improve actual vehicle fuel economy, instead increasing the weight and acceleration of the heaviest vehicles in the fleet. 8. In 2002, light truck drivers each spent an extra $387 on gas – totaling some $33 billion all together – that they would not have spent had manufacturers increased fuel economy instead of engine capacity and vehicle weight starting in 1988. Combined, light truck and car drivers spent nearly $68 billion extra for gas, or $242.54 for every man, woman and child in the country. 9. If automakers had chosen to improve fuel economy rather than efficiency, total savings in 2002 would have been over 1 billion barrels of oil – or about 3 million barrels a day, a savings of twice what the U.S. imports daily from Saudi Arabia, and about a third of daily oil consumption by U.S. motor vehicles. Over three years, it would have saved more than all proposed drilling plans for the Arctic National Wildlife Refuge. 10. In 1990, industry lobbying narrowly defeated the landmark bill authored by Sen. Richard Bryan (D-NV). Had the Bryan bill passed, light truck owners would have saved $489 in 2002 on gasoline, totaling $42 billion for all owners. Combined, light truck and passenger car owners would have saved nearly $89 billion in 2002, a sum that is $316.82 for every man, woman and child in the U.S. 5 www.bettersuv.org Public Citizen June 2003

11. Passage of the Bryan bill would have increased the fuel economy of 2002 light trucks by 40 percent, enabling savings of 720 million barrels of oil over actual 2002 usage. Combined with car savings, 1.5 billion barrels of oil could have been saved last year. This is more than 4 million barrels each day, almost as much as U.S. daily crude oil imports from OPEC countries, and four times as much as the oil savings amendment passed by the Senate on June 10, 2003. 12. Because Detroit is unwilling to improve safety and fuel economy without federal direction, Congress should: • Address the rollover epidemic by requiring rollover crashworthiness protections in light trucks and cars, and requiring a minimum rollover stability standard; • Put America back on the road to oil savings and improved safety by raising the light truck fuel economy standard and passing an aggressivity reduction standard.


Summary WHAT WE KNOW NOW ABOUT THE COSTS AND HAZARDS OF SUVS Due to the explosion of SUVs on the highway, overall fuel economy on American highways has taken a nosedive. Average fuel economy of the U.S. vehicle fleet peaked in 1988, and has since declined. The upsurge in light trucks (SUVs, vans and pickups), which average 6 miles-per-gallon (mpg) less than cars, according to government data, is to blame for the decline in fuel economy of the vehicle fleet.1 The proliferation of SUVs on the road is also rolling back the clock on safety. Figures from the National Highway Traffic Safety Administration (NHTSA) this spring show that the number of people killed in traffic crashes increased 1.7 percent last year, to the highest level since 1990.2 SUVs again explain why the U.S. is stuck in reverse. In 2002, SUV and pickup rollover deaths accounted for 46 percent of the increase in all occupant fatalities and 78 percent of the increase in passenger vehicle rollover fatalities.3 In another study, NHTSA researchers point out that deaths in SUV and pickup rollovers are more than offsetting declines in deaths of passenger car occupants.4 Crash mismatches between cars and SUVs are also increasing the risk imposed by SUVs on other motorists. In frontal crashes, SUVs kill 4.3 car drivers for every one SUV driver killed, and in near-side crashes, SUVs kill 16.3 car drivers, a kill rate twice that of cars.5 And research shows that crashes between two light trucks (a category including SUVs, pickups and vans) are more deadly than crashes between two cars.6 But the news gets worse. An unpublished analysis by Lawrence Berkeley National Laboratory and the University of Michigan, shows that SUVs, as currently designed, are unsafe for kids. Although SUVs rank as the second-most popular way to transport children, behind minivans, they are twice as deadly for children as minivans. SUVs are also the most dangerous vehicles for children in rollover crashes. Adding insult to this terrible injury, SUV owners pay considerably more for gasoline than they would if their SUV was as fuel-efficient as a car. A new analysis by Public Citizen shows that the average SUV owner pays $350 more out of the household budget each year than does the average car owner. And these dollars add up— to more than $9 billion a year paid in extra gas costs by all SUV owners in the U.S. American automakers can do better. A comparison of the trade-offs made by the auto industry over the past 20 years shows that automakers have the technology to make fuel economy improvements available to consumers. The march of technological progress yields yearly gains in engine efficiency that could be used to improve fuel economy. In the 7 www.bettersuv.org Public Citizen June 2003

absence of a strong federal fuel economy program, however, automakers have instead increased the weight and acceleration time of the heaviest vehicles. If automakers had employed gains in engine efficiency to improve fuel economy since 1988 (the target year contained in a 1990 landmark Senate fuel economy bill authored by Sen. Richard Bryan (D-NV)), cars would today achieve 35.7 mpg on average, and light trucks (a category including SUVs, minivans, vans and pickup trucks) would get nearly 26 mpg on average. Had manufacturers increased fuel economy, light truck owners each would have saved $387 on gas in 2002 alone, saving as a group more than $33 billion on gas for their vehicles. Combined, light truck and car drivers spent nearly $68 billion more than they should have. Automakers’ engine improvements would have taken us a considerable way towards improving fuel economy, and incentives provided by federal standards could have gone the rest of the distance. Had the 1990 Bryan bill passed, in 2002 the average light truck owner would have saved $489 on gasoline, totaling $42 billion for all light truck owners. Combined, light truck and passenger car owners would have saved nearly $89 billion in 2002. This is twice as much as all Americans spent on public transportation in 2001.7 Instead, automakers increased acceleration times for trucks by 2.5 seconds, increased the average weight of light trucks by almost 600 lbs., and bulked up engine horsepower. These attributes are unlikely to be used or appreciated by most SUV drivers, as most do not tow heavy loads and the vast majority never even wander off-road.8 The substantial increase in weight was possible because there was little improvement in the federal standard for the fuel economy of light trucks over the past three decades. But allowing manufacturers to increase the weight of vehicles, while keeping gas mileage constant, has made two-vehicle crashes more severe for car occupants, increasing the death rate on highways, and threatening children and families. Acceleration increases may exacerbate handling difficulties of light trucks, leading to more crashes. The auto industry suggests that consumer demand is dictating these vehicle designs— so we decided to ask SUV owners and others whether a safer, cleaner SUV would be preferred. Through a Web-based campaign at www.bettersuv.org, SUV owners can ask automakers for a better SUV for transporting their families. Rather than building another Porsche SUV capable of jack-rabbit starts, automakers should focus their efforts and ingenuity on building an SUV worthy of use by American families.


Detroit has known about these problems, and known their remedies, for years, and has not fixed the SUV. Rather than waiting another decade, Congress should require SUVs to meet higher fuel economy standards; it should also enact a minimum rollover propensity standard and establish requirements for rollover crash protections, such as stronger roofs and doors, window curtain airbags, and pretensioned safety belts. In addition, Congress must address the pressing need for safety measures to reduce the threat posed by SUVs to other motorists. A more socially responsible SUV is an imperative given the proliferation of these vehicles on the road and their increasing death rates and costs. Detroit has shown that, without federal fuel economy and safety standards, it does not act responsibly, so Congress can and should do better for Americans.


I. NEW RESEARCH SHOWS SUVS ARE NOT SAFE FOR FAMILIES AND CHILDREN. When Dr. Jeffrey Runge, Administrator of NHTSA, the federal auto safety agency, told journalists in January that he wouldn’t let a child of his buy a low-rated rollover-prone SUV if it were “the last vehicle on earth,” he was publicly chided by automakers as having stepped over the mark.9 Because rollover is the only area rated by NHTSA in which there is no minimum safety standard, and thus, no “failing” grade, Dr. Runge was speaking of vehicles that literally scrape the bottom of the barrel when compared with the tippiness of every other vehicle on the road. But that didn’t stop the industry from excoriating him. It turns out that Dr. Runge was right. New, as-yet-unpublished research by Marc Ross, of the University of Michigan, and Tom Wenzel, of Lawrence Berkeley National Laboratory, shows that SUV rollovers are a major hazard for children and draws the following troubling conclusions: Finding 1: Finding 2: Finding 3: Finding 4:

SUVs are the second-most common way to transport children (behind minivans). SUVs are twice as deadly for children as minivans. Children are more at risk of death from a rollover crash in an SUV than rollovers in any other type of vehicle. Alarming trend statistics show that the number of children riding in SUVs is increasing, while the number of children riding in minivans and cars has begun in recent years to decrease.

The bottom line: Exposure of children in SUVs is very high; closest to that of minivans. Yet parents who purchase SUVs for transporting their families may be unaware that a child riding in an SUV is twice as likely to die in a crash as a child riding in a minivan. A. SUV HYPE EXPLODES SALES Sales of SUVs have skyrocketed since the 1970s to become nearly a quarter of all new vehicles sold. Light trucks (a category including vans, minivans, pickup trucks and SUVs) now account for nearly half of all new sales. SUV sales rose by more than a factor of 10 from 1975 to 2003, from 1.8 percent of new vehicle sales to 23.4 percent. Over the same period, market share for vans (including minivans) rose 80 percent, while the market share for pickups was relatively constant.


Fraction of New Vehicle Sales by Vehicle Type10 MY 1975

MY 1988

MY 2003

% Change since 1988

Cars

71.2%

66.1%

48.4%

-17.7%

Wagons

9.4%

4.1%

4.0%

-0.1%

Vans

4.5%

7.5%

8.1%

+0.6%

SUVs

1.8%

6.4%

23.4%

+17.0%

Pickups

13.1%

16.1%

16.0%

-0.1%

While it is undoubtedly the case that SUVs appeal to many consumers, there are many factors that enlarge and distort the market for SUVs as well. These factors include: $9 Billion in Advertising for SUVs: • Over the last decade, automakers and dealers spent over $9 billion advertising SUVs. • This ever-increasing expenditure rose nine-fold during that time, from $172.5 million in 1990 to $1.5 billion in 2000 – a rise that exceeds, in percentage terms, the growth of SUVs over the same period.11 High Manufacturer Profit Margins on SUVs: • Cut-rate designs based on pickup truck chassis and low fuel economy requirements for SUVs generate very high profit margins for these “cash cows” of Detroit. • While manufacturers make only a 3 percent profit on cars, they make 15 to 20 percent profit on SUVs.12 • SUV and pickup truck sales account for nearly all of the profits of the Big Three auto companies.13 For example, in 2002 General Motors generated 90 percent of its profits from SUVs and pickups.14 Artificially Low Costs for SUV Manufacturers at a High Cost for Society: • Domestic manufacturers were protected until the mid-1990s by a tariff that imposed costs on foreign manufacturers, discouraging the importation of SUVs and helping to create crucial leverage for Detroit in that market sector. • The largest SUVs receive special breaks on certain safety laws, generating more profit.15 • Repeated efforts to implement key safety standards aimed specifically at reducing the risks of SUVs were repeatedly killed off by industry lobbying, keeping production costs for SUVs artificially low. In 1994, industry pressure killed a federal minimum standard on rollover prevention, which would have saved thousands of lives. The key argument automakers used to kill the safety standard was the cost of an SUV-redesign to lower the vehicle’s center of gravity. SUV rollovers are now a leading cause of higher death rates.


Special Tax Breaks for the Largest SUVs: • Thanks to the recent Bush tax cut, when businesses purchase an SUV (or other light truck) over 6,000 lbs., they can immediately deduct up to $100,000 dollars from their taxable income. • These special interest tax breaks do not preclude businesses from taking the standard 20 percent deduction annually over five years. • The original SUV tax break, which capped the initial deduction at $25,000, was estimated to cost the federal government between $840 million and $987 million yearly, making it one of the biggest tax breaks, per capita, in the U.S. tax code.16 Deceptive advertising about SUVs drives their popularity and misleads consumers about safety. • Despite being marketed to consumers as rugged, go-anywhere vehicles, only 1 to 10 percent of SUV owners use their vehicles for off-road driving or towing.17 • Manufacturers have long opposed point-of-sale labeling that would give consumers information about vehicle safety to allow them to make a truly educated decision about which vehicle is best for them, despite the collection of such information in crash tests by the government as part of its New Car Assessment Program (NCAP).18 • In April 2003, 40 state Attorneys General called on SUV manufacturers to immediately cease any misleading claims in advertising that SUVs have the same handling as cars, or that SUVs can safely handle emergency procedures at fast speeds. The letter was one result of a $51.5 million settlement with Ford over deceptive advertising of its Explorer.19

B. METHODS USED IN ANALYZING CHILD FATALITIES IN SUVS AND OTHER VEHICLES. Real-world crash data from a federal government database of all fatal crashes in the U.S., called the Fatality Analysis Reporting System (FARS) was first analyzed to determine child occupancy rates in various vehicles by vehicle type. Children were defined as people 15 years old and younger.


Figure 1. Average number of children (younger than 16) per vehicle

Average number of children per vehicle

0.7 0.62 0.6 0.5 0.4 0.32 0.3 0.22

0.19

0.2

0.19

0.22

0.13

0.12 0.1

Subcompact cars (high risk)

Subcompact cars (low risk)

Compact cars

Pickups

SUVs

Midsize cars

Large cars

Minivans

0.0

Figure 1 shows the child occupancy rate, or the number of children per vehicle, for seven types of vehicles (subcompacts are divided into two groups, based on the observed risk to their drivers; luxury import cars, which tend to have the lowest risks, and sports cars, which tend to have the highest, are excluded from the figure). These rates were calculated using all children in 1995 to 2001 vehicles recorded in the FARS database for 1995 through 2001, regardless of whether a fatality occurred in the vehicle containing a child. The data show that minivans carry the most children on average (0.62 per vehicle), followed by SUVs (0.32 per vehicle). Pickup trucks and large cars carry the fewest children on average (0.13 and 0.12, respectively). The child occupancy rates in other types of cars vary between 0.19 and 0.22. The relative differences in child occupancy rates by vehicle type do not vary when measured by crash type, so the data appears to represent child occupancy rates in all on-road vehicles. The data also show that SUVs carry 50 percent more children on average than do cars. Therefore, a simple comparison of child fatality totals across different types of vehicles may reflect different levels of exposure, rather than a level of risk inherent to the vehicle. Because of their higher child occupancy rate, SUVs would be expected to have a higher child fatality rate than cars, regardless of any differences in vehicle design. And SUVs do have the highest actual child fatality levels of any vehicle type analyzed (609 deaths in 1995-2001 vehicles between 1995 and 2001). To account for differences in the frequency with which children ride in particular types of vehicles, child fatalities were normalized, or adjusted mathematically, to the same child occupancy 13 www.bettersuv.org Public Citizen June 2003

rate (.20). The normalized fatalities indicate the number of fatalities that would have occurred in each type of vehicle if each carried on average the same number of children. (Using a different occupancy rate would not affect the relative differences in child fatality rates by vehicle type: it is the relative differences among vehicle categories that are relevant when comparing the safety of various vehicle choices.) Actual Child Fatalities OneTwoVehicle type vehicle vehicle Total Rollovers 170 195 365 158 Minivans 55 76 131 28 Large cars 295 474 127 Midsize cars 179 428 181 609 428 SUVs 228 163 391 191 Pickups 157 292 98 Compact cars 135 Subcompact 175 282 63 cars (low risk) 107 Subcompact 305 494 119 cars (high risk) 189 1,491 1,547 3,038 1,212 Total

Children per vehicle 0.62 0.12 0.19 0.32 0.13 0.22

Normalized Child Fatalities OneTwovehicle vehicle Total Rollovers 54 63 118 51 91 116 207 43 191 310 501 138 284 123 407 282 362 260 623 313 126 144 270 90

0.19

117

191

308

0.22 0.22

177 1,404

279 1,486

456 113 2,890 1,096

67

Table 1. Child fatalities (actual and normalized) by vehicle and crash type, 1995-2001 vehicles between 1995 and 2001. Normalized fatalities assume 0.2 children per vehicle in all vehicle types.

Table 1 shows the actual number of child fatalities, and the number of child fatalities normalized to the same occupancy rate of 0.2, by vehicle type and crash type. Rollover crashes are included in the one- and two-vehicle crash categories; two-vehicle crashes also include crashes involving more than two vehicles. The chart shows that a total of 365 children were killed in 1995 to 2001 model year minivans between 1995 and 2001. However, the table indicates that if minivans carried only 0.2 children on average per vehicle (as opposed to 0.62), only 118 children would have died in minivans. Figure 2 shows the normalized risk to children in single- and multiple-vehicle crashes, and rollover crashes, by vehicle type. The “risk” calculation represents the number of normalized child fatalities per million registered vehicle-years.20


Figure 2. Risk to children, adjusted, 0.2 children per vehicle

14

Risk to children

12

Single-vehicle crashes Multiple-vehicle crashes 5.6 4.8

10 5.4 8

6.4 3.1

6 4 2

6.2

2.9 2.0 2.4

3.7

5.0

4.6

6.2

7.8

8.8

2.7 Subcompact cars (high risk)


Compact cars

Pickups

SUVs

Midsize cars

Large cars

Minivans

0

While the highest risk categories are subcompact and compact cars, overall risk to children in minivans (4.4), the most popular vehicle for transporting children, is half that of SUVs (8.8), the next most popular vehicle for their transport. The relative risk to children by vehicle type does not differ greatly from the risk to drivers by type, according to published findings by Ross and Wenzel. Below is a table from that published research showing risk to drivers by vehicle type. The only ordering change is that risks to children are relatively higher in compact cars than in SUVs; for drivers, that order is reversed.

Ross and Wenzel Fatality Risk* by Vehicle Type21 Sports Car Pickup Subcompact SUV Compact Large Car Mid-Size Car Minivan Luxury Import

Risk to driver 175 108 109 79 90 74 66 40 40

Risk to other drivers 50 103 33 53 38 38 32 40 20

*Ranking based on a combined risk per million vehicles sold 1995-1999.


Combined risk 225 211 141 132 128 112 97 80 60

The threat posed to other vehicles (“aggressivity”) of SUVs and pickup trucks may well be a large contributor to the high death rates in multiple-vehicle crashes of children riding in compacts (6.2) and sub-compacts (7.8 and 8.8). Thus, the SUV boom is likely driving up death rates for children in other vehicles, just as it is for adults. Additional research in this area needs to be done, but findings that demonstrate the growing divergence of cars and light trucks in terms of weight, and the relationship of these trends to fuel economy and safety, are presented in Part III of this report. As presented below, the most important finding of the research is the overwhelming role of rollover crashes in the deaths of children riding in SUVs. The risk to children in rollover crashes riding in SUVs and pickups is the highest of all vehicle types— over three times the risk to children in minivans and large or midsize cars. Figure 3. Risk to children in rollovers, normalized to 0.2 children per vehicle 7 6

Risk to children

5 4 6.1

3

5.6

2 1

3.9 1.9

3.6 2.7

2.2 1.4

Subcompact cars (high risk)


Compact cars

Pickups

SUVs

Midsize cars

Large cars

Minivans

0

After adjusting for differences in occupancy rates, 70 percent of child fatalities in SUVs are in rollover crashes, in comparison with 50 percent of child fatalities in pickups, 43 percent in minivans, 34 percent in compacts, and 21 percent to 28 percent in other car types. Rollovers in SUVs pose a higher risk to children than rollovers in any other vehicle type— more than three times the rollover death risk of children riding in minivans.


C. WHY ARE SUVS MORE DEADLY FOR CHILDREN THAN MINIVANS? The key to understanding differences in child death rates for SUVs and minivans safety is not weight per se, but design: Poor crash ratings for SUVs indicate high risks and design compromises: • SUVs are not as well designed for safety as minivans. Government crash test ratings allow comparisons of crash test results: • In a 35 miles-per- hour (mph) frontal crash test, a dummy driver of the eight-seat 2002 Escalade SUV had a 16 percent chance of a life-threatening head injury, and a 20 percent chance of a life-threatening chest injury. The femur of the right leg also had a very high 35 percent chance of snapping. • Other examples are equally horrific. The 1997 Chevrolet Blazer, GMC Jimmy, and Oldsmobile Bravada received one star in 35 mph frontal crash tests, meaning that the driver dummy suffered head injuries that would produce a 50 percent chance of a life-threatening injury in an actual person. • In contrast, the seven-seater Ford Windstar minivan, which comes in at less than half the price of the Escalade ($25,000), the dummy driver had a 2 percent chance of a life-threatening head injury, a 4 percent chance of a life-threatening chest injury, and a 1 percent chance of breaking either leg. • No SUV won the best five-star rating for driver protection in a frontal crash until the 2001 model year, yet many of these poor performers will haunt the usedvehicle market for years to come. • Other comparisons of SUVs and minivans by crash ratings, weight and price may be found in Appendix A. Heavier, stiffer SUVs are less safe for occupants: • Safe vehicles are designed to crush and to absorb energy so that crash forces are not transferred to the people riding inside or in another vehicle. Yet SUVs are stiffer and heavier than cars or minivans, and absorb far less energy. As Bradsher explains, “SUVs typically outweigh cars and minivans by at least a quarter-ton and sometimes as much as a full ton...But SUVs have little more sheet metal than a car or minivan to absorb the force of all this extra weight in a crash. The front ends of SUVs, measured from the windshield to the front bumper, are not much longer than the front ends of cars or minivans. SUVs typically have much larger engines than cars or minivans, but engines are so stiff that they barely crumple in a crash and absorb little energy.”22 • Most SUVs, like pickup trucks, are built using stiff steel rails added to side panels. Originally designed for vehicles carrying or towing heavy loads, these rails are more stiff, and bend less than the corrugated steel panels that comprise the bodies of cars and minivans. High, tippy SUVs impose special rollover hazards: • SUVs’ high center of gravity makes them more likely to roll over, and the poor level of crash protection in most SUVs puts children inside those vehicles at considerably higher risk of dying in a rollover crash. SUVs lack strong roofs and doors, crash17 www.bettersuv.org Public Citizen June 2003

•

•

safe windows, and safety belt and side head protection airbags and rollover sensors for airbags to protect occupants during a rollover crash, despite the survivability of many rollovers given appropriate crash protection. Although the 2003 Ford Explorer received five stars on its side impact crash test rating , the door became unlatched, opening an ejection portal. Rollover ratings for SUVs continue to be dismal. Model year 2003 SUVs again did poorly in government rollover ratings. None received a four- or five-star rollover rating and the fleet showed little improvement from the 2001 model year.23 This is particularly troubling because rollover is the only area rated by NHTSA in which there is no minimum safety standard, and thus, no “failing” grade. One or two starvehicles are literally below the “floor” on safety, with a risk of rolling over in singlevehicle crash that is 41 percent or more likely to roll over in a single-vehicle crash, versus less than 10 percent for vehicles with the highest rating of five stars. The seat height of many SUVs is mounted higher than the seats in minivans, as is the roof of the vehicle, such as the 6’8” Ford Excursion.24 Yet taller vehicles are more rollover-prone, and higher seats mean that occupants are perched above the SUV’s center of gravity, increasing vehicle loading at the highest levels, another risk factor for rollovers.

In designing, marketing and selling SUVs, family safety has not been the focus: • Of all vehicle types examine by Ross and Wenzel in another study, SUVs had among the highest combined risk ratings, while minivans had the lowest driver risk and lowest combined risk. While families tend to be safer drivers, they found that the difference was so striking as to also be the result of far superior safety design. • Safety-related options may come as standard equipment or be otherwise more widely available on minivans, due to the family focus of the marketing and design of these vehicles. D. TRENDS IN CHILD OCCUPANCY RATES IN SUVS RAISE GREATER CONCERN The chart below shows that minivans and cars have both recently experienced a downward trend in child occupancy, while SUV child occupancy has risen significantly. Parents may be unaware that SUVs pose a much higher risk to children than minivans and large cars, and may be trading in minivans and mid-size cars for SUVs. Sales data also reflect a decline in the sales of cars, and only a very modest upward trend in sales of minivans, when compared to exploding SUV sales figures. If these purchasing trends continue, and SUVs are not re-designed to be less rollover-prone and deadly once in rollover crashes, children will continue to be killed in SUV rollovers at an alarmingly increasing rate. Manufacturers must design a better SUV, and NHTSA has the responsibility under the law to address this growing problem.


Children (aged 10 and younger) per vehicle 0.50 0.45 Children per vehicle

0.40 0.35 Cars Minivans SUVs Pickups

0.30 0.25 0.20 0.15 0.10 0.05 0.00 1991

1992

1993

1994

1995

1996 1997 Year

1998

1999

2000

2001

2002

II. SUVS ARE COSTLY FOR FAMILIES, WHO PAY TOO MUCH AT THE PUMP.

SUV owners pay an average of $350 a year for gas more than they would pay if their SUV was as fuel efficient as a car. This extra payment by SUV owners currently amounts to nearly $9 billion each year in additional gas costs. If 2002 SUVs were as efficient as 2002 cars, 151 million barrels of oil would have been saved in that year alone. Extra Costs at the Pump for Driving an SUV instead of a Car in 2002 Cost per Average gallon MPG per vehicle in average in 200226 200225 SUV 17.3 $1.40 Car 24.3 $1.40

Average vehicle miles driven27 15,000 15,000

Annual Extra cost cost of of driving gasoline an SUV $1,213.87 $864.20

$349.68

Total Extra Gas Costs for American SUV Drivers in 2002 SUVs in the U.S. in 200228 25,426,480

Costs to all SUV owners of driving an SUV instead of a car $8,891,012,060.23


III.

DETROIT CHOOSES WHILE CONSUMERS PAY: “SUPER-SIZED” VEHICLES INCREASE CARNAGE

As currently designed, SUVs are poor performers in terms of safety for their owners, dangerous for other drivers on the road and guzzle gas at an unchecked rate. SUVs are in fact a case study in a key lesson that bigger vehicles are not necessarily safer for the families who drive them or for others on the road. Even in the face of this compelling evidence, however, opponents of fuel economy increases continue to insist that weight and safety are synonymous. The real story is that the current CAFE structure keep profits from this market segment artificially high, encouraging the proliferation of SUVs and other heavier, larger vehicles, with devastating safety consequences for all of us. While it is true that heavier vehicles have some advantage in multiple-vehicle crashes, the size of that “advantage” for occupants, and its payoff for occupants, varies widely from vehicle to vehicle, as shown in other work by Marc Ross and Tom Wenzel (see Appendix B). Moreover, it is unethical for policymakers to perpetuate policies that foster a Darwinian “survival of the heaviest” on the highway. Despite the SUV boom, half of the new vehicles sold are still cars, and it is incumbent on automakers and lawmakers alike to assure that the road is safe for the people inside them. In addition, the simplistic argument regarding weight used by CAFE opponents has absolutely no relevance to a debate over improving the fuel economy of larger and heavier vehicles: Any weight reductions in behemoths on the highway – so-called “light” trucks – would benefit both their occupants and others on the road. Even a combined standard, to the extent it required design changes, would provide incentives for manufacturers to upgrade the fuel economy and reduce weight in the heaviest vehicles in the fleet first, as these changes would provide the most fuel economy credit for each investment in model re-design. Heavier vehicles, and SUVs specifically, impose special risks, making them a threat both to families who drive them and share the road with them. Slimming down these vehicles, and improving their fuel economy at the same time, would be a win-win for safety and the environment. The original CAFE standards doubled fuel economy from 1975 to 1988. So it is reasonable to ask, given the long history of manufacturer sluggishness regarding SUV fuel economy, what engineering improvements are reasonable and possible components of a better SUV? One answer at least is provided by the government data on the predictable “march of progress” in vehicle technologies. New data recently published by the Environmental Protection Agency show that automakers have regularly produced technological innovations that could have been used to dramatically increase the fuel economy of both cars and light trucks.


In the absence of federal requirements to improve fuel economy, however, automakers instead chose to increase the weight and acceleration speed of vehicles while letting gas mileage stagnate at the level required by law. This up-weighting has in turn widened the divergence of vehicle weights on the highway, increasing the deadliness of twovehicle crashes. In addition, faster acceleration may pose handling problems that exacerbate the already-considerable gap in handling between cars and light trucks, with negative consequences for safety. The report on vehicle trends by EPA shows yearly gains in the engine and fuel efficiency of vehicles of 1.9 mpg every year. When compared with the fuel economy legislation of over a decade ago authored by Sen. Richard Bryan (D-NV), which lost by a narrow three votes on a filibuster in 1990, Public Citizen has found that the Bryan bill would have provided a reasonable target and timeline for achievement by automakers. Had the Bryan bill passed, passenger cars would today, on average, get 40 mpg, and light trucks (including vans, minivans, SUVs and pickups) would get an average of 29 mpg. According to the EPA, merely applying engine and fuel efficiency improvements since 1988 towards the improvement of fuel economy would have brought cars on average to 35.7 mpg and light trucks to 25.9 mpg, without any other special effort by automakers. On-the-shelf, currently available technology would have easily been able to fill the gap, as the figure in Appendix F shows. If yearly fuel efficiency gains since 1981 had been translated into higher mpg rather than up-weighting and acceleration gains, cars would now achieve on average, almost 40 mpg, and light trucks would achieve nearly 28 mpg. All sources are the April 2003 EPA Trends Report, unless otherwise noted.29


A. IN THE ABSENCE OF ADEQUATE FEDERAL FUEL ECONOMY STANDARDS, AUTOMAKERS INCREASED THE WEIGHT AND ACCELERATION OF LIGHT TRUCKS The lack of adequate fuel economy standards for light trucks allowed automakers to balloon the overall weight of the vehicle fleet by 24 percent since 1981, as shown in the chart below. Percent Change from 1981 to 2003 in Average Vehicle Characteristics 100 90 80 70 60 50 40 30 20 10 0

Fuel Economy (1% higher) Weight (lbs.) (24% higher) Horsepower (93% higher) 0 to 60 Time (sec) (29% faster)

Although all vehicles got heavier between 1985 and 2003, the bulk of the recent gains in weight was concentrated in the light truck fleet. The key factor for incompatibility – the weight gap between vehicles in the fleet – continues to grow. Year

1975 1988 1990 2001 2003

Light Truck Inertial Weight Average (lbs.)

Car Inertial Weight Average (lbs.)

4072 3841 4005 4462 4595

4075 3092 3175 3379 3410

Difference in Average Weight of Cars and Light Trucks (lbs.) 3 749 830 1083 1185

Two charts showing additional trends in weight changes by vehicle type are below. On average, SUVs gained about 500 lbs. per vehicle from 1985 to 2002.


Average w eight of vehicle types 1975, 1985, 2002 4800 4600

Average Weight in lbs.

4400 4200 4000 3800 3600 3400 3200 3000 2800 1975

1985 Com bined Vehicle Fleet

Car

Van

2002 Pickup

SUV

Light-Duty Automotive Technology and Fuel Economy Trends: 1975 Through 2003 (EPA, April 2003): “[T]he fuel economy of the combined car and light-truck fleet has decreased about six percent from a peak value of 22.1 mpg achieved in 1987 and 1988, with much of this decline attributable to the increased market share of light trucks.” “Technologies continue to enter the new light vehicle fleet and are being used, for example, to increase light vehicle acceleration performance, while fuel economy is not being increased.”


Average W eight Change in Vehicle Groups 1975-2003 4800

4600

4400

Average weight in lbs.

4200

4000

3800

3600

3400

3200

3000 1975

1977

1979

1981

1983

1985

1987

Cars & W agons

1989

1991

SUVs

1993 Trucks

1995

1997

1999

2001

2003

Vans

Another way of viewing the relationship of weight to engine efficiency is to examine trends in the “ton-mpg” of light trucks and cars. Ton-mpg provides an indication of a vehicle’s ability to move weight (its own plus a nominal payload). The EPA Trends Report notes: “Just as an increase in vehicle mpg at constant weight can be considered an improvement in a vehicle’s efficiency, an increase in a vehicle’s weight-carrying capacity at constant mpg can also be considered an ‘improvement.’”30 The ton mpg of both cars and trucks has consistently improved since 1975, rising in a steep curve to above 40 ton-mpg for both cars and light trucks in 2003. Ton-mpg Versus Actual mpg for Passenger Cars 45

Miles per gallon (mpg)

40 35 30 25 20 15 10 1975

1979

1983

1987

1991

1995

1999

2003

24 www.bettersuv.org EPA Adjusted Real-World mpg Public Citizen by inertial weight in tons Ton mpg- Vehicle Adjusted mpg multiplied June 2003

Ton-mpg Versus Actual mpg for Light Trucks

45


40 35 30 25 20 15 10 1975

1979

1983

1987

1991

1995

1999

2003

EPA Adjusted Real-World mpg Ton mpg- Vehicle Adjusted mpg multiplied by inertial weight in tons

B. SUV BOOM RAISES THREAT TO OTHERS ON THE ROAD A vehicle’s aggressiveness in multiple-vehicle collisions is a function of weight (mass), stiffness, and geometry. The goal is to manage crash forces so that both vehicles bear them equally and so that impacts are distributed where they will do the least damage to occupants. The growing aggressivity of our light truck vehicle fleet means that it is both impractical and increasingly unethical to examine vehicle safety only from the point of view of the people riding inside a vehicle. Lawmakers and policymakers must look at the effect of policies on the weight of the total vehicle fleet, and should not perpetuate any further escalation of a “highway arms race” towards heavier and more threatening vehicles. As we have seen, industry has had an enormous stake in pushing for the replacement of cars with light trucks, and neither federal safety standards nor fuel economy standards have reduced the artificially high profit margins associated with these vehicles. The results for highway safety have been nothing short of catastrophic.


Increasing the Weight of Light Trucks, Including SUVs, Increases the Body Count in Collisions A study of the factors most important for aggressivity by vehicle type found that for SUVs and pickups, while weight, height of the center of force, static stiffness and dynamic stiffness all were correlated with aggressivity. While all factors were influential, weight was the predominant factor contributing to the aggressivity of SUVs.31 Key additional findings from more than a decade of research on vehicle aggressivity are below: The Replacement of Cars with Light Trucks is a Safety Disaster •

The steady increase in light trucks is increasing fatalities in cars struck by light trucks.32

•

In crashes between two light trucks, drivers are at more of a risk than in crashes between two cars, so replacing cars with light trucks increases the violence of multiple-vehicle crashes for everyone.

•

Light trucks are considerably more aggressive than cars, regardless of weight, due to design differences, and differences in the center of force in a crash.33 While some studies indicate SUVs are more aggressive than pickup trucks, others conclude pickups are more aggressive. All researchers agrees that SUVs and pickups are substantially more dangerous to other vehicles than cars.

•

An analysis of risk for 1995 to 1999 vehicles by Ross and Wenzel shows that the risk to drivers of the average SUV in single-vehicle crashes is 54 fatalities per million vehicles per year, while it is only 24 for the average large/midsize car, a difference of 18 fatalities per million vehicles per year. Similarly, the risk to drivers of other vehicles from the average SUV is 53, and only 35 for the average large/midsize car (a difference of 24 fatalities per million vehicles). Therefore, replacing a large/midsize car with an SUV would result in an additional 42 (18+24) fatalities per million vehicles per year. If the average vehicle is on the road for 10 years, the total number of additional fatalities would be 42 times 10, or 420 additional driver fatalities, for each million SUVs that are purchased instead of a car.34


•

Ross and Wenzel Top 20 Most Risky Vehicles for Other Drivers 1995-1999 Risk ranking includes the fatality risk to other drivers per million vehicles sold

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20

Type of Vehicle Pickup Truck Pickup Truck Pickup Truck Pickup Truck Pickup Truck Pickup Truck SUV Minivan SUV Pickup Truck SUV SUV SUV Pickup Truck SUV Compact Car Large Car Large Car Subcompact Car SUV

Make and Model Dodge Ram Ford F-Series Dodge Dakota Chevrolet C/K series GMC C/K- series Ford Ranger Chevrolet Tahoe Chevrolet Astro Van Ford Explorer Toyota Tacoma Chevrolet Suburban Jeep Wrangler Ford Expedition Chevrolet S-10 Chevrolet Blazer Nissan Altima Lincoln Town Car Dodge Intrepid Pontiac Sunfire Jeep Grand Cherokee

Risk to Other Drivers 137 128 110 99 92 78 74 61 60 59 59 58 57 55 50 49 47 45 44 44

C. LOST OPPORTUNITIES TO IMPROVE FUEL ECONOMY: THE 1990 BRYAN BILL GOT IT RIGHT In 1990, automakers and their allies in Congress defeated a landmark fuel economy bill authored by Sen. Richard Bryan of Nevada. After a titanic struggle, the bill lost by three votes on a filibuster. The bill’s requirements differed by manufacturer, using the automaker’s 1988 fuel economy as a baseline:

Fuel Economy Car fleet & light truck fleet (calculated separately)

1995 20% increase above a manufacturer’s 1988 fleet mpg


2001 40% increase above a manufacturer’s 1988 fleet mpg

Had the Bryan bill, S.1224, passed in 1990, passenger cars would now get, on average, 40 mpg, and light trucks would get 29 mpg. Approximate changes by manufacturer are presented below:

Chrysler Ford Honda GM Toyota

1988 Car Fleet (mpg)35 28.5 26.6 31.6 27.6 32.1

1995 Bryan Car (mpg) 34.2 31.9 37.92 33.1 38.52

2000 Bryan Car (mpg) 39.9 37.2 44.24 38.6 44.94

Chrysler Ford Honda GM37 Toyota38

1988 Light Truck Fleet36 21.2 20.6 N/A 20.2 23.2

1995 Bryan Light Truck 25.4 24.7 N/A 24.2 27.84

2000 Bryan Light Truck 29.6 28.8 N/A 28.2 32.48

Because fuel/engine efficiency increases by an average of 1.9 percent per year, every year, as the graphs below demonstrate, cars could now get 35.7 mpg and light trucks 25.9 mpg, had manufacturers maintained the same acceleration and weight as in 1988, and put fuel efficiency gains towards improvements in fuel economy.


Potential Passenger Car Fuel Econom y

40 36 32 28 24 20 1988

1991

1994

1997

2000

2003

Model Year EPA Lab mpg 55/45 Potential mpg holding 1988 w eights and acceleration constant



Potential Light Truck Fuel Econom y

30 28 26 24 22 20 1988

1991

1994

1997

2000

2003

Model Year EPA Lab mpg 55/45 Potential mpg holding 1988 w eights and acceleration constant

On average, light trucks went from going 0 to 60 in 12.9 seconds in 1988 to 10.4 seconds in 2003— a gain of 2.5 seconds that is not likely to be noticed by most drivers of SUVs. Gains in engine strength, which went from 141 to 220 horsepower, may be useful for pickup truck drivers who have a need to tow trailers or carry large loads, but is also unlikely to be needed by the typical SUV driver. Yet potential improvements in the fuel economy of SUVs were exchanged for these attributes, at considerable cost to consumers. Economic Costs of Driving Today’s Gas Guzzler Light Trucks Vehicle Type – 2002 MY Actual Light Truck Actual Car Improved Light Truck Improved Car Bryan Bill Light Truck Bryan Bill Car

Vehicle MPG Average Cost per Dollars Approximate Total Costs for Combined costs Miles Gas Cost year saved 2002 vehicle type 2002 Registrations 15,000 17.3 $1.40 $1,213.87 86,516,848 15,000

24.3

$1.40

$864.20

15,000

25.4

$1.40

$826.77 $387.10

15,000

34.3

$1.40

$612.24 $251.95

15,000

29

$1.40

$724.14 $489.73

15,000

40

$1.40

$525.00 $339.20

136,904,022 86,516,848 $33,490,773,849 136,904,022 $34,493,328,798 $67,984,102,647 86,516,848 $42,370,320,019 136,904,022 $46,437,506,227 $88,807,826,246


The Cost to Consumers of Choices by Detroit In 2002, light truck drivers spent an extra $387 on gas that they would not have spent had manufacturers increased fuel economy instead of engine efficiency from 1988. Light truck owners combined spent $33 billion more on fuel. Car owners spent $251 more than they would have if manufacturers increased fuel economy instead of weight and acceleration, totaling $34 billion for all car owners. Combined, light truck and car drivers spent nearly $68 billion more than they needed to, or $242.54 for every man, woman and child in the country.39 In oil terms, the savings are also considerable. If manufacturers had increased the fuel economy of light trucks instead of boosting acceleration and weight from 1988 levels, 569 million barrels of oil would have been saved in 2002. Similarly, if they had increased the fuel economy of cars, 586 million barrels could have been saved in 2002. The total savings for cars and light trucks in 2002 would have been over 1 billion barrels of oil – or about 3 million barrels a day. This represents a savings of twice what the U.S. imports daily from Saudi Arabia. It would have saved about a third of daily oil consumption by U.S. motor vehicles. Over three years, it would have saved more than the entire yield of oil from all drilling in the Arctic National Wildlife Refuge.40 The Cost to Consumers of Losing the Bryan Bill Had the Bryan bill passed, light truck owners would have saved $489 in 2002 on gasoline, totaling $42 billion for all light truck owners. Car owners would have saved $339.20 in 2002, totaling $46 billion in 2002. Combined, light truck and passenger car owners would have saved nearly $89 billion in 2002, or $316.82 for every man, woman and child in the U.S.41 Passage of the Bryan bill would have increased the fuel economy of 2002 light trucks by 40 percent, enabling savings of 720 million barrels of oil over actual 2002 usage. Increasing the fuel economy of cars would have saved 790 million barrels in 2002. Combined, 1.5 billion barrels of oil could have been saved last year alone – more than 4 million barrels each day, almost as much as U.S. daily crude oil imports from OPEC countries.42


Lost Oil Savings From Fuel-Inefficient Vehicles Vehicle MPG Estimated Gallons of Gas Barrels of Oil miles Registrations Consumed Consumed EPA Adjusted Actual 2002 Light Trucks 15000 Passenger Cars 15000 1988 Engine Efficiency 2002 Hypothetical Light Trucks 15000 Passenger Cars 15000 Bryan Bill 2002 Hypothetical Light Trucks 15000 Passenger Cars 15000

Potential barrel savings

Combined savings

17.3 24.3

86,516,848 75,014,608,092 1,786,062,097 136,904,022 84,508,655,556 2,012,110,847

25.4 34.3

86,516,848 51,092,626,772 1,216,491,114 569,570,984 136,904,022 59,870,563,557 1,425,489,608 586,621,238 1,156,192,222

29 40

86,516,848 44,750,093,793 1,065,478,424 720,583,674 136,904,022 51,339,008,250 1,222,357,339 789,753,507 1,510,337,181

IV. CONCLUSION: A BETTER SUV IS BOTH POSSIBLE AND A MORAL IMPERATIVE As currently designed, SUVs are a hazard for families both inside them and for other families on the road. Automakers have the technology to build a better SUV by improving their fuel economy and safety, but have chosen to increase the weight and acceleration of vehicles, at tremendous cost to consumers and to safety. Because Detroit is unwilling to improve safety and fuel economy without federal direction, Congress should: • •

Address the rollover epidemic by requiring rollover crashworthiness protections in light trucks and cars, and requiring a minimum rollover stability standard; Put America back on the road to oil savings and improved safety by raising the light truck fuel economy standard and passing an aggressivity reduction standard.

Because of the economic structure of vehicle design cycles, it would in fact be most cost-effective for automakers to improve fuel economy and safety simultaneously. Meaningful fuel economy standards for SUVs would also improve safety by absorbing efficiency gains and reining in weight increases in the heaviest vehicles in the fleet, producing a win-win for safety and the environment. A better SUV is not only possible with currently available technology— it is a moral imperative given the high costs of SUVs for American families.


Endnotes 1

U.S. Environmental Protection Agency, “Light-Duty Automotive Technology and Fuel Economy Trends: 1975 Through 2003,” EPA420-R03-006, April 2003, at 45 (“…[T]he fuel economy of the combined car and light-truck fleet has decreased about six percent from a peak value of 22.1 mpg achieved in 1987 and 1988, with much of this decline attributable to the increased market share of light trucks.”). 2 According to the most recent data from NHTSA, 42,850 people were killed on the highway last year, up from 42,116 in 2001. National Highway Traffic Safety Administration, Preliminary Estimates of 2002 Highway Fatalities, April 2003. 3 Id. 4 National Center for Statistics and Analysis, Characteristics of Rollover Crashes, April 2002, at 3 and 13. 5 Dr. Jeffrey Runge, “Automotive News World Congress: Meeting the Safety Challenge,” Jan. 14, 2003, at 3. 6 Ross, Marc and Tom Wenzel. Losing Weight to Save Lives: A Review of the Role of Automobile Weight and Size in Traffic Fatalities. ACEEE-To13. Washington, D.C. (2001) (citing Hans Joksch). 7 U.S. Department of Labor Statistics, “Consumer Expenditures in 2001” April 2003 at 3. 8 Despite being marketed to consumers as rugged, go-anywhere vehicles, only 1 to 10 percent of SUV owners use their vehicles for off-road driving or towing. J.C. Collins, Ford’s top marketing manager for SUVs said “[t]he only time those SUVs are going to be off-road is when they miss the driveway at 3 a.m.” Csaba Csere, the editor-in-chief for Car and Driver magazine said in interviews that “the bottom line is that, in every measurement of dynamic ability on pavement, cars outperform trucks,” effectively denying the myth that SUVs handle better than cars in the most common hazardous conditions. See Bradsher, Keith, High and Mighty: SUVs- The World’s Most Dangerous Vehicles and How They Got That Way, 2002, at 112-113, and see Hakim, Danny “Whether a Hummer or a Hybrid, the Big Complaint Is Fuel Use,” The New York Times, May 7, 2003. 9 Dr. Runge said he would not buy an SUV rated with one or two stars (vehicles with a rollover risk of 30 percent or more). One third of the SUVs rated by NHTSA in 2002 failed Runge’s purchase test – only scoring one or two stars. See “Regulator Assails Safety Of SUVs; Blunt Talk Is Unusual In Runge’s Position,” The Washington Post, by Cindy Skrzycki January 16, 2003. And, see NHTSA’s New Car Assessment Program rating for 2002 SUVs at http://www.nhtsa.dot.gov/NCAP/Cars/2002SUVs.html, visited March 13, 2003. 10 U.S. Environmental Protection Agency, “Light-Duty Automotive Technology and Fuel Economy Trends: 1975 Through 2003,” EPA420-R03-006, April 2003. 11 Bradsher, Keith, High and Mighty: SUVs- The World’s Most Dangerous Vehicles and How They Got That Way, 2002, at 112. 12 Hakim, Danny “Whether a Hummer or a Hybrid, the Big Complaint Is Fuel Use,” The New York Times, May 7, 2003. Citation attributed to Michael Flynn, director of the University of Michigan Office for the Study of Automotive Transportation. 13 Hakim, Danny, “Ford Will Phase Out the Taurus and Replace It With 3 Vehicles,” The New York Times, April 16, 2003. 14 Welch, David, “The Sun is Setting on ‘Truckish’ Sport-Utes,” BusinessWeek, Monday, May 5, 2003. 15 SUVs over 8,500 lbs. are held to a less protective side impact standard than applies to cars and need not meet any roof strength standard. In addition, the largest SUVs need not install new anchorage systems to accommodate child restraints. 16 Hakim, Danny, “Generous Tax Breaks for Some SUV Buyers Upset Environmental Groups,” The New York Times, Dec. 20, 2002. 17 Bradsher, Keith, High and Mighty: SUVs- The World’s Most Dangerous Vehicles and How They Got That Way, 2002, at 112-113, and see Hakim, Danny “Whether a Hummer or a Hybrid, the Big Complaint Is Fuel Use,” The New York Times, May 7, 2003. 18 See NHTSA’s New Car Assessment Program at http://www.nhtsa.dot.gov/cars/testing/ncap/ 19

http://myfloridalegal.com/newsrel.nsf/newsreleases/4997F73518725EF685256D110059DC01?OpenDocument This measure of exposure is produced by multiplying the number of registered vehicles by model year (as of Jan 2002), by the number of calendar years that model year has been on the road (6 for model year 1995, 5 for model year 1996, etc.), and dividing by one million. For example, model year 1995 vehicles in 2001 represent six times the number of vehicle-years as model year 2000 vehicles. 21 Marc Ross and Tom Wenzel, “An Analysis of Traffic Deaths by Vehicle Type and Model, “ ACEEE Report Number T021 (March 2002). 22 Bradsher at 145. 20

23

“SUVs fare poorly in latest government rollover tests,” Associated Press June 21, 2003. Bradsher at 104. 25 The average miles per gallon for 2002 MY cars taken from the U.S. Environmental Protection Agency, “Light-Duty Automotive Technology and Fuel Economy Trends: 1975 Through 2003,” EPA420-R03-006, April 2003. The figures are the on-road adjusted combined city/highway (44/45) figures for SUVs and passenger cars. 26 Cost per gallon: The average cost per gallon of gasoline during 2002, according to AAA's Media Site for Retail Gasoline Prices, was $1.40 (at http://198.6.95.31/index.asp visited 4-15-2003). 27 Vehicle miles traveled (VMT): Data based on the National Personal Transportation Survey indicate that first-year travel is over 15,000, and the average numbers in Oak Ridge National Laboratories’ Transportation Databook and the National Resources Council start at 15,600 for new vehicles. 28 Vehicle registration for 2001 given to Public Citizen by researchers at the National Center for Statistics Analysis. Vehicle sales information for 2002 from U.S. Environmental Protection Agency, “Light-Duty Automotive Technology and Fuel Economy Trends: 1975 Through 2003,” EPA420-R03-006, April 2003. 29 U.S. Environmental Protection Agency, “Light-Duty Automotive Technology and Fuel Economy Trends: 1975 Through 2003,” EPA420-R03-006, April 2003. 30 Id.at 1 31 Hans Joksch, “Vehicle Design versus Aggressivity,” Report No. DOT HS 908 194, April 2000. 32 Stephen P. Summers, Aloke Prosad, William T. Hollowell, “NHTSA’s Research Program for Vehicle Aggressivity and Fleet Compatibility,” Proceedings of the Seventeenth International Conference on Enhanced Safety of Vehicles, Paper No. 249, Amsterdam, Netherlands, June 2001. 33 Id. 34 Marc Ross and Tom Wenzel, “An Analysis of Traffic Deaths by Vehicle Type and Model, “ ACEEE Report Number T021 (March 2002). 35 NHTSA, “Summary of Fuel Economy Performance,” October 2002. 36 Id. 37 GM’s light truck fleet mpg is a sales-weighted average of 2WD CAFE and 4WD CAFE averages. 38 Toyota’s light truck fleet mpg is a sales-weighted average of 2WD CAFE and 4WD CAFE averages. 39 Projected 2002 Population: 280,306,000 from http://www.census.gov/population/projections/nation/detail/d2001_10.pdf U.S. Census Bureau 1999 to 2100 National Population Projections, "Annual Projections of the Resident Population by Age, Sex, Race, and Hispanic Origin: Lowest, Middle, Highest, and Zero International Migration Series, 1999 to 2100." Visited 6-9-2003. 40 According to the Department of Energy, the U.S. Imports 1,610,000 barrels of crude oil/day from Saudi Arabia, and U.S. motor gasoline consumption is about 8,610,000 barrels/day. http://www.eia.doe.gov/neic/quickfacts/quickoil.html. According to the Union of Concerned Scientists, 3.2 billion barrels of oil would be recoverable from ANWR http://www.ucsusa.org/clean_energy/renewable_energy/page.cfm?pageID=71 41 Projected 2002 Population: 280,306,000 from http://www.census.gov/population/projections/nation/detail/d2001_10.pdf U.S. Census Bureau 1999 to 2100 National Population Projections, "Annual Projections of the Resident Population by Age, Sex, Race, and Hispanic Origin: Lowest, Middle, Highest, and Zero International Migration Series, 1999 to 2100." Visited 6-9-2003. 42 See http://www.eia.doe.gov/neic/quickfacts/quickoil.html (U.S. crude oil imports from OPEC are 4.787 million barrels/day). 24


Appendices

34

Appendix A

More information on Child Safety The chart below shows the average number of children transported in the most popular vehicles by class (car, SUV, minivan). The subsequent Table outlines the crash safety ratings, fuel economy estimates, weights, and suggested retail prices of select SUVs and minivans. To help used car buyers, the last Table outlines the crash safety ratings and fuel economy estimates, for select model year 1997 SUVs and minivans.

0.7 0.6

0.1

Civic/CRX/del Sol Prizm Corolla

0.2

SL Escort/EXP Cavalier Sunfire Neon

0.3

Neon

0.4

Tracer Jetta Sentra Grand AM Contour Mystique 626 Altima Taurus Sable Lumina Accord Maxima Camry Stratus Lesabre/Wildcat/Centurion Bonneville Marquis/Monterey Intrepid Avalon

0.5

0.0

35

Ranger S-10, T-10 F-series Pickup C,K,R,V-series/Silverado Pickup C,K,R,V-series Pickup (Sierra) Ram Pickup

0.8

Astro Van Caravan Voyager (minivan) Windstar Explorer/Bronco/BroncoII S-10 Blazer 4-Runner Cherokee Grand Cherokee Blazer-fullsize/Tahoe Suburban

Children per vehicle, most popular 1995-99 models (1995-01 data)

1997 Crash Ratings (# of stars),Fuel Economy, Weights Frontal Rating

Minivans Chevy Astro Van Dodge Caravan Plymouth Voyager Ford Windstar

Driver 3 4 4 5

Passenger 3 5 5 5

4 3 3 3

4 1 3 3

3

4 Not Rated 4

Ford Explorer Chevy S-10 Blazer Toyota 4-Runner Jeep Cherokee Jeep Grand Cherokee Chevy Suburban Chevy Tahoe

4

Fuel Economy (mpg) 18 20 20 20 SUVs 15 19 17 Not Rated 15 15 15

Curb Weight (lbs) 4415 3645 3645 3762

Front Rear Not Rated Not Rated Not Rated Not Rated

4242 4026 4179 3488

Not Rated Not Rated Not Rated Not Rated

Not Rated Not Rated Not Rated Not Rated

3785 Not Rated 5400

Not Rated Not Rated Not Rated

Not Rated Not Rated Not Rated

Side Rating

Rollover Rating Not Rated Not Rated Not Rated Not Rated

2003 Crash Ratings (# of stars)1, Fuel Economy2, Weights and Prices Frontal Rating

Minivans Chevy Astro Van Dodge Caravan Chrysler Voyager Ford Windstar SUVs Ford Explorer Chevy S-10 Blazer Toyota 4-Runner Jeep Cherokee (2001) Jeep Grand Cherokee Chevy Suburban Chevy Tahoe

1 2

Side Rating

3 3 3 4

Fuel Economy (mpg) 17 19 22 20

Curb Weight (lbs) 4468 3874 3874 4126

Manufacturer Suggested Retail (2003) $24,395 $21,305 $21,625 $23,755 $26.930 $21,395

Rollover Rating

Driver 3 4 4 5

Passenger 4 4 4 5

Front 5 4 4 4

Rear 5 5 5 4

4

5

5*

5

3

16

4498

3 4

4 4

5 5

5 5

2 Not Rated

17 17

4164 4194

3

3

3

5

2

19

3457

3 4

3 3 Not Rated

4 5 Not Rated Not Rated

2 3 2

17 15 16

3968 5592 5233

$27,565 N/A $29, 352

NHTSA, New Car Assessment Program, http://www.nhtsa.dot.gov/NCAP/Index.html (Visited June 6, 2003). 55/45 City/Highway, EPA, Online Fuel Economy Guide, http://www.fueleconomy.gov (Visited June 6, 2003). 36

$37,865 $35,015

Appendix B

Ross and Wenzel Top 20 Most Risky Vehicles3 by vehicle make, 1995-1999 model year Risk ranking includes the driver fatality risk and risk to other drivers per million vehicles sold

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20

Type of Vehicle Pickup Truck Pickup Truck Pickup Truck Pickup Truck Subcompact Car Subcompact Car Pickup Truck SUV Pickup Truck Subcompact Car Pickup Truck SUV Pickup Truck Compact Car SUV Large Car Midsize Car SUV SUV Large Car

Make and Model Ford F-Series Dodge Ram Chevrolet S-10 Chevrolet C/K series Pontiac Sunfire Dodge Neon Ford Ranger Jeep Wrangler GMC C/K- series Chevrolet Cavalier Dodge Dakota Chevrolet Blazer Toyota Tacoma Pontiac Grand Am Ford Explorer Lincoln Town Car Dodge Stratus Chevrolet Tahoe Toyota 4Runner Buick LeSabre

3

Combined risk 238 225 216 203 202 199 196 194 193 186 184 172 171 157 148 147 143 141 137 133

Marc Ross and Tom Wenzel, “An Analysis of Traffic Deaths by Vehicle Type and Model, “ ACEEE Report Number T021 (March 2002). 37

Appendix C

What Should Be Done on Safety SUVs Need Rollover Crash Standards Congress should: •

Require NHTSA action and issuance of a final rule on a rollover crashworthiness standard that includes: •

Improved roof crush strength and added roof padding;

•

Stronger windshield bonding;

•

Better door locks and latches to prevent ejection;

•

Installation of side air bags;

•

Integrated seating systems with stronger seat backs and tracks and seat belt pretensioners and load-limiters;

•

Advanced head restraints.

•

Require NHTSA action and issuance of a final rule on a crash avoidance standard to prevent rollover.

SUVs Need Aggressivity Reduction Standards Congress should: •

Require NHTSA to improve vehicle compatibility by reducing the aggressivity of larger vehicles, while improving the front and side impact protection of occupants of small and mid-sized passenger vehicles.

•

Require NHTSA to develop countermeasures for large vans, pickup trucks and SUVs to ensure better management and distribution of crash forces.

•

Give NHTSA better funding for crash databases to collect real-world evidence of vehicle incompatibilities.

38

Appendix D

Information on Fuel Economy Standards In April 2003, the National Highway Traffic Safety Administration announced a new standard for light trucks for model years 2005-2007: Current standard 20.7 New standards 2005: 21.0 2006: 21.6 2007: 22.2 2007 Standard Requires Minimal Increase For Big Three Over 2000 Light Truck Fuel Economy Levels

NHTSA standard General Motors Daimler/Chrysler Ford

2000

2007

Change in MPG from 2000 CAFE

20.7 21.0 21.4 21.0

22.2

1.5 1.2 .8 1.2

Big 3 Break Promises to Improve SUV Fuel Economy To stave off Congressional action on fuel economy, in July 2000, Ford, General Motors and DaimlerChrysler made a highly publicized new commitment to improve the fuel economy of their SUVs. Ford announced it would increase the fuel economy of its SUV fleet by 25 percent over five years. General Motors and DaimlerChrysler echoed Ford’s pledge. If these promises had not been broken, this would have resulted in a 1.8 mile- per-gallon increase in Ford’s entire light truck fuel economy by 2005 – six times the increase required by NHTSA’s new standard for that year.

39

Appendix E

The Costs of Living in “SUV Country”

SUV Rollover deaths between 1991 and 2001 and cost, in millions, of these casualties4 SUV Cost of deaths in Rollover millions Deaths 1991-2001 1991-2001 Alabama 447 $1,519.8 Alaska 71 $214.1 Arizona 568 $1,931.2 Arkansas 279 $948.6 California 1,639 $5,572.6 Colorado 559 $1,900.6 Connecticut 87 $295.8 Delaware 39 $132.6 District of Columbia 18 $61.2 Florida 773 $2,628.2 Georgia 570 $1,938.0 Hawaii 44 $149.6 Idaho 193 $656.2 Illinois 438 $1,489.2 Indiana 198 $673.2 Iowa 108 $367.2 Kansas 184 $625.6 Kentucky 254 $863.6 Louisiana 250 $850.0 Maine 67 $227.8 Maryland 148 $503.2 Massachusetts 148 $503.2 Michigan 376 $1,278.4 Minnesota 214 $727.6 Mississippi 162 $550.8 Missouri 402 $1,366.8

4

Montana Nebraska Nevada New Hampshire New Jersey New Mexico New York North Carolina North Dakota Ohio Oklahoma Oregon Pennsylvania Rhode Island South Carolina South Dakota Tennessee Texas Utah Vermont Virginia Washington West Virginia Wisconsin Wyoming U.S. Total

SUV Rollover Cost of deaths in Deaths millions 1991-2001 1991-2001 231 $785.4 157 $533.8 293 $996.2 51 $173.4 198 $673.2 397 $1,349.8 385 $1,309.0 391 $1,329.4 48 $163.2 241 $819.4 271 $921.4 236 $802.4 456 $1,550.4 39 $132.6 257 $873.8 94 $319.6 439 $1,492.6 1,608 $5,467.2 315 $1,071.0 41 $139.4 349 $1,186.6 262 $890.8 158 $537.2 263 $894.2 193 $656.2 15,609

$53,043.3

State-specific SUV rollover fatality statistics provided to Public Citizen the National Center for Statistics Analysis. The National Highway Traffic Safety Administration cost per traffic fatality of $3.4 million in 2000 dollars does not include the costs of pain and suffering of victims or the emotional toll on families - Blincoe, Lawrence J., et al, “The Economic Impact of Motor Vehicle Crashes 2002,” May 2002, DOT HS 809 446.

40

SUV Rollover Deaths 1991-2001 by State 262

67 48

231

41

214

51

236 193

263

94

385

193

148 87

376 456

108 157

293

438 315

1,639

241

198

158

559 184

349

402

254 391

439 568

397

271

257

279 162

447

570

250 1,608

71

773

Rollover Deaths 1991-2001 by State (number of States) 44

41

400 270 210 110 10

to 1,640 (11) to 400 (9) to 270 (9) to 210 (10) to 110 (12)

NJ-198 DE-39 MD-148 DC-18

Cost of SUV Rollover Deaths 1991-2001by State in Millions 890.8 227.8 785.4

163.2 727.6

802.4 319.6

656.2

1,309

894.2 1,278.4

656.2

1,550.4

367.2 533.8 996.2

819.4 1,489.2

1,071

673.2 537.2

1,900.6

1,186.6

1,366.8

625.6

5,572.6

863.6 1,329.4 1,492.6

921.4 1,931.2

1,349.8

873.8

948.6 550.8

1,519.8

1,938

850

5,467.2

2,628.2

214.1

149.6

Cost in Millions of SUV Rollover Deaths by State (number of States) $1,350 to $5,580 (11) $920 to $1,350 (9) $730 to $920 (8) $370 to $730 (11) $60 to $370 (12)

42

NH-173.4 VT-139.4 MA-503.2 RI-132.6 CT-295.8 NJ-673.2 DE-132.6 MD-503.2 DC-61.2

Appendix F

The SUV That Could Be – www.bettersuv.org Using Available Safety and Fuel Economy Technology Inflatable safety curtains: prevent ejection and protect against head injury, should be installed in every outboard seating position.

Roll cage and reinforced roof: prevent roof crush in rollovers.

Interior padding: prevents injury from contact with vehicle interior.

Gyroscopic rollover sensors: monitor roll rate and angle, trigger traction control and inflatable safety curtains airbags to prevent head injury.

Active air management: optimizes air flow for engine speed.

Seatbelt pretensioners: tighten belt-slack prior to impact, keeping passengers firmly in place.

Aerodynamics: Redesigning bumpers, side mirrors, & wheel covers to reduce wind resistance.

Web grabbers: prevent seatbelts playing out in crashes.

Traction control: monitors wheel grip, prevents skidding and loss of control by adjusting tire torque automatically.

Cylinder deactivation: shuts down fuel to cylinders during light operation.

Hybrid powertrain: combines electric motor and internal combustion engine.

Integrated starter generator: provides start-stop operation.

Lower center of gravity: To reduce rollover propensity.

Adaptive auto transmission: optimizes transmission performance. 43

Lower cross-member and low profile bumper: engages bumper of smaller cars, prevents override.

Continuously variable transmission: keeps engine rpm in most efficient range.