ATG Applauds EPA for Using Size-Based 'Footprint' Approach to Regulate Fuel Consumption, CO2 Emissions

The North American aluminum industry supports continuation of the size-based "footprint" approach to regulating fuel consumption and C02 emissions, the Aluminum Transportation Group (ATG) has told federal regulators.

Given the safety, fuel economy, and emission benefits associated with larger, yet lighter vehicles, "we believe this approach recognizes and encourages manufacturers' aggressive development and implementation of advanced fuel efficiency improvement technologies throughout the vehicle fleet," ATG said.

ATG made the statement in written comments submitted February 11 to the Environmental Protection Agency (EPA) and the National Highway Traffic Safety Administration (NHTSA) on the agencies' Notice of Proposed Rulemaking on reducing fuel use and greenhouse gas emissions from passenger cars and light-duty trucks for model years 2017–2025.

"The ATG believes the identified approach of using annual assessments of vehicle footprint, fuel economy performance, and sales mix to establish individual OEM fleet fuel economy targets will ensure that OEMs receive full credit for advances in vehicle efficiency technology, while ensuring achievement of national fuel economy objectives."

"Reaffirmation of a size-based approach stands as a major milestone for the auto industry, forward-thinking suppliers, and consumers. It is clear, to save energy and reduce emissions, a transition to strong, affordable, and carbon-reducing materials, like aluminum, already is under way. By utilizing these materials, cars and trucks will get lighter—not necessarily smaller—and more fuel efficient. As both NHTSA and EPA have signaled in agreement, such a transition is a good thing for consumers and the environment."

According to the ATG, downweighting, without downsizing, has become an increasingly important element in most comprehensive original equipment manufacturers' (OEM) vehicle efficiency improvement strategies. As automakers transition towards greater use of lightweight materials, the focus is increasingly toward system cost. Aluminum is widely recognized as a cost-effective choice for reduced-weight automotive components and structures. As automakers turn to greater aluminum use, secondary weight reduction is emerging as a major cost savings opportunity.

Vehicle weight reduction with aluminum allows a reduction in the size, weight, and cost of powertrain and chassis components (secondary weight reduction) without sacrificing performance or safety. Cost savings from secondary weight reduction can offset a majority of the cost premium associated with conversion to aluminum. This allows aluminum to compete successfully with other materials because of the advantages it brings in primary and secondary weight savings, fuel savings, structural performance. and design flexibility.

Since the aluminum industry provided comments on the agencies' Notice of Intent regarding this rulemaking in October 2010, additional research has been completed that reinforces the conclusion that downweighting with aluminum can be done both safely and economically: a survey of North American automakers conducted by Ducker Worldwide, a separate and independent survey of automakers by DuPont, statements by a high-level Honda executive at the recent International Automotive Body Congress, and findings of a new report on life-cycle cost analysis commissioned by the European Union, titled "Support for the Revision of Regulation (EC) No 443/2009 on CO2 Emissions from Cars."

EPA/NHTSA's final rule is expected to be published in August 2012.