I blogged on January 24, 2008 on the National Automobile Dealers Association's (NADA) new report complaining about complying with the California Clean Cars Program. The study makes the following claim: "On a national level, the new federal CAFE standards will be higher than what CARB has adopted..." (see page 9 of their study).
This claim is very misleading. The bottom line is that California's standards are more stringent and would reduce more global warming pollution if applied on a national level than the proposed federal fuel economy standards. When comparing the standards on the basis of actual global warming pollution reductions, the California program is more stringent by the equivalent of 1.7 mpg in 2015. Here's why:
First, the proposed CAFE standards that the NADA study presents do not take into account the very generous flex fuel vehicle (FFV) credits that the CAFE program allows. The way the credit works is that the automobile industry in say 2015 is allowed to achieve 1.0 mpg lower fuel economy than the nominal standard just by building relatively cheap FFVs. These vehicles, while capable of being run on gasoline or ethanol, never actually run on ethanol (the so-called "FFV loophole"). That is, the supposed 31.6 mpg standard in 2015 is in effect only 30.6 mpg (for 2011-14, the credit is 1.2 mpg). For more details, see the California Air Resources Board's recent study comparing their program to CAFE (table 1, page 4).
Second, the CARB analysis that NADA cites assumes that automakers will substantially improve air conditioning systems to make use of CO2 credits in the California program. However, since the CAFE program ignores air conditioning emissions, there is no reason to believe the automakers will make such improvements in absence of the California program. Thus, the CAFE program would have to raise its standard by an additional 1.0 mpg in 2015 to make up for the global warming pollution benefits of air conditioning improvements assumed by CARB. The 31.3 mpg fuel economy equivalence CARB estimates for 2015 actually provides the equivalent of 32.3 mpg of global warming pollution benefits with improved air conditioning properly accounted for.
Applying the above more accurate assumptions to the numbers in the NADA study yields an "apples to apples" comparison on the basis of global warming pollution benefits as shown below. The table shows that a national version of the California program reduces more global warming pollution, equivalent to a 0.5 to 2.1 mpg increase in fuel economy levels over the proposed CAFE standards.
Comparison on GHG Emission Benefit Basis
Model Year CAFE California Gap
2011 26.6 27.2 0.5
2012 28.0 30.1 2.1
2013 29.3 30.8 1.5
2014 29.8 31.3 1.5
2015 30.6 32.3 1.7