Grad students showed how real people can shape CAFE standards

Americans, particularly during this heated election season, can be forgiven if they assume that their government never listens to them. That federal policy that impacts the everyday lives of hard-working families is simply crafted on a whim, behind closed doors, beyond public view.

That certainly wasn’t the case with the Environmental Protection Agency (EPA) when it set about revising the CAFE standards, the landmark set of rules created by Congress in 1975 designed to curb the nation’s dependence on oil.

A group of graduate students in the Bren School of Environmental Science and Management at UC Santa Barbara not only weighed in on the proposals during the 60-day public comment period, they made a class project out of it and ended up shaping federal policy that has had a pronounced benefit on the nation’s air quality.

The government listened.

“For me it was a surprise. I had no idea. I was just a citizen,” said Robin Vercruse, Fuel Freedom’s Vice President of Policy and Environment. She worked on the project as a Masters student in the fall of 2009.


Bren Hall at UC Santa Barbara.

Vercruse and nine of her classmates took part in a working group led by Dr. Charles Kolstad, one of the world’s leading experts on the economics of climate change. Intimately familiar with the Corporate Average Fuel Economy standards, he made the project into a quarter-long seminar, once the proposed rules were published in the Federal Register on Sept. 28, 2009.

This was an interesting and complex time in the then-34-year-long history of the CAFE standards. Until then, fuel efficiency were the separate domains of both of the National Highway Traffic Safety Administration (NHTSA), which had been focused squarely on reducing oil consumption in the wake of the 1973 OPEC oil crisis; and of the EPA, whose purview was strictly the environmental impact of tailpipe emissions, as measured in grams of pollution per mile driven. In 2009, for the first time, the two agencies set about combining their distinct sets of rules into one document.

The agencies’ initial proposal set off a 60-day public comment period. The clock was ticking.

The team focused on several different areas, but became frustrated by an algorithm in the proposal, which produced a vehicle technology adoption “curve” that displayed the expected relationship between vehicle size and fuel economy over time. The model used by NHTSA didn’t seem to add up, based on the Bren team’s analysis. What to do? Call up NHTSA and ask them about it, Kolstad urged.

“We basically said, ‘Hey we can’t re-create this curve,’ ” Vercruse said. “So they went back and acknowledged that, and then went and changed it to ensure that people could actually reproduce it.”

After taking into account the public comments — submitted in writing and during a series of hearings — the feds acknowledged that they had erred with their numbers.

“They were very transparent with us about it, which was quite refreshing,” said Natalija Glusac, then a Ph.D. student in the Bren program who took part in the seminar. “It was, ‘Hi, we’re a bunch of grad students, and we were doing this class and looking at it, and we were just wondering how you got to this number.’ They were fairly responsive. And that’s their job, to be responsive, and I think that’s something the public likely doesn’t understand.”

In the Final Rule, published on May 7, 2010, officials noted the Bren team’s contributions:

” … considering comments by the UC Santa Barbara students regarding difficulties reproducing NHTSA’s analysis, NHTSA reexamined its analysis, and discovered some erroneous entries in model inputs underlying the analysis used to develop the curves proposed in the NPRM [notice of proposed rulemaking].”

The rules, which covered light-duty cars, trucks and SUVs made for model years 2012 through 2016, helped fuel efficiency across the U.S. fleet keep rising: Vehicles sold in the U.S. averaged 24.1 mpg for MY2013, then the highest on record. But the gains have been slowing the last couple years. The average is around 25 mpg today. The auto industry has some catching up to do if it hopes to hit 54.5 mpg by 2025, the target under the most recent iteration of the CAFE standards for MY2022-25.

Not every vehicle has to hit 54.5: There are separate standards for passenger cars versus trucks and SUVs, and automakers get special credits for selling lower-emissions vehicles like hybrids.

Those seemingly arcane rules affect every American. Which is why it’s important that people know about them, and if they’re so inclined, to offer their opinion. The UCSB team showed it’s possible to influence a crucial aspect of public policy.

“It’s something that I wish every American knew about and could tangibly contribute to. … If you know something about a certain area and you take the time to learn about it, you actually can make a difference,” Vercruse said.