Efficiency standards: No public comment?

This is the season of bailouts.  A great many people did foolish things with other people's money, and now Congress is putting the US taxpayer on the hook for it.

The $700 billion bailout of Wall Street is the biggest of these, but far from the only one.  With Congress handing out fiat money, the auto companies have also begged for and been granted a $25 billion slice of the pie.  The only thing left to be determined was the terms under which they could qualify.  Those terms have now been set, and they don't look good.

Granting money to do what's already been done better

The oxymoronic Interim Final Rule sets out the following standards (table format borrowed from Green Car Congress):

Baseline fuel economy eligibility by vehicle class
Vehicle class	2005 FE average	Baseline (2005 FE x 125%)
Two-seater	25.3	31.6
Two-seater performance	22.2	27.8
Minicompact sedan	29.3	36.7
Minicompact performance sedan	22.4	28.0
Sedan	22.4	28.0
Subcompact sedan	29.6	37.0
Subcompact performance sedan	22.8	28.5
Compact sedan	33.8	42.2
Compact performance sedan	23.6	29.5
Mid-size sedan	29.4	36.7
Mid-size performance sedan	23.1	28.9
Large sedan	26.2	32.7
Small wagon	32.7	40.8
Mid-size and large wagons	26.7	33.4
Small and standard pickup	19.7	24.6
Minivan	24.3	30.4
Passenger van	19.0	23.8
Cargo van	24.2	30.2
SUV	21.8	27.2

These figures are ridiculously low.  They do not even come up to the standards of vehicles available today.  My 2004 Passat TDI, which is either a medium sedan or a large sedan under the rules, has achieved better than 38 MPG in mixed driving despite its antiquated 5-speed automatic transmission.  Achieving 32.7 MPG requires no R&D whatsoever, just building cars with an emphasis on efficiency.  What kind of advance does it take to put a 4-cylinder engine into a vehicle?  Is there any mystery about Atkinson cycles, or dashboard displays with economy feedback?

Over in the GCC thread, commenter Will S opines "And with Prius already achieving 48 mpg overall, the 35 mpg CAFE 2020 "target" is a joke. Is [sic] should be closer to 75 mpg..."  I could not agree more.

And the public frozen out

Which is why the lack of public comment on this rule is so troubling.  The comments from auto manufacturers and suppliers stand alone; the public, whose money is involved and whose available choices are being determined and limited by this process, has had no opportunity to be heard.

This is wrong, and should be changed immediately.  Whatever my reservations about the policies of an Obama administration, I have reason to expect that this is likely to get better.

¶ 11/07/2008 11:51:00 AM