CAFE Standards: Do They Work? Do They Kill

Sam Kazman

“CAFE Standards: Do They Work? Do They Kill?”

Speech At The Heritage Foundation

February 25, 2002


The point that I want to start with, and it’s also a point I’ll come back to, is that the debate we’re seeing right now over CAFE is a fundamentally dishonest debate. I’ve been involved in this issue since the late 1980’s, and before the National Academy of Sciences issued its CAFE report this past summer, I had never met a single defender of CAFE who admitted that it kills anyone. It’s not as if they said: “Yes it kills people, but not as many people as CEI claims.” And it’s not as if they said: “Yes it kills people, but we should still have this program for other reasons.” No, I never met a single person who defended CAFE – let alone a single person who wanted to make CAFE more stringent – who admitted that it kills anyone whatsoever. For them, it was always a win-win proposition for consumers and industry. And win-win-win for the environment as well. And now win-win-win-win for national security as well.


None of them had ever said that CAFE kills. They didn’t admit that CAFE kills anyone after Bob Crandall and John Graham published their 1989 study, which found between 2,200 and 3,900 deaths annually from CAFE. They didn’t admit that it kills anyone when we won our court decision in 1992. They didn’t admit that it kills anyone when USA Today published its extensive 1999 analysis of CAFE, finding over 40,000 deaths over the lifetime of this program. They didn’t admit that it kills anyone.


Then the National Academy of Sciences issued its report last August, and it found that CAFE kills between 1,300 and 2,600 people per year due to its constraining effect on producing larger cars. For a program that’s been in effect for more than two decades, that’s a huge number.


And what happened after that report came out? They still don’t admit it kills anyone at all.


The debate over CAFE, for that reason, is a fundamentally dishonest debate.  I will get back to that.


Why does CAFE kill? It does so because it constrains the production of larger cars. And in most modes of collision, larger, heavier cars are more protective of their occupants than are small cars. Let’s consider first of all single vehicle crashes, where about fifty percent of all occupant deaths occur. Extra mass in a car involved in a collision with a tree, or a bridge abutment, or a brick wall, is incredibly protective. You find differences in survival rates between sub-compacts and larger cars on the order of four times as great or eight times as great. There is simply no question that in single vehicle crashes, larger, heavier cars are safer.


The other half of all occupant deaths, however, occur in multi-car collisions, largely in two-car collisions. And there, the issue gets a little more complicated. The analysis I’m about to give you is based on the work of Dr. Leonard Evans, who is head of the International Traffic Medicine Association, who’s been a researcher in this field for three decades, and who has this up on his website at


Essentially it’s a very complex issue, but the net effects tend to be very small. In multi-car collisions, adding mass to your car protects you more, but it does put the occupants of the other car at somewhat greater risk. And so the question is: what is the net effect? Does society benefit – or is it hurt – by adding mass to the car that you’re driving?


Here’s how it breaks down. When the two cars that are involved in that multi-car collision are pretty much identical, larger mass helps the occupants of both cars. When they’re not identical, but they’re pretty similar to each other, adding mass to your car tends to protect you and it hurts the occupants of the other car. But its net effect is protective, and so society benefits there as well from added mass.


Finally, when there’s a huge difference between the mass of your car and the car you strike, the extra mass in your car actually poses a disservice to society. That is, it adds more risk for the people in the other car than it does to protect you.


When you add all of those scenarios together, in the area of multi-car collisions, it’s not clear what the answer is. But it is a relatively small effect. In Dr. Evans’ view, added mass in multi-car collisions probably benefits society. In the view of some other people, it hurts overall social safety. But whatever that multi-car effect of mass is, it’s totally outweighed by the protection offered by added mass in single car collisions. And for that reason, in Dr. Evans’ words, “CAFE kills. More stringent CAFE standards will kill even more.”


Some people ask about the National Highway Traffic Safety Administration’s tests? NHTSA has multi-star test ratings for cars, based on crashing them into nondeformable barriers.  We see small cars getting three and four stars – top ratings from NHTSA– and we also see large cars getting three and four stars. So small cars seem to do as well as large cars here.


Well, the problem is that if you look at the NHTSA test results, they expressly state that you cannot compare these ratings across different weight classes.  In fact, NHSTA’s test results also used to say – before they went on the Web – that larger cars are more protective than small cars. I can’t find that statement on the web, and that’s something I’ll get back to—how the political incorrectness of large cars has incredibly distorted the information that we’re getting.


Now, what arguments do proponents of CAFE – especially those who want to make CAFE more stringent – offer? They essentially offer three arguments and one image, and let me quickly describe them.


The first argument is that new technology can get us out of this bind. It can give us much higher fuel economy and much greater safety, and so there is no trade-off here. Now I want you, as a thought experiment, to imagine the most high tech car you can. It’s got incredibly advanced, incredibly efficient valves and engines, and incredibly great safety devices. Picture that car in your mind, and then add a few additional cubic feet to that car and a few additional pounds, to make it a little bit bigger, and a little heavier.


Two things happen. This high tech car, once you made it bigger, is a bit safer. But it’s also a bit less fuel-efficient. That is, you’ve got a tradeoff even at this incredibly high tech frontier. You’ve got a tradeoff between safety and fuel economy.


And so high technology doesn’t get you out of this bind. As Leonard Evans says, this is like a tobacco industry executive saying that smoking doesn’t endanger your health, because with everything we now know about eating right and exercising right, you can smoke and still be as healthy as a non-smoker.


Well, it’s true that, with what we know about diet and exercise, smokers can be healthier. But this knowledge can make a nonsmoker even healthier yet. And if you smoke, you’re going to be taking a risk.


The folks who are selling you CAFE, more stringent CAFE, on the basis of high technology, are arguing with no different logic than that. It’s as if they were trying to sell you tobacco with the claim that it’s risk-free.  There is a risk, no matter what technologies are developed.


What is the second argument? It’s this: Look, here’s a chart of the death rate in cars. And we see that since the 1970’s, when CAFE was enacted, that death rate has steadily improved. And yet, cars have been downsized. The average car today is 900 to 1,000 pounds lighter than it was in the mid 1970’s. How can you tell me that downsizing cars makes them more dangerous when the death rate has been steadily improving?


To answer that, let me do an analogy. I’m going to use that same logic to show you that AIDS is not a health threat. Because in 1970 we had zero cases of AIDS. Now, we’ve got several tens of thousands. And yet longevity – life expectancy – in the U.S. now, is about ten months greater than it was in 1970. So how can you tell me that AIDS is a health threat when longevity has been improving?


Well, the real answer is that longevity has been improving not just since AIDS appeared, but since it began to be recorded. Human life expectancy has been steadily getting better. Were it not for AIDS, it would be even better still. The same is true for the death rate in cars. It has been improving, not just since we began to downsize cars, but since we began to actually record the data. And it would have improved even more.


You cannot look at a long-term improving trend in traffic safety and use it to argue against the effects of CAFE.


What’s the last argument they use? They say: CAFE can’t be deadly. It’s endorsed by Ralph Nader, Joan Claybrook, and Clarence Ditlow. They is exactly what they say. If you go to the Sierra Club’s web page on global warming and CAFE, and go to the questions and answers, the very first question asks, doesn’t CAFE undermine safety? The very first answer is: Nonsense. It’s endorsed by Nader, Claybrook, and Ditlow. And it’s true. It is endorsed by them.


But long before large cars become so politically incorrect, these very same folks stated very forthrightly that larger cars are safer cars. In 1989, in a magazine interview, Ralph Nader was asked for advice on buying safer cars. He said, first, buy one with an airbag. Secondly, buy a larger car.


In 1972, Nader and Ditlow published a book called Small on Safety, a critique of the Volkswagen Beetle. Page after page in here has statements like: “Small size and light weight impose inherent limitations on the degree of safety that can be built into a vehicle.”


What’s happened? Back then, large cars were not politically incorrect. Now they are.


A month ago, Joan Claybrook appeared before the Senate Commerce Committee, and gave a huge diatribe on how the CAFE-safety tradeoff was a myth propagated by industry. But in 1977, she appeared before that same committee and she said “There are going to be tradeoffs.” The exact opposite.


Why have these folks taken this view on this position? Because for them, the line all along has been: You want more safety? You need more government. You need another government regulation if you want a safer product.


With CAFE, all of a sudden, it’s exactly the opposite.


One other point here on the political incorrectness of large cars, and what’s it meant for the information that consumers get: Every year Consumer Reports has an annual buying-guide issue. It comes out in April. It rates all the models. It has a very extensive discussion of how to buy a safer car.


You have to dig through that safety article, midway through or longer, to find any mention of the fact that larger cars are safer. In some years, it’s not said at all.


On the other hand, go to the website of the industry that probably has the most direct stake in accurately assessing vehicle crashworthiness: the auto insurance industry. Go to the website of the Insurance Institute For Highway Safety. Look in their “Tips For Buying A Safer Car.” One of the very first factors they mention is that large cars are safer than small cars.


You don’t find it in Consumer Reports, but you do find it at the IIHS website.


Now, I said that proponents of CAFE have three arguments, and one image. What’s the image? It’s the image of a Ford Explorer devastating a Geo Metro. A large SUV just killing everyone inside a sub-compact when there’s a collision between the two. It’s a very gripping image, but it’s very, very unrepresentative of the total universe of vehicle collisions. According to the Insurance Institute, it is a highly irrepresentative example. And the real issue isn’t so much the larger size of the Explorer, but the small size of that subcompact. If you want to improve auto safety, you have to do something about the size of the subcompacts.


And, by the way, suppose you do use CAFE to start shrinking the size of the Explorer.  Well, look at the fatality data, the rollover data for SUVs alone; it turns out that smaller SUVs are much less safe than larger ones. Just as with passenger cars.


One interesting side note on the Ford Explorer-Firestone issue. Public Citizen, last April, issued a very detailed report on that. And their chronology is essentially as follows: Ford had requested Firestone to redesign the Explorer’s tires so it was more fuel-efficient. Firestone attempted to do that, and the result was a defective product.


So here is an example of one company, in its quest for higher fuel economy, producing a defective product. Yet that was never the focus of any attention whatsoever. Days after that report came out, Senator Diane Feinstein introduced a bill to, in essence, put every SUV manufacturer in the same box that Ford was with respect to the Explorer. Namely, force them to improve fuel economy for their SUVs, and do it quickly.


By the way, if you go to the website of the Union of Concerned Scientists – a longtime defender of CAFE – they present some supposedly well-tested technologies for improving fuel economy; among them is tire redesign.  And yet, as the Ford-Firestone tragedy shows, that technology can be risky.


No one pushing for higher CAFE admits that it kills anyone. One thing that they claim is that, with higher CAFE, we would be kept out of all of these blood-for-oil wars.


But in a sense, CAFE itself is a blood-for-oil battle. And it is waged not with knowing soldiers – with a military that knows it’s being put at risk – but with civilians who have no idea that they’re being placed in any danger whatsoever.


What does happen when the public learns about the CAFE safety issue? Well, we’ve all been seeing polls week after week recently that supposedly show that three hundred percent of the American public wants higher CAFE standards. But look at the questions that are asked; they never say anything about the safety issue.


As indicated by the poll we’re releasing today, once you tell the public about the safety issue, their views of CAFE change dramatically. When we first asked people about what they think of CAFE, sixty percent support it. No surprise there.


Once we introduce them to the safety issue, that support drops to only forty-two percent in favor against thirty-nine percent in opposition. Pretty close to a dead heat.


And when they’re then asked: “Do you support more stringent CAFE standards?”, forty-eight percent – a plurality – oppose that.


Once the public learns about safety, once they learn about the issue that CAFE’s proponents refuse to acknowledge, their views on CAFE change dramatically. And that is something that folks in Congress should keep in mind. The safety issue is an issue that can change this debate. It can change public opinion. It should change public opinion.


If the National Academy’s report last August involved not CAFE, but a privately produced chemical, and if they found that it killed not 1,300 to 2,600 people per year, but 13 to 26 people per year, we would have had demands from the entire environmental movement to prohibit it. Congress would have scrambled to ban it overnight.


CAFE, however, is not a privately produced product, it is a government program. So finding that it has fatality effects has led to calls to actually make it even more stringent. Ask yourselves: Where’s the Precautionary Principle when we need it?


Thank you.