The footprint provision was intended to be a kind of grandfather clause that would protect automakers with larger fleets—which happen to be General Motors, Ford, and Chrysler—from rule changes that would create abrupt disadvantages. But there seem to be unintended consequences. Volkswagen, for instance, expects its passenger cars to average about 29 miles per gallon in 2011, slightly better than those of the Detroit automakers. But because its cars are generally small, its required mileage is 35.4 mpg—near the top of the scale. That means Volkswagen has to improve the fuel efficiency of its planned fleet—already deep into development—by 23 percent to meet the new standard.
That's a tall order. "For anybody within 10 percent or less, it shouldn't be that big a deal," says David Cole, chairman of the Center for Automotive Research. The carmakers ought to be able to substitute smaller engines, more efficient transmissions, and lighter materials to help reach the required mpg numbers. "But over 20 percent," says Cole, "it's going to be tough."
Volkswagen and Subaru say they're working on diesels, electric cars, and other high-mileage solutions to the problem. But both companies are also likely to lobby for a change to the rules, which aren't final yet. "It seems inherently unfair," says Subaru spokesman Michael McHugh. "We've been building small cars for a long time, and it feels like we're being punished."
The Detroit Three fare OK. Executives from the domestic automakers have complained that the new targets will require costly new technology—but they're closer to their targets than some competitors. For both passenger cars and light trucks (which the government treats as two separate categories), GM, Ford, and Chrysler are all within 10 percent of their targets. In fact, for light trucks—which include SUVs and pickups—GM is in pole position. Even though GM's average mileage for light trucks will be a relatively low 22.9 mpg in 2011—in the bottom half—it will need to improve its numbers by just 4.4 percent to meet its target.
The domestic makers will also benefit from credits for building "flex fuel" vehicles that can run on ethanol, which will effectively lower the mileage targets they have to meet. Many automakers will probably offer flex-fuel vehicles by 2011, but the Detroit Three will still build the most.
average mpg, 2011
average mpg, 2011
|How much mpg
must be improved
Sources: National Highway Traffic Safety Administration, "Notice of Proposed Rulemaking, Average Fuel Economy Standards, Passenger Cars and Light Trucks, Model Years 2011-2015;" "Preliminary Regulatory Impact Analysis, Corporate Average Fuel Economy for MY 2011-2015 Passenger Cars and Light Trucks."
Notes: Manufacturer production plans are preliminary in some cases and are based on "adjusted baseline" numbers, as computed by NHTSA, which account for certain manufacturers making minor technological changes to meet government requirements.