EJECUCION Y TRAMITE DE PROYECTO

The committee explained that although direct costs and benefits are critical to understand, as the economics of technology implementation are a primary decision attribute for manufacturers, carriers, and operators, the indirect costs, benefits, effects, and externalities should also be addressed in developing a regulatory system.188 The committee considered, at a high level, the following indirect costs and benefits, including (1) fleet turnover effects, (2) ton-miles traveled and the rebound effect, (3) vehicle class shifting by consumers, (4) environmental co-benefits and costs, (5) congestion, (6) safety impacts, (7) incremental weight effects, and (8) manufacturability and product

development.189 The committee stressed that this was not an exhaustive list of indirect effects, and encouraged the agency to assess possible indirect effects during policy development to help avoid or mitigate negative unintended consequences.190

Fleet turnover effects: The committee stated that consumer buying in anticipation of new regulations (pre-buy) and retention of older vehicles can slow the rate of fleet turnover and the rate at which regulatory standards can affect in-use fleet fuel

consumption.191 However, the committee expressed its belief that these effects will be transient and reduced to the extent that fuel consumption savings offset incremental purchase costs.192 The committee suggested that government incentives in the form of tax credits or excise tax reductions with a sunset date could be used to help minimize 185 Id. at 156. 186 Id. 187 Id. at 157, Recommendation 6-1. 188 Id. at 149. 189

Id.; see also Id. at 156, Finding 6-9.

190 Id. at 150. 191 Id. at 156, Finding 6-10. 192 Id.

anticipated pre-buy/low-buy fluctuations in the future.193 The committee emphasized that regulators must be cognizant of these potential effects and should consider regulatory mechanisms that minimize these potential distortions.194

Rebound effect: The “rebound effect” for MD/HD vehicles measures the increase in ton-miles shipped (or more generally, vehicle miles driven) resulting from a reduction in the cost of shipping (or more generally, driving). The committee stated that elasticity estimates vary over a wide range, and that it is not possible to calculate with a great deal of confidence what the magnitude of the rebound effect is for these vehicles.195

However, the committee stated, a rebound effect nevertheless likely exists that will partially offset fuel consumption declines due to the adoption of new cost-effective technologies.196 The committee emphasized that to the extent the regulation pushes beyond the private cost-effective point, the rebound effect will be reversed,197 meaning that the costs of shipping will have increased, and will ship less freight. The committee cautioned that estimates of fuel savings from regulatory standards will be somewhat misestimated if the rebound effect is not considered.198

Vehicle class shifting: The committee stated that standards that differentially affect the capital and operating costs of individual vehicle classes (for example, if Class 8 trucks are regulated but not Class 6 trucks) can cause purchase of vehicles that are not optimized for particular operating conditions.199 The committee cautioned that the complexity of truck use and the variability of duty cycles increase the probability of these unintended consequences.200

Environmental co-benefits: The committee stated that reduced fuel consumption through fuel efficiency technologies in MD/HD vehicles will likely reduce emissions of criteria pollutants201 (although this also depends on the direction and magnitude of the rebound effect). Efficiency improvements achieved by improved aerodynamics, tire rolling resistance, and weight reductions will translate into lower tailpipe emissions as well.202

Congestion: The committee stated that to the extent that regulations alter the number of shipments and VMT, there will be some safety and congestion impacts.203 The possible rebound effect may increase truck VMT and thus add to congestion. Further, if the regulations have performance impacts that result in slower trucks, congestion could also increase. The committee suggested that a more detailed 193 Id. 194 Id. 195 Id., Finding 6-11. 196 Id. 197 Id. 198 Id. 199 Id., Finding 6-12. 200 Id. 201 Id., Finding 6-13. 202 Id. 203 Id., Finding 6-14.

assessment of these impacts would be needed based on the type of regulation put forward by NHTSA.204

Safety: The committee stated that there are potential safety issues associated with MD/HD fuel efficiency standards.205 First, new technologies may have specific safety issues associated with them – such as the need for operators, service mechanics, and emergency personnel to be educated about high-voltage electrical equipment in hybrid trucks, or aerodynamic fairings that may detach on the road.206 Second, the rebound effect may increase overall truck traffic on the road, thereby leading to potentially higher incidences of accidents.207 Third, some technologies and/or approaches to improving fuel efficiency may actually lead to a safer highway system, such as speed reductions,

improved driver training, and use of side fairings that may reduce hazards to other vehicles in inclement weather.208 Fourth, if new technologies diminish the performance of vehicles (e.g., by decreasing acceleration times), negative safety impacts could occur.209 And finally, if new technologies or regulations have the effect of increasing payload capacity for trucks, fewer trucks may be in operation, potentially resulting in safety benefits.210 The committee stated that a more detailed assessment of all these safety aspects would be needed based on the type of regulation that NHTSA ultimately puts forth.211

Incremental weight effects: The committee stated that some fuel efficiency reduction technologies will add weight to vehicles and push those vehicles over Federal threshold weights, thereby triggering new operational conditions, and affecting, in turn, vehicle purchase decisions.212 The committee indicated that more research is needed to assess the significance of this potential impact.213 The committee also stated that, on the other hand, some fuel efficiency reduction technologies will reduce cargo capacity for truck models that are currently “weighed out” (i.e., adding weight to trucks that already hit the maximum weight allowed on highways and bridges will mean that more trucks will be needed to transport the same payload to enable each truck to stay under current weight limits).214 The committee indicated that more research is also needed to assess the significance of this potential impact.215

Manufacturability and product development: The committee stated that it found no current studies or analyses suggesting that manufacturability was a major barrier to the integration of gas/diesel engine, hybrid, aero, tire, or other technologies in the vehicle 204 Id. 205 Id., Finding 6-15. 206 Id. at 153. 207 Id. 208 Id. 209 Id. 210 Id. 211 Id. at 154. 212 Id. at 156-157, Finding 6-16. 213 Id. at 157. 214 Id., Finding 6-17. 215 Id.

manufacturing process.216 However, it cautioned that there may be challenges with integrating new technologies into manufacturers’ product development processes, and that sufficient time would be needed for design and validation, customer acceptance, testing, and compliance strategy development.217