Subaru's Comments on NHTSA's proposed 2011-15 CAFE Rules

First, in order to make sense of Subaru's comments, you need to read the first page of my thread at http://forums.nasioc.com/forums/showthread.php?t=1526329.

 

Subaru argues that NHTSA ignored the small manufacturers when designing its proposed CAFE numbers and catered strictly to the 7 largest manufacturers. It also argues that the smallest manufacturers have the least ability to respond to regulation changes that take effect so soon, for the 2011 model year.

 

I like Subaru's main proposal: let the smaller manufacturers meet the CAFE standards by simply producing cars which meet the nationwide CAFE standard, not based on some stupid footprint formula.

 

Subaru's comments, as an MS Word document, are at http://www.regulations.gov/fdmspublic/ContentViewer?objectId=0900006480647127&disposition=attachment&contentType=msw8. If anyone has trouble reading that, I can post the whole thing here as a series of posts.

 

BTW, Subaru has finally supplied NHTSA with its production plans for 2011-15 (see the MS Word doc at http://www.regulations.gov/fdmspublic/ContentViewer?objectId=090000648064705a&disposition=attachment&contentType=msw8). I sure would like a peek at the redacted spreadsheets.

Thats interesting.

Sorry but I want my 2015 legacy to give me 40mpg and go 0-60 in 3.5secs while in a blizzard and stop on a dime and never hydro plane and survive any accident ever. No cake for you subaru.

Sorry but I want my 2015 legacy to give me 40mpg and go 0-60 in 13.5secs while in a blizzard and stop on a dime and never hydro plane and survive any accident ever. No cake for you subaru.

 

That's what you'll get.

This is a common complaint. Porsche is complaining too. That's what happens when the gov regulators only take input from a small select bunch of large auto execs

This is a common complaint. Porsche is complaining too. That's what happens when the gov regulators... regulate.

 

Ninja Quote-fix.

It does seem that some manufactures are getting screwed. Even some Washington DC dreamer should be able to see it.

So am I understanding it that the bigger the vehicle the lower the CAFE expectations are for fuel economy? So because Subaru makes smaller sedans than say Ford, they have to have significantly higher economy numbers?

Correct. In 2011, Subaru will be required to raise its CAFE to 36.9 MPG whereas a company like Chrysler, which makes lots of big cars, will only be required to raise its CAFE to 28.7 MPG. And 2011 is like tomorrow for car companies. Except for minor tweaks, Subaru has already designed its 2011 model lineup.

Oh Chrysler is so far behind right now its not even funny.

i really like how Subaru notes that the rest of the world encourages more efficient cars w/ its "CAFE equivalent" standards while the US encourages larger cars with our CAFE standards.

 

right.

Big Brother FTL

Looks like subaru is going to have to just build bigger cars. This is why America is ass backwards. It's because everything is so corrupt. A car company like subaru, who is relatively fuel efficient for what it offers is being penalized for it's strategy, while larger companies are being catered to. When you interfere with market forces, things will eventually correct themselves, but with larger consequences. Demand for oil isn't going to go down any time soon. The government should be encouraging companies to become more efficient, rather than encouraging them to build larger cars.

So am I understanding it that the bigger the vehicle the lower the CAFE expectations are for fuel economy? So because Subaru makes smaller sedans than say Ford, they have to have significantly higher economy numbers?

 

It has to do with the law of averages. Car companies that sell more cars, if they sell a lot of a model with good gas mileage, it offsets poorer mileage cars. Trucks are included, but I think they may have an adjusted scale.

 

Chevy can sell cobalts and Aveos, and other tiny cars, Ford has Focus and Fusion, which probably get judged on their base I4 configuration.

 

toyota sells lots of corollas, priuses, yarises, scions, etc.

 

Subaru sells as many cars as one single name in that list, for their entire lineup. They all have AWD, and the Tribeca doesn't have an H4 option.

 

Subaru's average hovers around the middle, but they don't have the force of numbers to leverage their average higher, as the regs increase over time. Plus, the fact that they don't have any giant gas guzzlers to cut, and don't want to become ONLY an economy car dealer, or lose AWD, they don't have a lot of momentum to greatly increase fuel economy from where they are now.

 

There are a few things, but not a lot, without spending LOTS of cash that other companies have, and subaru doesn't, to implement hybrid tech, which may not sell well enough to make a dent, or pay off the investment.

 

If Subaru wants to keep on keepin' on, doing the things it does, it is going to have a hard time balancing it's core business and drastically improving average fuel economy.

It has to do with the law of averages. Car companies that sell more cars, if they sell a lot of a model with good gas mileage, it offsets poorer mileage cars. Trucks are included, but I think they may have an adjusted scale.

 

Chevy can sell cobalts and Aveos, and other tiny cars, Ford has Focus and Fusion, which probably get judged on their base I4 configuration.

 

toyota sells lots of corollas, priuses, yarises, scions, etc.

You don't quite understand. Under the new rules, selling lots of small cars raises the CAFE you must achieve to avoid fines. In other words, its possible that if a small car doesn't achieve 35 MPG, then it's hurting your efforts to meet the new CAFE requirements and you'd be better off, CAFE-wise, by not selling that small car at all.

http://www.inspiring-breakthrough.co.uk/images/books/who-moved-my-cheese.jpg

A good book. Read it sometime regarding change.

This is a common complaint. Porsche is complaining too. That's what happens when the gov regulators only take input from a small select bunch of large auto execs

 

Also called Lobbying - and the one with the largest purse wins.

;2003373']Correct. In 2011' date=' Subaru will be required to raise its CAFE to 36.9 MPG whereas a company like Chrysler, which makes lots of big cars, will only be required to raise its CAFE to 28.7 MPG. And 2011 is like tomorrow for car companies. Except for minor tweaks, Subaru has already designed its 2011 model lineup.[/quote']

 

Which means that we will see the 1.5 liter engine in the Legacy.

 

It's possible to get better figures, but we will have to pay some penalty.

 

Like having our cars look like this:

http://www.bedug.com/pics/CAFE-legacy.JPG

So mayn companies are moving to produce more efficient 4 cylinder engines because they know its a good invest. Toyota and Ford both have new 2.5Ls comin out. Perhaps this is the route Subaru needs to take. The EJ25 has been around since '96, which isn't all that old, but it has always been utilized for power and performance. What Subaru needs is smaller displacement 150 HP engine for the Impreza base and perhaps their new sports car. And if its worth it, the Forester. And we all know that the EJ20 just plain is not efficient for a small engine.

 

I read today that Chevy's new compact will utilize a 150 HP 1.4L direct injected, turbo 4 that should yield 40+ MPG.

Which means that we will see the 1.5 liter engine in the Legacy.

 

It's possible to get better figures, but we will have to pay some penalty.

 

Like having our cars look like this:

http://www.bedug.com/pics/CAFE-legacy.JPG

 

Is that a thalidomide legacy?

WTH is that???

http://www.bedug.com/pics/CAFE-legacy.JPG

 

REPORTED FOR CRUELTY... WTF

It's like a Mini and a Legacy got it on, and that's what came out...

 

I'm working my way through the Fuji document, but I'm keen to find out whether the 1.5l diesel motor will help them out...isn't that theoretically coming here somewhere in the 2010-12 range?

 

edit: on further examination, I think I'd be all over a 3-door LGT with the wheelbase stretched out to the corners like that. Mmmmm, yes indeed...especially with the rear diff hanging out the backside

If the proposed CAFE rule is adopted more-or-less as proposed, all Subaru's problem could be easily solved if it was to be completely bought out by Toyota.

 

2013 Toyota Legacy TRD

 

LOL, and I'll stand around, fists on hips, frowning. And wonder... why does my Legacy look like a larger version of a Prius?

Three of Subaru's models, Outback, Forester and Tribeca, are already classified, for CAFE purposes, as light trucks and the light truck CAFE standard is more lenient, although it, too, bases required fuel economy on footprint. So that leaves Legacy and Impreza as the 'problem' model lines. For MY2011, Subaru could simply bring back the Outback sedan (classified as a light truck) and dump the Legacy. And I guess Subaru could jack up the Impreza line so that it has the ground clearance and entry/exit angles necessary to qualify as a light truck.