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Letter to NHTSA on Revised Light Truck CAFE Standards

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This letter was written by Amory Lovins in 2005 and sent to the National Highway Traffic Safety Administration. In the letter, Lovins commends the NHTSA for its 2005 adoption of CAFE standards based on size rather than weight. Size-based standards incentivize manufacturers to use lighter materials that improve the efficiency of trucks. Lovins then describes new manufacturing technologies in light material that can improve the efficiency of vehicles even more. Lovins additionally recommends that the NHTSA adopt a system of feebates coupled with efficiency standards and CAFE standards. Lovins concludes by arguing that any modifications be performance-based, not prescriptive; be at least neutral as to vehicle mass; if they do influence mass, favor its downward rather than upward harmonization; if fuel-economy choices are desired to be decoupled from vehicle-size-class choices, then do so by normalizing to size; and be technology-neutral but preferably technology-forcing.