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

Jon in CT

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WTF? Really? So in 2011, as of right now, Subaru needs to change the ENTIRE Leg/Imp line to meet the standards? What are the fines for not doing so?
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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




I wonder if FHI could/would sell SOA to Toyota - only SOA, so to circumvent the moronic US CAFE legislation. Basically it would be Toyota manufacturing Legacy/Outback/Tribeca at SIA (probably TIA then) under "license" from FHI Japan.

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;2025938']Fines are nearly doubled under the new proposed CAFE rules.

So technically these are still "proposed" and not final?


By the way..... what did you do this time to get banned over there? :lol:

Please PM joeleodee For All Site Questions. He is the acting Admin and can resolve anything related to LegacyGT.com
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Maybe they should try replacing the crappy RE92s with some low rolling resistance tires like Chevy has on the Cobalt XFE. Don't see how they could be any worse.


Would it really add that much to the price if they dropped the 4EAT completely and used the 5EAT instead??

Friends don't let friends drink cheap beer.
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Well last nite i went on the highway for 100miles and i was tired of averaging 19mpg in pure city so i decided to do most of the trip with cruise set to 60mph... and I averaged 34.5mpg according to the trip meter! The peak was at 36.6mpg at one point but after I hit some traffic and it leveled around 35. So theoretically my 2006 can attain the new Cafe regulations but thats in VERY conservative driving, though if conditions were better (less traffic/hills) i might of hit almost 40mpg.


So Subaru awd can get 35mpg just they need to modernize their engines/transmissions (no hybrid) just things like cylinder deactivation, more gears with taller gearing, variable valve timing on the N/A models, and reduce engine size to say 2.2L while still being about to get 160-170hp. Some weight reduction all around and better aerodynamics.


Or perhaps Subaru is hoping they can get assimiliated by Toyota so they have the Yaris and Prius offsetting their own regulation.

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Don't forget to also work around friction issues in the transmission, especially those caused by the high viscosity of cold transmission oil.


It is possible to get good figures, the big problem is not really in that area, but that people also want high performance cars and the driving style associated with that.


In addition to that there are also a lot of traffic safety issues that adds weight to our vehicles. And more to come - like pedestrian safe bumpers...


More gears usually also means a heavier transmission. This is why the CVT gearboxes starts to make sense.


The real challenge is to get a CAFE compliant vehicle with the driving patterns specified for measurements.

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Perfect opportunity to divorce the front differential, and put it up front, and the engine almost entirely behind the front axle line...


IF we are dreaming about an H8... why not?


I'll add to the dream list:


Direct injection

VVEL-like variable timing and lift, rendering the engine throttle-less. At least on intake cam, with variable timing on exhaust cam, or variable timing and lift on all four cams.

Unless electro-magnetic, or pneumatic valvetrains are ready to go... but I doubt it.


How about top-side exhaust, like the new BMW V8-twin-turbo. It makes even more sense on a boxer. Heat rises, so put the hot stuff on the top, where it can be cooled by a hood scoop, or extracted into the airflow.


Turbos mounted on top, drawing air in from the hood scoop, pushing it through a double FMIC, into double intake manifolds under the cylinder heads, along the sides of the oil pan, and protected by the under-tray and chassis.


The exhaust has downpipes, but the manifolds don't need up-pipes, and the lag would be very short, as the exhaust route is short. Might not even need catalysts before the turbos.


And even on a non-turbo H8... a nice gleaming set of polished headers on top of the engine isn't a bad thing. :D

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I had to read who moved my cheese for work. I don't see how it applies here at all. Subaru can't change the way it does things. Things haven't gone stale. It does apply to the SUV's and big gas guzzlers because as you can see the trend is dying. if anything other car companies need to follow what subaru is doing. and start building cars that the drivers can actually see over the steering wheel in.
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GM's comments:


GM’s Lutz Calls for Break on Crash-Testing in U.S.

JOLIET, IL – The U.S. should suspend crash-testing requirements in order to allow auto makers to speed more fuel-efficient models to the market, says Bob Lutz, General Motors Corp.’s vice chairman and product-development chief.


In a wide-ranging interview here at a preview of ’09 models, Lutz denies there are plans to drop the Saturn Outlook cross/utility vehicle, as has been widely speculated, and he reveals retail customers won’t be able to get behind the wheel of a new Chevrolet Volt plug-in hybrid-electric vehicle before November 2010.


In addition, Lutz says GM is worried about the future of its Corvette sports car as a result of tightening fuel-economy regulations.


“I’m not going to get into individuals, but I will tell you what we want from whoever it is,” Lutz says when asked which of the two major-party presidential candidates would benefit the auto industry more. “We have tremendous pressure from mandates on fuel economy and safety that are going to add weight to vehicles, and so we are victims of the federal government.


“So it’s not unreasonable to request federal loan guarantees from the government to fund the new technology needed to meet the mileage and safety mandates.”


Detroit-based auto makers are lobbying for a $50 billion federal financing package to fund product development and retooling to more fuel-efficient vehicles.

Lutz: No Lamda vehicles to be dropped.


“We also would like a 3-year moratorium on certain U.S. front- and side-impact crash test regulations,” Lutz adds. “The regulations impact our ability to bring in several high-mileage small cars we make elsewhere in the world.


“In Europe, the crash-test procedures are different than in the U.S., so the tests are different. If our government says cars that meet crash tests in other countries are good enough to be sold here, we would have more high-mileage, small-car flexibility.”


As for the Saturn Outlook being discontinued now that the more volume-oriented Chevrolet Traverse is hitting the market, Lutz says simply, “No Lambda-based crossover will be dropped.”

He does reconfirm that plans for fullsize rear-drive Chevrolet and Buick have been cancelled due to higher gasoline prices. Also impacted is the new Camaro sports coupe set to roll out.


“I get letters from people saying they heard we were going to add a supercharged 600-hp V-8 to the Camaro lineup, and I write back saying ‘Sorry, with new (corporate average fuel economy) standards (for 2020), we aren’t going to do it.”


The new minimum CAFE standard of 35 mpg (6.7 L/100 km) in 2020 and additional pressure from California and 15 other states to limit carbon dioxide is part of what may force Chrysler LLC to jettison its Viper high-performance model. Chrysler said this week it was examining options for its Viper business, including a sale.


“Setting lower CO2 limits would equal setting CAFE at 43 mpg (5.5 L/100 km),” Lutz says. “This is why the sale of the Dodge Viper by Chrysler makes sense, because anyone selling fewer than 50,000 vehicles annually would be exempt (from fuel-economy requirements).


“So if someone else bought Viper, they could sell to capacity, but Chrysler couldn’t. This is why we are concerned about Corvette.


“The reason California set the exemption for less than 50,000 units is that it would mean the Hollywood folks could keep driving their Lamborghinis and Ferraris.”

Based on the 50,000-unit exemption “Porsche could sell 11-mpg (21.4 L/100 km) Cayennes, but we couldn’t sell 20-mpg (11.8 L/100 km) Chevy Tahoes,” Lutz adds.


GM is happy with the pace of battery development for the Volt, but he emphasizes the car won’t be available to the public any earlier than 26 months from now.


“The batteries have proven trouble free,” he says. “It’s almost frightening.


“We’ll start releasing (the car) to the public in November of 2010. No one, no one, will get one any earlier,” he says, adding “the first generation won’t be profitable.”


Asked how auto makers will generate profits from small cars, Lutz says, “Profits follow demand. When SUVs were in big demand it meant profits. When small cars are in big demand, it will mean profits.

“The Chevy Malibu transaction price is up by $4,000 this year because it is in big demand,” he says. “The old Malibu it replaced we had to give away with incentives.”


Meanwhile, Lutz continues to insist retirement isn’t on his radar screen.


“I have no plans to retire,” he says. “But that doesn’t mean someday Rick (Wagoner, GM’s chairman) or the board might say, ‘Hey, you’re starting to ramble.’”


Lutz, who notes he is “76-and-a-half” says, “When I’m 80 we’ll have a party in my office and have cake.”


But he concedes he has made some concessions to age.


“I’m not shy about taking my vacation time, I just don’t take it all at once,” he says. “As I get older, I think I’ll probably take more time off.


“I think I’ve figured out the perfect work week – Fridays and Mondays off.”

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I just had a nice talk with the folks at my Subaru dealership about this. Hell, they say that Subaru has a deisel model coming soon (currently execs drive them in Europe or something) and that they have 2 prototype Electric models (not hybrids) out in Japan. Literally 2 cars out there.


They also said since Toyota bought 17% of Subaru, they gave the plans for the WRX style turbo (Legacy, WRX, non-sti) in exchange for Toyota's hybrid plans, which the guys at the dealership say are the worst emissions out of all hybrids. They said it would take subaru a few years to un-f*ck what Toyota did to it.



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;1996864']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.


Here's my response to Subaru's whining. "You're right. Let's bag CAFE cz it's a half witted solution to the fuel economy issue. Instead we're going to impose a $3/gallon gasoline tax to give direct incentives to manufacturers to raise their fuel efficiency. Stop whining and deal."

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Here's my response to Subaru's whining. "You're right. Let's bag CAFE cz it's a half witted solution to the fuel economy issue. Instead we're going to impose a $3/gallon gasoline tax to give direct incentives to manufacturers to raise their fuel efficiency. Stop whining and deal."


Do you realize how badly that would cripple the US Economy? You do realize that this all burdens citizens when it comes right down to it? Citizens like you.


People know what fuel economy is. People know what it means to their bottom line, and they will make decisions based on that. But often, they make decisions based on more than just fuel economy, as other factors come into play.


The energy market sets prices, like markets do. If the fair market value of energy goes up, it goes up. It also makes people consider economics more (fuel economy has the word 'economy' right in it!)


CAFE, and other corporate regulations work somewhat like corporate taxes do. It gets rolled onto the expense sheet as a cost of doing business. The regulations are targeted, though, and actually hurt product diversity. Diversity is one of those words that is a buzz-word sometimes, but ignored other times. But the point is, that it drives costs up, and flexibility down. Something Government is not intended to do to private business, nor private citizens.


Lack of product diversity, and increases in costs, leading to increases in price for a given product is why domestic cars have less value, and are losing marketshare. Boneheaded management, and greedy labor are only exacerbating it. Lack of product diversity hurts the other factors, aside from fuel economy, that I mentioned earlier.


But if you throw out the regulations for a gasoline excise tax, you penalize the market far more directly. The tax itself becomes a means of deterrent, not a necessity for a valid governmental purpose. Just a governmental windfall.


I thought government hated windfall revenues. They want to take them away from private and publicly held companies. They want to take it away from private citizens, both as a tax expense, and as a detriment to capital investment. That is decidedly against the freedom this government was designed to protect, not to exploit.


Instead of penalizing customers via the corporate vendors, you penalize the customers directly with an excise tax. And since when do we want to tell the people with 11% approval rating in Congress, that we think it is OK to give them tons of money on top of our energy expenses for every family and business in America?


People know about fuel economy, and when it becomes a market-driven criteria, as it has now, the market will incentivize alternatives, and will drive purchasing choices. Just because the conditions weren't favorable for alternatives before, doesn't mean that today is the same as yesterday.


The Government only serves in this sort of role to muck up the works. They should stick to prosecuting fraud, and let the market work otherwise. laissez faire is a principle worth pursuing, and is instrumental to the principle of the freedom for life, liberty, and the pursuit of happiness.


If it is energy today, what will it be tomorrow? Food? Shelter? (like fannie and freddie)

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I agree with you about CAFE, but it should go AWAY, not be replaced with confiscatory taxes on anything, least of all, energy. Why can't the government recede, instead of playing a shell game of "where is the tax now?"


The price of every last good or service you buy will go up, the cost of heating and cooling your home, the cost of commuting to work, EVERYTHING, if fuel excise tax is imposed.


Notice how everything is inflating, and the dollar is down since fuel prices went up? Notice how your money isn't going as far as it did 12-24 months ago? The only reason that the dollar "appears" to be up a bit is because now the Euro is tanking, as well, and the only measure of the dollar is "relative" to other currencies.


The dollar may be up compared to the tanking euro, but the dollar is not up compared to the dollar 6 months ago, and is still down compared to 12-24 months ago, and farther back.


If you want to supercharge that effect, tax gasoline more. Instant Depression, mark my words. That is a bit deeper than "simple" economics, but not much.


I don't know about you, but an 80-90% increase in gas prices is NOT going to get me to buy another, economical car. My Legacy and my Miata are both paid for, I would have to PAY for another car, even if it is more fuel efficient than my Legacy is.


I cannot pay MORE for fuel, and MORE for a more fuel efficient car at the same time. Auto sales are down market wide. Increasing gas prices by 3$ a gallon, as you propose, would instantly kill new car sales. It would also put shipping companies, grocers, convenience stores, and A LOT of other people out of work, almost instantly.


I got less than 3.5% of a cost of living increase in pay this year, and a song-and-dance about how the institution can't afford merit pay increases this year, and no one I know is getting one, it isn't just an excuse to not pay me.


I commute ~45 miles a day, round trip. Not that uncommon, especially in the midwest, and most of the wide-open spaces in this country. I could NOT afford to pay ~80% more for fuel, and still afford to feed my family, and heat my house.


Government tax increases have to come from people's pockets, there is nowhere else that they can come from. My pocket is getting thinner, not thicker. Chances are yours is the same way unless you are somehow blessed with skyrocketing income right now.

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But I agree that now would be a bad time to institute higher gas taxes. Wait until the economy recovers and then gradually increase it over a period of several years.


I hate taxes just as much as the next person, but high gas prices have actually changed the behavior of the American consumer. Anyone else notice how fast a new Tahoe/Suburban/Escalade deprecates, and how much inventory dealers have stuck on their lots? It's not to say that because gas instantly goes up in price everyone will trade in their tahoe's for highlander hybrids, or caddilacs for priuses, but when the time to buy a new car does come around, they'll be thinking more economical. It's not in my best interests to change vehicles now because my LGT is paid for, but when I trade her in for something else in 2 years, it may be a legacy diesel, or something else that's more economical.


The change in behavior associated with higher gas prices/commodity prices will do good because it's changing the way our currently wasteful minds THINK - Look at Europe for example; the ridiculous gas prices there have moved people away from gas guzzlers, and instead to economical cars, motorcycles and public transit. The tax is not so much about the collection of monies into our massive American bureaucracy, but migration of society away from our current improvident ideals, to that of energy conscious frugality.


Things like this that I saw in Switzerland got me excited for what may be coming to our own country:)


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Not even then, and it doesn't matter how slow. The economics still hold, and will reverse any recovery the economy might make.


You've all GOT to get away from this idea that government is a beneficial overlord. It isn't. It doesn't have your best interest at heart, and that is why it needs to be strictly limited. You should be left to yourself and your own best interests, no one knows them better than you do.


Would you trust your household to some people who you don't really know, and have no reason to trust? That is what you are doing!!! Congress has 11% approval, ELEVEN!!!!!!!!!! That is how well they run things, or DON'T, as it were.


This is a matter of freedom, life, liberty, and the pursuit of happiness. your economics are just a medium through which your work, time and effort translate into lifestyle and security.


Handing that over to the government through high taxation is not only incorrect, it is immoral. People don't have a choice with taxation, they pay or they go to jail. Only the most DIRE things that the VAST majority of people agree are legitimate taxation purposes should be ascribed that force of law.


The force of law is not designed to enforce "frugality", or any other imposition of social trends, at the expense of choice and freedom. The market, based on changing costs and conditions, give people a CHOICE, to justify higher costs, or reduce costs. Force of law only takes choice AWAY! Taxation is not a proper vehicle for social awareness. Buy advertising airtime if you want to do that. DON'T DARE FORCE IT AT THE POINT OF LAW ENFORCEMENT'S GUNS!


This is practical at the surface, but it goes all the way to philosophy, and the most basic tenants of freedom and self-rule.


If all of you people willingly abandon your freedom, including your economic freedom, then voluntarily pay more for gas. When you buy 45$ in gas, hand the clerk $70, and tell them to send the change to Washington. Don't you dare force it on people who need to use that margin to pay other bills, and should have the freedom to choose to be responsible for themselves.


Maybe this free country has already died, and we just don't know it yet. How can you all give up your freedom, economic, or otherwise, so easily?


Think about what you spend on fuel in a month. Then multiply that by about *0.8*. THAT Number, roughly, considering the 3$ gas tax that Kartboy is talking about, is ONLY THE ADDITIONAL money that will come out of your budget if you have to pay that much more. Multiply by *1.8* if you want the total.


My fuel bills are about 6 tanks of gas, at 48-50$ per tank, per month. That is about 300$ a month. Roughly ~3.80 a gallon right now. Another 3$ is about a 79% increase.


A 3$ gas tax increase would be another ~237 per month. ALMOST DOUBLE. I don't have another 237$ in my monthly budget that I am just wondering what to waste it on.


I don't even have car payments, and I don't have any other debt, besides one student loan, and a mortgage. One of those, or one of my utilities bills, or my groceries, would have to take a big hit. My utilities bills are usually less than 237$ a month, aside from the heat of summer or depth of winter.


If EVERYONE is paying that percentage more, no one is going to have a whole lot of money to hire me into a better job, or give me a better raise, and most likely not you, either. Can you imagine what that would do to ANY product that requires shipping? HUGE inflation.


Do you people realize just what a BAD idea increased taxes are? They SAP VALUE OUT OF THE ECONOMY.


What the hell is a do-nothing, money-hungry, 3.1-trillion-dollar-budgeted federal government going to do with all that additional money from doubling the cost of our transporation energy? Do you think they are going to just give that money back? Have they ever just given our money back, willingly?

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So because of my curiosity, how do you propose we move away from our finite gasoline dependence? I'll be the first to say that I know what to do with my money better then the government does, but how else do we move the general public away from our wasteful thinking? And i don't mean just with energy, but with food prices, raw material prices, etc. The alternative is that sooner then we would like to think, these things will become more and more scarce - especially with other countries developing like China. As our dependence grows larger and as other countries dependence increases, the supply decreases, and eventually there will be a crisis to which no one is prepared. Not only are we addicted to non-clean energies like oil, but we're addicted to FOREIGN sources for these commodities.


You say that the force of law only takes choice away - I very much disagree; to an extent. Without the force of law, we experience what is called anarchy. We would also experience brutal unregulated capitalism - you think the downfall of Enron, or the takeover of freddie and fannie are bad, what if there were no GAAP to which these industries have to be monitored? Regulation, like all things, is necessary IN MODERATION. The same is going to hold true when it comes down to SHARING the resources that we have on this earth. If the government did nothing, and 50 years down the road there is so much demand for oil, but so little left, we're stuck in a world that is unprepared for such. A little preparation now, will go a long way to removing our foreign oil dependence, and whether we like it or not, the world's governments play a key role in making this change.

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