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U.S. Legislative Issues

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NAFA Comments on RFS Standard

In comments submitted to a congressional committee, NAFA expressed strong concerns with the risks that E-15 presents for both vehicles and fueling systems: "There are many technical and practical concerns that must be addressed, including the potential for E-15 to damage vehicle engines of all model years and for misfueling of vehicles older that model year 2001 and other gasoline powered equipment not approved for E-15 use." NAFA also informed the House Energy and Commerce Committee, "Although fleet managers strongly support protecting and sustaining our environment, the potential difficulties and related expenses that will result by introducing E-15 before it is fully evaluated will outpace our ability to address the mechanical problems that will result."

NAFA's comments were submitted as part of a congressional assessment of the federal Renewable Fuels Standard (RFS). The RFS was created by the Energy Policy Act of 2005 and greatly expanded under the Energy Independence and Security Act of 2007. It sets targets and timetables for adding ethanol and other biofuels to the transportation fuel supply.

NAFA responded to the first of several white papers issued by the House Energy and Commerce Committee as part of the committee’s review of the RFS. The first white paper addresses the so-called blend wall and fuel compatibility issues. The blend wall is the limit at which ethanol can readily be added to the gasoline supply in order to comply with the RFS.

In the comments, NAFA stated that the blend wall could be delayed or prevented with the use of E-85, pointing out there are roughly 9 million flexible fuel vehicles designed to run on blends containing up to 85 percent ethanol (E-85) out of 225 million passenger vehicles in the U.S. "In order to increase the use of E-85, light duty passenger vehicles manufactured after 2013 should be required to be compatible with E-85." NAFA continued, "However, any such requirement must be coupled with policies that expand the availability of public E-85 refueling facilities."

NHTSA Survey Looks at Distracted Driving

The U.S. Department of Transportation’s National Highway Traffic Safety Administration (NHTSA) has released new survey results showing that Americans continue to use electronic devices while driving, despite warnings that it causes their own driving to deteriorate and can lead to crashes, injuries and even death.  The new data are being released at the start of National Distracted Driving Awareness Month.

The new data include statistics from the 2012 Distracted Driving Attitudes and Behaviors Survey and the 2011 National Occupant Protection Use Survey on Driver Electronics Use, as well as the 2011 Distraction Fatality Analysis Reporting System (FARS) data.

According to NHTSA, the 2011 National Occupant Protection Use Survey (NOPUS) shows that at any given daylight moment across America, approximately 660,000 drivers are using cell phones or manipulating electronic devices while driving, a number that has held steady since 2010. According to separate NHTSA data, more than 3,300 people were killed in 2011 and 387,000 were injured in crashes involving a distracted driver.

"Distracted driving is a serious and deadly epidemic on America’s roadways," said U.S. Transportation Secretary Ray LaHood. "There is no way to text and drive safely. Powering down your cell phone when you’re behind the wheel can save lives – maybe even your own."

NAFA Comments to NHTSA on Proposed Survey

NAFA has submitted comments on a proposed survey of truck fleets.  The U.S. Department of Transportation’s National Highway Traffic Safety Administration (NHTSA) proposes to collect data from truck fleets to assist in establishing the next phase of fuel efficiency standards for medium- and heavy-duty (MD/HD) on-highway vehicles and work trucks. The intent of the survey is to baseline vehicle configurations within the fleet and, also, to baseline each vehicle category and subcategory’s relative fuel consumption performance.

In the comments, NAFA expressed doubts about the ability of the survey to capture the diverse nature of vocational and work truck fleets. "The wide variability in truck sizes and weights coupled with duty cycles and work applications makes standard setting an extremely difficult undertaking," NAFA said. "Given the scope of the survey and expected response rate of 100 finished surveys, NAFA believes that 100 surveys will not capture the diversity of vocational fleet operations."

NAFA will continue to work with NHTSA to refine the survey, as baseline data is needed to properly set fuel efficiency standards. NAFA noted that proper fuel efficiency standards, however, must take into account vehicle utilization.

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NAFA Fleet Management Association
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Princeton, NJ 08540

Telephone: 609.720.0882 Fax: 609.452.8004