To the Editor:
The Steel Market Development Institute agrees with Christopher Grundler, director of the EPA's Office of Transportation and Air Quality, in recognizing that we can't simply look at auto regulations from "a tailpipe standard-setting point of view" ("EPA ponders post-2025 regulation," Jan. 18).
What's important to remember is that the manufacture and disposal of a vehicle can have more of an environmental impact than years of driving. The production phase is responsible for up to 30 percent of the total emissions for internal combustion engine vehicles and as high as 45 percent for battery electric vehicles. Those are significant impacts to the environment before a vehicle is ever driven.
Also, the costs of complying with new fuel economy regulations are considerable. That means automakers will design to meet fuel economy targets. Ultimately, vehicles in the same class will have essentially the same fuel economy and tailpipe emissions regardless of the materials used.
That makes production emissions the determining factor in reducing vehicle emissions, and material production emissions vary greatly. For example, according to a 2013 report available on the Aluminum Association website, production of aluminum in North America emits 8.9 kg of CO2 per kg of aluminum, which is more than a fourfold difference from steel.
The importance of production emissions is clear, and materials decisions about future vehicles are being made now.
The midterm review to determine the appropriateness of the regulations for the 2022-25 period is ramping up now and runs until April 2018. Let's use this review period to consider and address the impact of production emissions on total vehicle emissions to ensure that future vehicles result in a net decrease in emissions.
Steel Market Development Institute