The new intertwined CAFE and greenhouse gas standards the EPA and NHTSA proposed on April 1 initially come into play for new car manufacturers, not the aftermarket, or so it would seem at first glance. But that is not necessarily so. Short-term implementation of the standards--which go into effect for model year 2012--will depend on low-tech solutions such as low-rolling resistance tires and alternative automotive refrigerants. Both products will have an immediate aftermarket presence, too.
The day after the Environmental Protection Agency (EPA) and National Highway Traffic Safety Administration (NHTSA) released the final 2012-2016 standards, the EPA separately released a proposed rule dealing with HFO-1234yf (R1234). That is the automotive air conditioning refrigerant which has been all but designated as the replacement for R134a, the current refrigerant used in autos. The proposed rule was actually a re-proposal of a direct final rule issued February 1, 2010, which the Automotive Refrigeration Products Institute (ARPI) and the Automotive Aftermarket Industry Association objected to because it would have limited distribution of R1234 to containers larger than 20 pounds and to persons who are certified technicians. EPA's thinking was that R1234, for reasons of flammability, is not safe for aftermarket use. Because the ARPI and AAIA challenged that notion, the EPA was forced to reopen the rulemaking thereby delaying final approval of R1234 for use both in the aftermarket (maybe) and in new vehicle systems.
Any delay is particularly significant on the OEM side because the sooner Ford, GM, Toyota, et al. start using R1234 in new car AC systems, the sooner they can start booking significant "credits" which can be used if they miss fleet CAFE/GHG targets. By 2016, each manufacturer's "fleet"--both vehicles and trucks combined--will have to average 35.5 miles per gallon and 250 grams of CO2 emission. Manufacturers can also get credits for reducing both direct and indirect CO2 emissions when R134a is used. But the real gain in CO2 reductions would come from use of R1234. The Global Warming Potential (GWP) for R1234 is 4; for R134a it is 1,410.
Manufacturers won't get any similar credit for putting low-rolling resistance tires on new cars, which manufacturers are already doing. These tires are already available, to some extent, in the aftermarket. The problem is that comparing low-rolling resistance tires within manufacturers, not to mention across manufacturers, requires a Ph.D. in tireology. Hence NHTSA's development of a "consumer" label for rolling resistance tires.
The agency held a public meeting on that topic on March 26, 2010 where Roy Littlefield, Executive Vice President, Tire Industry Association, which strongly supports development of a label, criticized the way NHTSA was going about it. TIA represents the tire retailers, not the manufacturers, and Littlefield pointed out that current tire ratings for the same manufacturer within the same tire size vary all over the place. Littlefield wants NHTSA to allow his members to run any consumer education program, given what he views as the failure of NHTSA's consumer education efforts in the area of the uniform tire grading system. NHTSA has asked the White House Office of Management and Budget (OMB) to approve a proposal to attach a consumer education card to each tire. According to Littlefield, OMB refused to approve that. So NHTSA has more work to do on developing a consumer education program, which it hopes to finalize by this fall.