[microcolonel]

> Are you advocating for more regulation in terms of performance parameters?

I'm saying I'd prefer consistent (between vehicle classes) regulation of performance parameters which have externalities; and the abolition of non-normalized fleet-based targets (since they privilege the largest manufacturers). If the goal is to reduce external risk, the threshold of acceptable risk should be the same for all motorists as a matter of fairness.

A possible alternative to CAFE is a specialized cap and trade market. I get that they did think a bit about this stuff when they implemented it, but I feel like it has weird effects in practice, especially when gaming it enters medium-long term corporate strategy.

I think it would be spectacular if inefficiency was purchased on a per-vehicle or per-lot basis from manufacturers who exceed the target, and efficiency was sold in turn to those. Not sure how these transactions would be cleared, but I'm sure something reasonable could be worked out. This would do away with adjustments/exemptions based on vehicle footprint (CAFE targets currently differ based on mean vehicle footprint).

[bumby]

I think I agree in an idealized sense, but also think if this approach was taken it would decimate the ability to create certain vehicles, especially those used in heavy-duty applications. I don't know the history of CAFE standards but it may very well have been a practical choice...either get some form of progress or dig our heels in on an idealized version that never gets adopted.