Scott - Comment

Document ID: NHTSA-2010-0079-0070
Document Type: Public Submission
Agency: National Highway Traffic Safety Administration
Received Date: December 10 2010, at 12:00 AM Eastern Standard Time
Date Posted: December 13 2010, at 12:00 AM Eastern Standard Time
Comment Start Date: November 30 2010, at 12:00 AM Eastern Standard Time
Comment Due Date: January 31 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80bb3cc6
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This is comment on Rule

Greenhouse Gas Emissions Standards and Fuel Efficiency Standards for Medium- and Heavy-Duty Enginesand Vehicles

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Why is the fuel efficiency emphasis so much on Medium and Heavy Duty vehicles? A Toyota Prius weighing 1.521 tons costs 4.11 cents per ton per mile to operate at 48mph and $3 gas. A Semi truck grossing 80,000 lbs only costs 1.25 cents per ton per mile at 6mpg and $3 fuel. To be comparable considering the weight difference, a Prius would need to get 151.48 mpg to be at the same cost per ton per mile as a fully loaded semi. Since a truck with payload weighs 26 times more than a Prius, you would expect a Prius to get 26 times better fuel efficiency yet it is only 8 times better. In addition, trucks move America, a Prius doesn't.