The Scapegoat Utility Vehicle

What's So Threatening about SUVs?
by  Sam Kazman

Sam Kazman is general counsel of the Competitive Enterprise Institute (, a Washington-based free-market advocacy organization.

First sin, then treason, and finally, reckless idiocy. For owners of sports utility vehicles (SUVs), that pretty much sums up the last holiday season. They went into Thanksgiving under fire from the “What Would Jesus Drive?” campaign. Then the New Year started with Arianna Huffington’s charge that they were aiding Osama bin Laden. To top it off, in late January the head of the National Highway Traffic Safety Administration (NHTSA) declared that SUVs were simply too deadly for his children.

The media, of course, ate it up. In part, that was a healthy sign that there was nothing really important to report. But beyond their amusement value, these campaigns had some very real objectives: raising the federal government’s fuel-economy standards, encouraging congressional legislation, and sticking some new voodoo pins into the demonized doll of automobility.

Attacks on the SUV are nothing new. Prior to last fall, environmentalist organizations regularly decried their gas-guzzling nature and their contribution to the alleged threat of global warming. Self-proclaimed consumer-safety groups claimed they were dangerous to those who rode in them and to those who rode near them, citing rollovers and the Firestone-tire fiasco. Photos of subcompacts demolished by intact SUVs became a news favorite, despite the relative rarity of such occurrences. In September a book by New York Times reporter Keith Bradsher, High and Mighty, labeled them “the world’s most dangerous vehicles.”

But the attacks seemed to change in November, when the “What Would Jesus Drive?” (WWJD) campaign hit the big time. The Evangelical Environmental Network brought a convoy of electric hybrid cars to Detroit, where its spokesmen met with top Ford and GM executives to urge increased production of more fuel-efficient vehicles. The Network claimed that “the Risen Lord Jesus is concerned about the kinds of cars we drive because they affect his people and his creation.” The industry responded that it preferred to leave its purchasing decisions to consumers. That, apparently, was not a satisfactory answer.

The WWJD event was widely covered, though its most noteworthy impact was to stimulate jokes. But the campaign’s attempt to inject theology into the SUV debate created a curious paradox. Here were people concerned with issues of morality and ethics, and yet they were absolutely mum about the fact that the program they wanted to tighten had already been found lethal.

The program is CAFE, shorthand for Corporate Average Fuel Economy. CAFE was enacted in 1975 in response to the Middle East oil shocks and was aimed at increasing the fuel economy of new cars and trucks. NHTSA, a unit of the U.S. Department of Transportation, was authorized to establish a series of minimum mile-per-gallon standards that each car maker had to meet in terms of yearly vehicle sales. Not every car sold had to meet this standard; a company’s sales of large cars that were below the standard could be offset by sales of highly efficient small cars, and credits for exceeding the standard in one year could be applied to future production. The current CAFE standard is 27.5 mpg for passenger cars and 20.7 mpg for light trucks, a category that includes pickups, vans, and SUVs. On March 31, NHTSA announced that the light-truck standard, unchanged since model year 1996, would be raised to 22.2 mpg by 2007.

CAFE has been subject to a number of critiques. There’s considerable dispute over whether CAFE actually reduces fuel consumption. By forcing new technologies into vehicles quickly, CAFE raises new-car prices, encouraging many people to hold on to their older, less fuel-efficient cars longer. Moreover, when people have more fuel-efficient vehicles they tend to drive more, since each mile costs less in gasoline.

There’s also the old-fashioned notion that people should be able to buy the vehicles they want, and drive them as much as they want, without government interference. Unfortunately, this argument carries less and less weight in Washington.

CAFE Kills

But perhaps the most interesting critique is that CAFE kills people by causing vehicles to be “downsized.” Larger, heavier cars are less fuel efficient than similarly equipped smaller, lighter cars, but they also tend to be more crashworthy in practically every collision mode. They have more mass to absorb energy forces, more interior space in which their occupants can decelerate, and more momentum, which reduces the severity of their deceleration in accidents. As a result, occupant death rates for small cars are generally higher than those of large cars, sometimes by a factor of four or more.

It’s true that new technologies can improve both safety and fuel economy for small and large cars alike. Nonetheless, no matter what new technologies are developed, CAFE will still impose a blood-for-oil tradeoff. Take the most technologically advanced car imaginable, and then add a hundred pounds to it. Two things will happen—that new car will become less fuel efficient, and it will become crashworthier. In short, even with advanced technologies we still have to choose, at a certain point, between more safety and more fuel economy.

You might think that NHTSA, as an agency whose middle name is safety, would have been extra careful to publicize CAFE’s lethal effects. In fact, it did exactly the opposite, taking the position through most of the 1980s that CAFE had no real impact on safety.

The Competitive Enterprise Institute (CEI) and Consumer Alert sued NHTSA, and in 1992 they won a federal appellate-court ruling that NHTSA’s treatment of the CAFE-safety issue was so arbitrary as to be illegal. In the court’s words, NHTSA had used a combination of “fudged analysis,” “statistical legerdemain,” and “bureaucratic mumbo-jumbo” to duck the issue. The agency was ordered to reconsider its position.

NHTSA took over a year to come up with a new rationale for why CAFE was harmless. CEI and Consumer Alert sued again, and this time the agency won, though the court noted that it found NHTSA’s approach “troubling.” Given the high degree of deference that government agencies receive in court, that was a good indicator that NHTSA was still fudging things.

In 2001, however, any doubts about CAFE’s lethal effects should have been put to rest by a National Academy of Sciences study of the program.* The study concluded that CAFE’s downsizing effect probably contributed to between 1,300 and 2,600 traffic deaths annually. Given that CAFE has been in full force for more than a decade, that is one staggering sum.

The National Academy’s safety findings, however, were not widely reported. Instead, the press focused mostly on the study’s far more tentative conclusion that new technologies, if introduced carefully, would enable the auto industry to meet moderately higher CAFE standards without additional downsizing. In effect, CAFE advocates were able to spin the study as a “blueprint” for raising CAFE, and the public continued to remain uninformed about its human costs.

The “What Would Jesus Drive?” campaign did nothing to enlighten them. When it came to acknowledging CAFE’s risks, the WWJD organizers were no better than NHTSA. For all their talk about concern for God’s creation, they never even hinted that their demand for higher CAFE standards might put people at risk. To do so would have destroyed the moralistic nature of the campaign. While the safety issue had been ignored in the past by CAFE advocates, its treatment by the WWJD campaign reached a new level of dishonesty.

In early January 2003 the anti-SUV campaign embraced a new issue—national security. Erstwhile conservative celebrity Arianna Huffington and her Detroit Project released a series of television spots claiming that owning an SUV was tantamount to funding terrorism.

The ads had superb production values; no surprise, given the Hollywood crowd that was helping her. They were also nonsense—elitist nonsense, to be precise. Here we had a jet-setting celebrity criticizing the vehicles bought by people who had barely a fraction of her wealth. If she was concerned about our use of Middle East oil, then shouldn’t she be advocating opening up the Alaskan National Wildlife Refuge to oil drilling? If her concern was our use of any oil, then shouldn’t she set an example by taking a vow of petroleum abstinence, perhaps, eschewing oil-fueled limos and planes? And if Huffington was serious, then why focus on the types of vehicles we own rather than on the amount of driving we do?

The answer, of course, is that the SUV is so easy to demonize. SUV has come to stand for Scapegoat Utility Vehicle.

While Huffington’s campaign was new, her sentiments, in at least one sense, were not. Changes in mobility have often upset elites. In the early 1800s, when railroads first began to spread across Great Britain, the Duke of Wellington reportedly sneered that they would “only encourage the common people to move about needlessly.” Today the concern isn’t commoners in railroads, but commoners with four-wheel drive.

NHTSA Re-Enters the Fray

Several weeks after the launch of the Detroit Project, Jeffrey Runge, head of NHTSA, attacked SUVs as being incredibly unsafe, declaring that he wouldn’t let his daughter ride in one “if it was the last one on earth.” While Runge, a medical doctor, later backtracked at a congressional hearing, his latter remarks were dismissed by many as a bureaucrat’s buckling to White House pressure. The real story, supposedly, was that the dangers of SUVs had been acknowledged by the head of the nation’s traffic-safety agency, speaking from the heart.

But Dr. Runge, of all people, should have known that focusing on the rollover risk of the SUV misses the real point, which is overall vehicle safety. Because of their higher center of gravity, SUVs do have a higher rollover risk than cars, and some models may be especially bad. But the real measure of a vehicle’s safety is not how it performs in one particular crash mode, but how it does overall. Probably the best indicator of this is a vehicle’s occupant death rate, since that is based on all types of accidents represented according to their frequency. Occupant death rates may themselves need some adjusting, to reflect such things as differing driver demographics, but they nonetheless are a basic means by which to compare vehicles.

The data in the National Academy’s CAFE study indicated that, in fact, cars and SUVs are practically identical when it comes to overall safety. In terms of occupant deaths per million registered vehicles, cars had an overall death rate of 138, while the SUV rate was 140—a negligible difference. Despite everything we’ve heard about SUV rollovers and tire blow-outs, the NAS data show no real difference.

In both categories, moreover, the occupant death rate improved as size and weight increased, demonstrating yet again the lethal effects of downsizing. The most dangerous vehicles were mini-cars, with a death rate of 249. The safest were the largest SUV models, those above 5,000 pounds, with a rate of 92. Dr. Runge has yet to condemn mini-cars or praise large SUVs. What could be more politically incorrect?

Some SUV critics argue that while the vehicles may be safe for their occupants, they are unsafe for the people in the cars that are struck by them. This issue of vehicle incompatibility is complex, however, and it is questionable whether downsizing SUVs would produce enough benefits for car occupants to offset the dangers that it would pose to SUV owners. (Single-vehicle crashes account for half of all occupant deaths, and in those cases more mass greatly protects occupants while posing no risks to outsiders.) Moreover, the same argument could be used to downsize large cars in order to protect small-car occupants, or to downsize all cars in order to protect motorcyclists. If overall “social safety” were the criterion, the best approach would be to simply get rid of CAFE, which currently restricts the extent to which any car can be upsized and made safer.

But of course if safety were the criterion, we would never have had CAFE at all. At a minimum, it would have been hastily repealed after the National Academy report.

Appealing SUVs

The real issue in the anti-SUV campaign is lifestyle. SUVs have become popular because many people find them incredibly useful and appealing. They offer the passenger and cargo capacity that many downsized vehicles no longer have. (The old-fashioned full-sized family station wagon is practically extinct, due in large part to CAFE.) SUVs offer towing capability, a rarity in fuel-efficient front-wheel drive cars. They offer good sightlines, and maneuverability in bad weather and on bad roads—traits that even Consumer Reports admits are valuable. Their height makes them exceptionally comfortable for people who have trouble climbing up out of cars, since in an SUV you climb down. They offer security from smash-and-grab attacks while idling in traffic. They give us the ability to transport not only our kids but also our neighbors’ kids, together with our bikes and dogs and baby carriages. And in snow emergencies, they’re the ones called on to ferry hospital staffs and emergency supplies.

There’s no denying that SUVs do have a certain natural irritation factor, such as the visibility problems they can cause for car drivers. But this hardly accounts for the venomous nature of the attacks. Something else is at work here. Perhaps it’s the fact that SUVs are such an unmistakable sign of human abundance, of other people living their lives, having kids, buying things, going places, utilizing resources.

That never used to bother too many people, but it probably did bother the Duke of Wellington. Now it bothers the Duchess of Huffington. And thanks to our economic growth since the 1800s, her minions are unfortunately far more plentiful than were the Duke’s.

*National Research Council (NationalAcademy of Sciences), Effectiveness and Impact of Corporate Average Fuel Economy (CAFE) Standards (Washington, D.C.: NationalAcademy Press, 2002). See Finding 2 at

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