Fuel Consumption


Agency Administrative Actions




I apologize for the delay in my response to Mr. Hudgins and Mr. White. I have been away from home for work-related travel in the States and overseas. It has pained me not to be able to respond more promptly. While this response may not have the brevity desired for web publication, I would urge you to forward the full text to Mr. White and Mr. Hudgins, as I am writing this in direct defense to their attacks on my previous writing.

Regrettably, I made a typographical error with huge implications when I was comparing SUVs’ vs. passenger vehicles’ emissions. While I intended to point out that SUVs are allowed to emit more carbon MONoxide (CO), I instead wrote carbon DIOxide (CO2). Mr. Hudgins and Mr. White were correct in attacking this point, as CO2 emissions directly correlate with the amount of fuel used, regardless of the vehicle in which they are burned. CO however, is a smog producing pollutant, and SUVs are not held to the same standards as passenger cars when it comes to emitting CO and nitrogen oxides.

While I strongly regret the error, it was only an error, similar to Mr. White’s repeated misspelling of my last name throughout his letter, and not, as he seemed to imply, a deliberate attempt by me to distort the facts in order to give credibility to my argument.

Mr. White argues that the Expedition emits nitrogen oxides at a rate lower than permitted for passenger cars. It is true that Ford Motors voluntarily began in 1999 to build all of it’s SUVs to emit roughly the same pollution as cars, much to the chagrin of it’s main competitors, GM and Chrysler. It cost Ford roughly $100 per vehicle to do so and made it possible for Ford to avoid having to be apologetic as far as smog-producing pollutants were concerned. It also had the added benefit of requiring other SUV manufacturers to spend a lot more money if they wanted to be competitive in this regard.

However, even with this improvement, the Expedition has an EPA emissions rating of 3 (on a scale of 1-10), not exactly a stellar performance from an environmental perspective. While this rating is calculated measuring CO2 emissions (directly proportional to the amount of fuel burned), and Mr. Hodgins has made it clear that his Expedition gets a miraculous 27 mpg, we can assume that this rating does not apply to his Expedition.

Let me linger for a moment on the case of Mr. Hodgins’ very unique Expedition.
A vehicle’s window sticker will indicate it’s mpg performance for city and highway driving. The Expedition claims 14 mpg and 18 mpg respectively.

To understand how window stickers relate to real-world driving conditions, it is necessary to understand how vehicles are tested for fuel economy.

A vehicle is placed on an instrument called a dynamometer, which simulates driving conditions while the vehicle remains stationary. The vehicle is tested at a speed of 48 mph to represent highway speeds, and 20 mph representing city driving. The test does not take into account the actual speed that people drive on highways, air-conditioner use, growing traffic congestion, or the cleanliness of gas at different fueling stations. The test also assumes road conditions are at their best: level paved roads, no wind, scrupulous adherence to speed limits, and only one person in the car. Because of the disparity between real-world driving conditions and those simulated in testing, the EPA began adjusting lab figures downward in the late ‘70’s to reflect more realistic driving conditions.

However, most drivers still complain that they are unable to meet the mileage standards indicated by their window sticker. At, a consumer-generated product review guide, I found gas mileage to be consistently mentioned as one of the “weaknesses” by Expedition owners, and I only scanned those reviews which gave the Expedition the highest “overall” rating of 5. Not once did I encounter a review citing higher than listed mileage. Ironically, given the Expedition’s towing capacity, only a handful of the reviewers even mentioned towing capacity as a “strength”. I have to ask: Why purchase a vehicle with this kind of towing capacity if you have nothing to tow? In regards to poor gas mileage, while quite a few owner/reviewers complained, most were unconcerned, and took for granted that a vehicle this size would perform poorly. As one poster very succinctly put it: “Oh well, I guess if you can afford the vehicle, you can afford the gas.”

An October 2000 survey by the Canadian Broadcasting Corporation’s Marketplace, a consumer-affairs program, concluded that two-thirds of the drivers surveyed recorded poorer gas mileage than that which their cars were supposed to get. Taking the results of the survey to Dave Checkel, professor of Mechanical Engineering at the University of Alberta in Edmonton, they recorded his response: “You’ll get something like ten, fifteen percent worse if you’re just doing typical driving...thirty to forty percent worse if you’re a very aggressive driver and using a lot of power.”

Given that the average driver has trouble meeting the fuel economy given for their make and model, and that the Big Three have consistently had trouble meeting federal mileage standards (resorting to underhanded tactics like the production of more “dual fuel” vehicles in order to raise their average fuel economy), I would assume that Ford Motors would be very interested in your particular Expedition, and what would be causing it to exceed mileage expectations by such an amazing margin.

I have to ask the question, Mr. Hudgins: Did you know when you leased your new Expedition that your average mileage would so greatly exceed the window sticker’s estimate? I am assuming that you willingly leased a vehicle that you believed would only get about 18 mpg, under optimal driving conditions, and that the added mileage must have been a pleasant surprise. My point is that for most SUV drivers, fuel economy does not seem to be among their priorities.

On to another point. Mr. White stated: “Many of the personal attacks Ms. Mars (sic) quotes in her attacks on SUV drivers in general (" Above all, they are apt to be self-centered and self-absorbed") apply equally to drivers of over priced German and Japanese Luxury cars and to people who ride in Limos to anti-SUV protests.”

Let me first stress that the source of the “personal attacks” on SUV drivers came directly from SUV market research, paid for by the people who manufacture and market SUVs. I referenced the book High and Mighty: SUVS: the World’s Most Dangerous Vehicle and How They Got That Way, by Keith Bradsher. While undoubtedly an anti-SUV work, Mr. Bradsher makes it implicitly clear that he did not rely on outside critics for information, but “tried to quote the auto industry’s own executives, the men and women who have designed, built and marketed SUVs...” Let me also add that Mr. Bradsher is an award winning, Pulitzer nominated journalist, whose name is often mentioned in tandem with Ralph Nader. (Mr. Nader certainly earned the enmity of automakers with his book Unsafe at any Speed, published in 1965. Mr. Nader’s crusade ultimately resulted in safer cars, which have saved countless lives.) I will quote Mr. Bradsher’s book liberally in the next several paragraphs.

While it would stand to reason that it would not benefit the manufacturers of SUVs to personally attack or insult it’s prospective customers, it does pay to know what those potential customers are thinking, and to market vehicles accordingly.

Consider the Cadillac Escalade with it’s ads cautioning other drivers to “YIELD”. Or the Lexus LX 470: “Now with added intimidation”. Or the Chevrolet Avalanche: “We didn’t intend to make other trucks feel pathetic and inadequate, it just sort of happened”. This is pretty much in keeping with the Hummer’s “the only SUV that can drop and give you twenty”. The message is clear. Bigger is better. The more intimidating to other drivers, the better. My vehicle is bigger than yours, so you better get the hell out of my way.

In spite of the fact that they are designed for serious off-road driving, and SUV advertising is always keen to point out an SUVs off-road capabilities, a minuscule amount are ever taken off-road. To quote J.C. Collins, Ford’s top marketing manager for SUVs and mini vans: “SUVs are about image, it’s about who the customer is and who that customer wants to be. The only time those SUVs are going to be off-road is when they miss the driveway at 3 a.m..”

Auto industry surveys indicate that one in six SUV owners use their vehicles at least once a year for towing, while the percentage of SUV drivers who say they use them for off-road driving varies from 1 -13 percent, depending on how the question is asked. SUVs are designed to tow large loads and to drive off-road. If you do little or none of either, you do not need an SUV.

As far as the drivers of luxury cars, or “people who arrive in limos to anti- SUV protests”, these drivers do not make up a significant portion of the population, and it is fairly ridiculous to make comparisons to such a marginal “consumer group”. Overpriced German luxury cars do not trouble me at all, because they are considerably easier to see around, and with their superior agility, handling and braking distances, and because of their weight and design, they do not pose anywhere near as great a threat to me and my family as a full-sized SUV. I would much rather maneuver my way out of a parking lot full of Bentleys and Maybachs than one filled with Expeditions and Yukons. Have you ever tried to back out of a parking space in a car with an SUV on either side of you?

Furthermore, “light trucks” are once again exempt from a gas-guzzlers tax that was enacted in 1978, subjecting cars with gas mileage 5 or more miles below the federally mandated standard, to a separate tax. The tax adds as much as $7,700 to the price tag of some of the most inefficient sports cars.

Given that SUVs now account for roughly 30% of all new cars sales, and the relatively small market share of luxury imports, I am not likely to be concerned with the marketing profile for buyers of these cars.

Mr. Hudgins: you seemed to take special offense at my mention of the Hummer, assuming that I was using it as a basis of comparison to your Expedition. Indeed, the bulk of your counter-argument revolves around my supposed attempt to equate “apples and oranges”.

Actually, I used the name “Hummer” in the body of my letter only once, and referenced it only to show the growing trend of SUVs as status symbol vehicles. You are right to have your sensibilities outraged by these road behemoths, Gregory. I would assume that any sensible person could not reasonably argue that the Hummer is a viable alternative to the family car, and the only viable use for a vehicle of this size is for towing extremely heavy loads. Interestingly, however, is that while doing research on the Expedition at Car and Driver’s web site, a helpful little feature at the bottom of the review “You may also be interested in:” pointed me to a link for the Hummer H2.

You argued that the Hummer should not even be considered an SUV:
“ If you simply compare the SUV statistics, the Hummer is not an SUV. It is the equivalent of a commercial grade tow-truck, at the least.” Although it was not originally my intention to equate these vehicles in any way other than as status symbol vehicles, I took your advice, and compared some statistics. The Hummer H1 and H2 have towing capacities of 7,986 pounds and 7,000 pounds respectively. Your “Best in Class Towing Capacity” Expedition can tow 8,900 pounds. So your family car can out-tow the Hummer, a “commercial grade tow-truck”.

Regardless of what the Hummer is or is not, it is certainly being marketed by G.M. as an SUV: “In a world where SUVs have begun to look like their owners, complete with love handles and mushy seats, the H2 proves that there is still one out there that can drop and give you 20”.

The H2 does have you outdone on Base Curb weight. While the 2003 Expedition with a 4.6 liter SOHC Triton V8 engine weighs in at 5,564 pounds (add about 120 pounds for the 5.4 liter version), the H2 weighs in at 6,400 pounds.

It is my opinion that the H2 is the natural extension of the trend towards ever-larger, more powerful SUVs. Your Expedition was designed specifically to meet the demands of Ford customers who were asking for something larger than the Explorer, and more luxurious than the crude, two-door Bronco. Ford was only too happy to oblige. The entire front third of the vehicle was identical to the front end of an F-150 pickup truck, the back two-thirds shared many of it’s parts, and they could easily be manufactured at the same factories as the F-150s. By adding a couple of extra doors and a couple of rows of seats, Ford was able to transform it’s pickup truck into an immensely popular and profitable “new vehicle”, without the years of design analysis and millions of dollars typically invested in a new model. Change a few body panels, add a huge chrome grill and 200 pounds of sound-deadening foam, and viola!, you have the Lincoln Navigator.

Incidentally, the curb weight for a 2003 Explorer 4x4 is 4,374 pounds. Your Expedition is 16.3” longer, 6.6” wider, and 6.2” taller than the Explorer. To give some perspective, the curb weight for the 2004 Volvo V40 4 door station wagon is 2,822 pounds. It is 178.0" long, 67.6" wide, and 56.1" tall.

Now let’s compare the 2003 Expedition and the 2003 Hummer H2:

2003 Expedition 2003 Hummer H2

Exterior length 205.8” 189.8”

Exterior Width 78.7” 81.2”

Exterior Height 77.6” 77.8”

So, while your Expedition is 6” longer than the Hummer, the Hummer is a mere 2.5” wider and only 0.2” taller. The Expedition, in terms of these dimensions has much more in common with the Hummer H2, than with the mid-sized Explorer.
For the driver of the Volvo V40, the miniscule differences in width and height between the Expedition and H2, would offer very little consolation if he or she were unfortunate enough to be sandwiched between the two. A full 22’ inches shorter than either vehicle, the Volvo driver would be at an extreme disadvantage when it came to seeing around either vehicle, or through the dark-tinted rear windows (a feature “passenger vehicles” are prevented by law from having) of either vehicle.

I can only speculate how the Volvo driver would fare if involved in a collision with either vehicle. While the H2 outweighs the Expedition by less of a margin than the Expedition vs. the Explorer, research into crash compatibility in recent years demonstrates that the design of a vehicle is at least as important a factor as it’s weight. In addition to their weight, it is the high front ends and stiffness of SUVs that make them so deadly to drivers of cars, allowing them to drive over cars’ bumpers and reinforced door sills, and drive right into the passenger compartment.

This extra height and weight offers little extra protection to the SUV occupants. Their height makes them more likely to rollover, and their stiffness prevents them from crumpling, effectively transferring the force of a collision to their occupants’ bodies. SUV engineers are finally taking steps towards making the vehicles more crash compatible with lighter, lower riding cars, but still have very far to go, and meanwhile millions of previously manufactured SUVs will be on our roads for many years to come.

Because of the sheer number of them that have been involved in crashes (being America’s most popular SUV since 1991, and representing about 1 in 7 of SUVs currently on the road), the Ford Explorer offers statisticians a plethora of comparative data in crash compatibility. According to research by Hans Joksch of the University of Michigan, High and Mighty author Keith Bradsher drew the following conclusion (an unbiased, mathematically achieved conclusion, I should add) : “ for each Explorer driver whose life is saved in a two-car collision by choosing an Explorer instead of a large car, an extra five drivers are killed in vehicles struck by Explorers”. ( High and Mighty, chapter 9: “Kill Rates”) Given the Expedition’s increased weight and height, it would probably be safe to assume that they pose an even greater threat to car drivers than the Explorer.

To take a moment to address Mr. Hudgins’ accusation of biased input; I referred him to exactly one online article, “online entities” suggests a plural. The article and web site in question was decidedly anti-SUV (, however the page in question dealt with basic engineering tenets and principles as they apply to SUV manufacture, and is not necessarily anti-SUV in and of itself.

Mr. Hudgins, you also inferred that a camaraderie exists between SUV drivers, and that an SUV driver who would try to “out muscle” you while you are in your Camry, would not be as likely to do so if you are in your own SUV. This is very small consolation to the rest of us who do not drive SUVs. Your point is that it is the driver mentality and not SUV construction that poses a risk to drivers of cars. Again, small consolation to us car drivers, and decidedly untrue. Even if SUV drivers aren’t inherently more aggressive drivers, the weight and design of these vehicles pose a serious threat to other drivers involved in a collision with an SUV. No one intentionally causes an accident. Even conscientious drivers make mistakes. The truth is, I would be better off in a collision with a reckless teenage boy driving a Mustang, than with a soccer-mom momentarily distracted by kids in the back seat, driving an Expedition.

I too have two children, and am as concerned for their safety as any other parent. Since I could not reasonably argue that two kids makes for a large family, since I am not required to tow anything with recurring frequency, since I am not required to pull heavy farm equipment out of deep mud or snow, traverse steep muddy or rocky driveways (mine being paved, like most people’s), and since my Volvo manages to get over those speed bumps at the mall without the benefit of 4 wheel drive, I acknowledge that I do not need an SUV for my primary family vehicle.

To drive one anyway, knowing that I posed a significantly greater threat to other motorists, while achieving marginal improvements in my own safety (as long as I do not have to swerve quickly, increasing my chances of rolling over), to contribute to the problems of traffic congestion (drivers tend to put more space between themselves and SUVs, thus allowing fewer cars through a green light, etc.) smog and greenhouse gases, and America’s dependence on imported oil, and to obstruct other motorist’s view of the road, would seem to me a horribly unconscionable act.

Yes, there are pickup truck drivers who do not need a pickup for it’s utilitarian purposes (I would venture to bet that more pickup drivers actually use their pickups for the work they are intended, than do SUV drivers). Yes, there are drivers of gas-guzzling sports cars, and yes, there are RVs on the road. While the problems these other vehicles pose should be addressed, again, I will point out that they represent a relatively small segment of the market when compared to SUVs. Mr. Hudgins especially likes to point the finger at these drivers: But what about them? Pointing out that there are other drivers who do not drive socially responsible vehicles, in keeping with their real vehicle needs, does nothing to support your own case, and is the kind of tactic my 13 year old would resort to: “but Matt and Zach did it too!”

In regards to your children’s safety, Mr. Hudgins, how safe will you feel when half of the passenger vehicles on the road are as big as your own? How safe will your children be when they enter their driving years, only to encounter other inexperienced and reckless teen-aged drivers in huge, 12 year-old Expeditions with failing brakes? No one could reasonably argue that an SUV is a good first car for children learning to drive. They are difficult to maneuver, they roll over easily, they give the driver an illusion of invincibility, they take longer to come to a complete stop, and they pose a terrible threat to pedestrians and other motorists. However, teenagers tend to buy used cars, and they really like SUVs. Every two years when you trade in your Expedition for a new one, you are contributing one more used vehicle to the market. Hopefully by the time your children are ready to drive, Ford will have something much bigger than your Expedition that you can pack them off to school in.

Christina Marrs
Austin, TX

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