1

Memo 

To: Docket EPA-HQ-OAR-2009-0472 

From: Joseph McDonald, U.S. EPA-OTAQ-ASD 

CC: Ed Nam, U.S. EPA-OTAQ-ASD 

Date: Tuesday, March 23, 2010 

Re: Ford Curb-weight reduction 

The attached “Blueprint for Sustainability” from the Ford Motor Company document’s Ford’s mid-term 

plans for 2011 to reduce vehicle curb-weight by 250 to 750 pounds and characterizes the weight 

reduction as “Full implementation of known technology”. 
2008/9

Blueprint for Sustainability

Our Future Works

See our full report

www.ford.com/go/sustainability
Welcome

Message from the Executive Chairman and 

President and Chief Executive Officer

In 2008, companies in the automotive sector and virtually every other 

industry were hit by a worldwide economic slowdown of historic 

proportions. A lot has changed since our last report, but our blueprint 

for sustainability and our commitment to pursuing it have not changed. 

Our vision is to provide sustainable transportation that is affordable in 

every sense of the word: socially, environmentally and economically. 

These are uncertain times. We do not know exactly when or how 

much auto sales will recover. We do not know the fate of our U.S. 

competitors or the precise impact it will have on our Company. 

But there are some certainties. The world’s economies and people

are more interconnected than ever. Issues like climate change and 

water availability demonstrate environmental and social 

interconnectedness. Economic conditions will be one of the 

predominant concerns of the public and of politicians for the 

foreseeable future. However, sustainability is now solidly established 

as a top priority for citizens and governments around the world. At 

Ford, we believe this is a positive development, because only when 

we, the people of the world, come together to discuss these issues 

will real progress be made. We also believe strongly that our 

sustainability strategy will be a key component of our business going 

forward. By remaining economically viable, we can continue to make

positive contributions to society and reduce the environmental impact 

of our products.

We have pursued our sustainability agenda despite challenging 

conditions. During 2008, we:

• Were on track to exceed our product carbon dioxide (CO2) goal, 

which calls for a 30 percent reduction in the CO2 emissions of our new 

U.S. and European vehicles by 2020, compared to the 2006 model 

year. We accelerated our electric vehicle strategy and introduced 

several vehicles that achieve best-in-class fuel economy, including the 

Ford Fiesta ECOnetic model, which at 98g/km has the lowest CO2

emissions of any family car sold in Europe.

• Continued to improve our product development, manufacturing

and quality processes to boost vehicle quality, putting Ford on 

par with the best in the business, according to several global 

third-party assessments.

• Cut global water use by 24 percent and improved energy efficiency

in North America by 4.5 percent. Since 2000, we have cut energy use

at our global facilities by 34 percent and CO2 emissions by 45 percent.

• Received the most Top Safety Picks from the U.S.-based Insurance

Institute for Highway Safety of any automaker and introduced a range 

of safety innovations to our vehicles. In the most recent EuroNCAP

assessments, the Ford Kuga, Fiesta, European Focus, Mondeo, 

S-MAX and Galaxy received best-in-class, five-star adult protection 

and four-star child protection ratings.

We welcome you to peruse this document for an overview of our 

progress on several of our most important issues, and visit our Web 

report for full coverage of these and other topics.

“We believe our new products deliver exactly what 

our customers and society need – quality, safety, 

value and, importantly, fuel efficiency.”

“Our economic and environmental goals are 

aligned. In fact, we believe that the best way for 

us to be more profitable is to make our business 

and products more sustainable.”

William Clay Ford, Jr.

Executive Chairman

Alan Mulally

President and Chief Executive Officer

1
As evidence mounts about the effects of climate 

change, the urgency to act increases. The issue affects 

our operations, our customers, our investors and our 

communities. It warrants precautionary, prudent and 

early actions to enhance our competitiveness and 

protect our profitability in an increasingly carbonconstrained economy. In early 2008, Ford announced a 

goal to reduce CO2 emissions from our U.S. and 

European new vehicles by 30 percent by 2020, relative 

to a 2006 model year baseline. 

Blueprint for Sustainability 

We have set out a technology migration plan – embodied in our 

blueprint for sustainability – that details our near-, mid- and longterm plans to meet or exceed the goal. Despite challenging 

economic conditions, we are making significant progress in 

implementing the plan, as described in the box (right).

Our climate change strategy is based on delivering products that 

our customers want while doing our share to stabilize greenhouse 

gas concentrations in the atmosphere at levels generally accepted 

to minimize the effects of climate change. This will require 

considerable increases in vehicle fuel economy globally, as well as 

the development of lower-carbon fuels, including clean electricity.

Climate Change

In 2008 and early 2009, we: 

•	 Accelerated the development of battery electric vehicles (BEV)

and plug-in hybrids (PHEV), which we will introduce in North

America from 2010 to 2012. 

•	 Committed to make all of our new vehicles either best in class

or among the best in class in fuel economy. All of our North

American 2010 model year vehicles and many 2009 model 

year vehicles meet this commitment.

•	 Introduced the EcoBoostTM engine technology on several

vehicles. EcoBoost uses gasoline turbocharged direct-injection

technology to deliver up to 20 percent better fuel economy, 

15 percent fewer CO2 emissions and superior driving 

performance compared to larger-displacement engines. 

•	 Launched the ECOnetic Fiesta, which emits fewer than

100 grams of CO2 per kilometer. It is part of our European 

ECOnetic line of fuel-efficient diesel vehicles.

•	 Launched the Fusion Hybrid, the most fuel-efficient midsize

sedan in the United States. 

Read more online about:

• Ford’s climate change risks

and opportunities

• Our blueprint for sustainability

• Climate change public policy

• Electric vehicles

 Significant number of vehicles 

with EcoBoost engines

 Electric power steering 

 Dual clutch and 6-speed 

transmissions begin replacing 

4- and 5-speeds 

 Four hybrid applications

Introduction of BEV

 Increased unibody applications

 Introduction of additional 

small vehicles

 Introduction of battery 

management systems 

 Aerodynamic improvements to 

increase fuel economy

NEAR TERM

Begin migration to advanced 

technology

MID TERM

Full implementation of known 

technology

LONG TERM

Continue to leverage 

advanced fuel-efficiency 

technologies and increase 

deployment of alternative 

powertrains and energy 

sources

EcoBoost engines available 

in nearly all vehicles

 Electric power steering 

full implementation 

 6-speed transmissions 

full implementation

 Weight reduction of 250–750 lbs

 Engine displacement reduction 

facilitated by weight reductions

 Additional aerodynamic 

improvements

 Increased use of hybrids

Introduction of PHEV

 Diesel use as market demands

 Increased percentage of 

internal combustion using 

renewable fuels

Volume expansion of

hybrid technologies

 Continued leverage of 

PHEV, BEV

 Introduction of fuel cell vehicles

 Clean electric/hydrogen fuels

2007 2011 2020 2030

Climate Change Policy 

We are committed to advocating for effective and appropriate 

climate change policy in the United States and around the world. 

We are an active member of the U.S. Climate Action Partnership 

(USCAP), a coalition of diverse stakeholders that is advocating for 

comprehensive U.S. cap-and-trade climate legislation. Our CO2

product goal is aligned with the USCAP recommendations and 

positions our products to meet or exceed new fuel economy 

requirements in the United States and Europe.

Improving Fuel Economy

Fusion Hybrid

At 41 mpg in city driving

and 36 mpg highway

(EPA rating), the Ford

Fusion Hybrid is the most

fuel-efficient midsize

sedan in the United States.

2

More about climate change

www.ford.com/go/sustainability
Mobility

New Mobility Solutions 

We believe that creative collaboration and innovative technologies 

and services can yield new solutions, and that these new models 

can harness the benefits of mobility while reducing its environmental 

and social impacts. Information technology shows promise for tying 

modes of transportation seamlessly together. Ford has been a 

leader in exploring the potential for these models to contribute to 

solutions, especially in urban areas. 

As mobility models change, so do the needs of our current and 

potential customers. The insights we gain from our sustainable 

mobility work help us to understand the forces that are shaping our 

markets, our role in addressing mobility challenges and the 

opportunities these trends present for us.

Our goal is to make mobility affordable in every sense of 

the word – economically, environmentally and socially. 

Today, there are 6.7 billion people in the world. By

2050, there will be 9 billion people, 75 percent of whom 

will live in urban areas. Forty of the world’s 50 largest

cities will be in countries outside of North America,

Europe or Japan. These mega-cities – urban areas of 

5 million to 10 million people or more – will be 

increasingly affluent and crowded.

Residents of these cities will want – and deserve – the same

freedom of mobility that many in developed nations enjoy today.

But, because of energy costs, climate change concerns,

infrastructure constraints and resource limits, business as usual will 

not work.

We need to explore sustainable alternatives. Ford has worked 

with a wide range of academic and public- and private-sector 

partners to explore sustainable mobility issues, advance thinking 

and test different approaches to urban mobility. For example, we 

are using our mobility expertise to forge partnerships among Ford, 

municipal governments and utilities aimed at building markets for 

electric vehicles.

Urban Challenges 

Many cities are already imposing regulations to restrict the use of 

private transportation. London, Vienna and Bucharest, for example,

have established anti-congestion policies in the form of a tax on 

personal vehicle usage in the city center. Legislation is pending in

Berlin, Paris and Tokyo to enforce zero-emission public transportation. 

Adding more and more privately owned cars to a mega-city may 

not be possible, and certainly isn’t practical. A car stuck in traffic

wastes time and energy; a car sitting in a parking garage wastes 

a valuable asset.

Read more online about:

• Mobility challenges and

opportunities

• Collaboration to support

electrification

• Mega-cities

• New mobility

Atlanta

Ford and Georgia Tech 

are developing and testing 

mobility solutions for one 

of the United States’

most congested cities. 

During 2008, we: 

•	 Cosponsored a major forum on mobility at the University of

Michigan that brought together leading thinkers from around 

the world to share knowledge and insights and plan 

collaborative projects.

•	 Concluded our involvement in pilot mobility projects in Cape

Town, South Africa, and Bangalore and Chennai, India,

gaining important insights that will aid us in the future. 

•	 Refocused our mobility efforts on products like electric

vehicles, bringing together fleet managers, utilities and city 

managers to encourage use of these technologies in 

alignment with the priorities of the new U.S. administration.

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More about mobility

www.ford.com/go/sustainability
Ford has long recognized that treating people with 

dignity and respect is fundamental to how we conduct 

business. We are committed to honoring human rights 

everywhere we operate, because it’s the right thing to

do and it strengthens our business in the long run. Our 

human rights goal is to leverage Ford’s complex global

supply chain to make a positive impact in the markets 

in which we do business.

In 2000, we made human rights a core element of our sustainability 

strategy. In 2003 we began implementing the Ford Code of Basic

Working Conditions (CBWC), which applies to our own facilities and

those of our joint-venture companies and suppliers. Ford requires

suppliers to ensure that products – no matter where they are made 

– are manufactured under conditions that demonstrate respect for 

the people who make them. This is just as important to us as

quality, cost competitiveness and timeliness of delivery.

The CBWC covers workplace issues such as working hours,

child labor and forced labor, as well as broader issues such as

bribery and corruption, community engagement, and environment 

and sustainability.

We take a three-pronged approach to human rights issues in our 

supply chain:

Engagement with Individual Supplier Facilities

The primary focus of our supply chain human rights program is 

building capability among our suppliers to responsibly manage 

working conditions, including meeting legal requirements and Ford 

expectations. We have developed and delivered tailored training 

programs for Ford suppliers in select countries in cooperation with 

the Automotive Industry Action Group (AIAG). We also regularly 

conduct assessments of the working conditions at existing and 

prospective suppliers’ facilities.

Engagement with Key Suppliers’ Corporate Management

Ford has formalized its relationship with 65 key suppliers through its 

Aligned Business Framework (ABF). One element of the ABF

agreement is the commitment by these suppliers to manage and 

assure proper working conditions in their facilities and in their own 

supply chains. ABF suppliers are asked to establish a code of

conduct aligned with the CBWC, conduct internal awareness

training, develop compliance processes and extend these 

expectations to their suppliers. 

Collaboration within the Automotive Industry

Ultimately, Ford would like all automakers to take a coordinated 

approach to protecting human rights and environmental conditions 

in the supply chain. Ford is driving this collaboration between 

automakers and supply chain companies through the AIAG, which 

has conducted automotive supplier training in China and Mexico. In 

addition, in December 2008, the AIAG and the five participating 

auto manufacturers held two pilot working conditions training 

sessions targeted at senior management from the procurement 

organizations of their top supplier companies.

In early 2008, Ford joined the United Nations Global Compact

(UNGC), a framework for businesses that are committed to aligning

their operations and strategies with 10 universally accepted 

principles in the areas of human rights, labor, the environment and 

anti-corruption. We are the only manufacturing company 

participating in the UNGC’s Human Rights Working Group. These

actions reinforce our commitment to outstanding performance and 

transparency in the areas of human rights and working conditions.

Human Rights

Since 2004, Ford has conducted:

•	 41 formal working conditions assessments of Ford or

joint-venture facilities.

•	 550 assessments of the human rights practices of existing

and prospective suppliers in 20 countries. 

•	 Training in human rights and working conditions issues for

1,621 managers at 1,317 supplier companies. 

•	 Training sessions in China and Mexico that reached nearly

1,000 Tier 1 suppliers and 7,700 Tier 2 suppliers and were 

cascaded to more than 66,000 individuals. These sessions 

were in conjunction with other automakers and the AIAG.

Read more online about:

• Ford’s Code of Basic Working

Conditions

• Our supply chain profile

• Our supply chain working

conditions training and 

assessment status 

Ford’s Code of Basic

Working Conditions 

applies to our own 

facilities and those of our 

joint-venture companies

and suppliers. 

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More about human rights

www.ford.com/go/sustainability
Here at Ford, we are continuously enhancing the safety 

of our vehicles and sharing safety research and 

technologies across all of our brands. In 2008, our 

efforts were once again rewarded, and we set new 

standards for safety test performance. Based on the

independent measures listed below, Ford is now the 

industry leader in motor vehicle safety. 

Our primary focus at Ford is designing and manufacturing vehicles 

that achieve high levels of vehicle safety for a wide range of people 

over the broad spectrum of real-world conditions. We also seek to 

encourage safer driving behavior and a safer driving environment. 

For example:

Ford’s award-winning SYNC® system, powered by Microsoft®, 

enables drivers to use cell phones and MP3 players more safely, 

because they can do so through voice commands alone while 

keeping their eyes on the road and hands on the wheel. Beginning

with the 2009 model year, SYNC-equipped vehicles come with 911

Assist, which can help in placing a call to a local 911 emergency 

operator in the case of an air-bag-deploying accident. 

Ford’s new MyKeyTM system is designed to help parents 

encourage their teenagers to drive more safely. MyKey allows 

owners to program a key that can, for example, limit the vehicle’s

top speed to 80 mph and the audio volume to 44 percent of total 

volume, among other features. 

Ford’s U.S.-based Driving Skills for Life (DSFL) driver education 

program was launched in the Philippines, Vietnam, Thailand and

Indonesia in 2008. More than 5,400 driver participants have taken 

part in the program in those markets thus far. A DSFL-related

statewide effort in Illinois, called Operation Teen Safe Driving, helped 

to reduce teen accident fatalities by more than half in the year 

following that program’s implementation.

Ford’s accident avoidance features, which use forward-looking 

radar and vision sensors, continue to be developed and introduced. 

For example, City Safety, an award-winning system introduced by 

Volvo in 2008, helps drivers avoid low-speed collisions. If a driver is

about to collide with the vehicle in front and does not react in time, 

the City Safety system is designed to activate the brakes to slow 

the vehicle. 

Ford’s collaborative research efforts include a large-scale field 

operational test on active safety systems, launched in Europe in 

2008. The project joins together 28 partners – including vehicle

manufacturers, suppliers, universities and research centers – and 

will run for three years. It is led by the Ford research center in 

Aachen, Germany. 

Vehicle Safety

2008 Highlights

•	 Ford holds the most Top Safety Picks (awarded by the

Insurance Institute for Highway Safety, or IIHS) of any vehicle 

manufacturer. Fourteen Ford vehicles earned this honor in 

2008, compared with eight in 2007. 

•	 For the 2009 model year, 24 Ford vehicles received five-star

ratings for both frontal impact and side impact from the 

National Highway Traffic Safety Administration (NHTSA) in its

U.S. New Car Assessment Program (NCAP) ratings,

compared with 15 for the 2008 model year.

•	 The 2009 Ford Taurus is the safest-rated large sedan sold in

America, with five-star NCAP crash ratings for frontal and side

impact and “good” IIHS ratings in offset frontal impact, side 

impact and rear impact evaluations.

•	 The 2009 Ford F-150 is America’s safest full-size pickup. It’s the

only pickup to earn five-star crash-test ratings in all categories 

from NHTSA and be named a Top Safety Pick by the IIHS.

•	 In the most recent EuroNCAP assessments, the Ford Kuga

and Ford Fiesta achieved Ford’s first three-star ratings (out of

a possible four stars) for pedestrian protection. These cars 

also joined the Focus, Mondeo, S-MAX and Galaxy in having

best-in-class, five-star adult protection and four-star child 

protection ratings (out of a possible five stars). 

Read more online about:

• How we manage vehicle safety

• Our occupant protection

technologies

• Our road safety research

partnerships

Safety Research 

Ford uses “balloons” 

nearly the size and shape 

of real cars to test 

active-safety features.

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More about vehicle safety

www.ford.com/go/sustainability
The year 2008 undeniably ranks among the most 

difficult in Ford’s history. It was a year marked by

workforce reductions, plant closures, dramatically 

reduced consumer demand for vehicles and the worst 

global economic downturn in decades. Despite a 

profitable first quarter, the financial crisis and related 

credit crunch acutely affected our worldwide operations 

and challenged all of our stakeholders.

Over the past several years, we have undertaken a fundamental 

restructuring of our operations that affects every part of our business, 

from product innovation and fuel efficiency to labor relations and 

our interactions with suppliers and dealers. In difficult economic 

times, it is more important than ever for Ford to stay focused on 

issues of sustainability. 

In the past we allowed our portfolio to become too dependent on 

popular and profitable trucks and SUVs, missing opportunities to

advance production of small and midsize cars. In short, Ford 

recognized that our business model needed to change, and we are 

changing it. 

As part of our plan to return to profitability, we are working to reverse 

the decades-long trend of losing money on the production of small 

cars in the United States. We are increasing production of smallersized vehicles, and we are improving costs to competitive levels. 

While the sales trends for 2008 were gloomy, we expect that our 

overall and our North American Automotive business pre-tax results

will break even or be profitable in 2011, excluding any special items. 

More and more, consumers are recognizing Ford vehicles for their 

quality and performance. 

Restructuring Ford 

We continue to make the tough decisions needed to match our 

production capacity to the demand for new vehicles. Since 2005, 

we have reduced our U.S. payroll through buyouts, layoffs and 

attrition, and have closed 12 North American manufacturing

facilities. Four additional plant closures are slated to take effect 

between 2009 and 2011. We have eliminated pay raises and 

performance bonuses for 2009, suspended programs such as 

401(k) matches and tuition assistance, and increased employee 

cost sharing in benefit programs. 

In early 2009, the UAW agreed to a number of key contract 

modifications that will save Ford $500 million a year – and possibly 

even more – through a restructuring of the retiree health care

trust fund, along with other actions relating to paid break time, 

alternative work schedules, performance bonuses and Cost of 

Living Allowances.

These actions have been difficult for the Company and our 

stakeholders. We have attempted to handle workforce separations and 

plant closings with respect for the people and communities affected. 

Adapting to Change 

Looking to the future, we are leveraging our best technology from

around the world to create global platforms that offer superior fuel 

economy, safety, driving dynamics and customer features. We then 

tailor the global platform to national or regional preferences and 

requirements. New technology is cutting the time required to bring

new vehicles to market. These steps will help build a truly global 

company, strengthen our financial, environmental and social 

sustainability and help us respond more effectively to the everincreasing pace of change in our markets.

Sustaining Ford

In 2008, Ford continued to take many of the decisive actions 

necessary to ensure a healthy future for our Company: 

•	We have shifted our emphasis away from trucks and

SUVs to a more balanced portfolio including more small

and midsize vehicles. 

•	We have set a CO2 emissions-reduction goal for our U.S. 

and European vehicles, and we are on track to exceed it. 

•	We implemented our “One Ford” plan to create a leaner,

more efficient global enterprise. 

Read more online about:

• The One Ford plan

• 2008 sales trends

• Our North American restructuring

Our One Ford plan is anchored 

by four key priorities:

• Aggressive restructuring

• Accelerated product development

• Improving our balance sheet

• Working together

EcoBoostTM

Delivers up to 20 percent 

better fuel economy and 

15 percent fewer CO2

emissions compared to 

larger-displacement 

engines.

More about sustaining Ford

www.ford.com/go/sustainability
Performance Overview

We define sustainability as a business model that creates 

value consistent with the long-term preservation and 

enhancement of environmental, social and financial capital. 

Below are some key indicators of our performance in these

areas. See the full data set and notes at

www.ford.com/go/sustainability.

7

For notes to accompany this data go to the full report 

www.ford.com/go/sustainability

FOrd data 2008/9 

 ECONOMY 2006 2007 2008

GQRS things gone wrong (3 months in service), total things gone wrong per 1,000 vehicles 1,586 1,405 1,287

GQRS customer satisfaction (3 months in service), percent satisfied 74 76 77

Sales satisfaction with dealer/retailer, Ford brand, U.S., percent completely satisfied 81 82 84

Sales satisfaction with dealer/retailer, Ford brand, Europe, percent completely satisfied 81 80 81

Service satisfaction with dealer/retailer, Ford brand, U.S., percent completely satisfied 70 72 74

Service satisfaction with dealer/retailer, Ford brand, Europe, percent completely satisfied 67 68 70

Shareholder return – Bowne & Co., Inc., percent 1 -10 -37

Net income/loss, $ billion -12.6 -2.7 -14.7

Sales and revenue, $ billion 160.1 172.5 146.3

 ENVIRONMENT 2006 2007 2008

Ford U.S. fleet fuel economy, combined car and truck, miles per gallon (higher mpg reflects improvement) 23.8 25.3 26.0

Ford U.S. fleet CO2 emissions, combined car and truck, grams per mile (lower grams per mile reflects improvement) 371 352 340

European CO2 performance, percent of 1995 base (1995 base = 100 percent) (lower percentage reflects improvement)

Ford 78 78 77

Volvo 86 84 81

Worldwide facility energy consumption, trillion BTUs 73.8 65.6 61.0

Worldwide facility energy consumption per vehicle, million BTUs 12.2 10.8 12.2

Worldwide facility CO2 emissions, million metric tonnes 6.7 6.1 5.4

Worldwide facility CO2 emissions per vehicle, metric tonnes 1.11 1.01 1.09

North American Energy Efficiency Index, percent (2000 base = 100 percent), (lower percentage reflects improvement) 78.4 74.4 69.9

 SOCIETY 2006 2007 2008

Employee satisfaction, Pulse survey, overall, percent satisfied 62 64 66

Overall dealer attitude, Ford, relative ranking on a scale of 1–100 percent (summer/winter score) 64/64 69/64 68/69

Overall dealer attitude, Lincoln Mercury, relative ranking on a scale of 1–100 percent (summer/winter score) 62/64 66/64 64/66

Ford Motor Company Fund contributions, $ million 58 37 33

Corporate contributions, $ million 25 17 16

Volunteer corps, thousand volunteer hours 80 86 100

Lost-time case rate (per 100 employees), Ford Motor Company 1.1 0.9 0.7

Lost-time case rate by region (per 100 employees), Ford Motor Company 

Americas 1.5 1.2 1.0

Asia Pacific/Africa 0.1 0.1 0.1

Europe 0.9 0.7 0.6

Severity rate (per 100 employees), days lost per 200,000 hours worked 14.5 12.6 13.5

U.S. safety recalls, number per calendar year (including legacy vehicles on the road for 10+ years) 11 15 10

U.S. units recalled, number of million units (including legacy vehicles on the road for 10+ years) 1.7 5.5 1.6

IIHS Top Safety Picks, number of vehicles 6 8 14

Contact

Preparing this summary offers a valuable 

opportunity for us to assess and improve 

upon our progress and performance. To 

continue to do so, we need your feedback:

Thomas A. Niemann

Ford Motor Company

One American Road

Dearborn, MI 48126, U.S.A.

sustaina@ford.com