White House staff prompted the development of a controversial proposed overhaul of the entire structure of automobile fuel economy regulation aimed at diminishing standards. Foremost among the architects of the change was John Graham, administrator of OMB's Office of Information and Regulatory Affairs (OIRA). According to documents obtained by Public Citizen, high-ranking administration officials began working on changes to automobile fuel economy regulation as early as summer 2001. Leaders of powerful offices, ranging from the Office of the Vice President to the Council of Economic Advisors to top staff from a wide array of government agencies, began meeting in earnest and circulated numerous draft proposals and e-mail correspondence on the issue. At the same time that substantial resources were being invested in the corporate average fuel economy program (CAFE), Jeffrey Runge, administrator of the National Highway Traffic Safety Administration (NHTSA), claimed that NHTSA was unable to develop safety standards to prevent SUV rollover because the Ford-Firestone crisis had preoccupied too much of NHTSA's time. CAFE regulates automotive fuel efficiency in a two-tiered system that divides the auto fleet into two classes, passenger vehicles and light trucks, and accords different fuel economy standards to each. Highway safety advocates argue that the current standard, which demands 27.5 miles per gallon for passenger vehicles and only 20.7 for light trucks, encourages the production of more vehicles designated as light trucks and, in turn, increases the risk of death and serious injury in two-car collisions with passenger cars. NHTSA announced in an Advance Notice of Proposed Rulemaking that the very structure of CAFE regulation could be overhauled, with one possibility being dividing the vehicle fleet based on vehicle weight. Public Citizen criticized that proposal in its formal comments, arguing that NHTSA's proposal is based on a study that is deeply flawed. In these comments, Public Citizen appended summaries from documents it received under the Freedom of Information Act (FOIA). FOIA excludes from its disclosure requirements most interagency consultations conducted in advance of agency decisions, but Public Citizen was able to unearth details of the extent to which high-ranking officials were meeting on CAFE by acquiring calendar notes and other logs which document that meetings had occurred. Among the revelations is that OIRA's Graham was prominent in CAFE discussions, and the proposed structural change based on weight classifications mirrors Graham's overemphasis on vehicle weight in two articles he worked on at the industry-funded Harvard Center for Risk Analysis.