Monday, April 5, 2010

Fairness in the EPA, aka The American Way

As reported in Autobloggreen, the EPA has announced it will allow the first 200,000 units of a given manufacturer's EVs sold as zero emission for the purpose of corporate average fuel economy (CAFE). After that milestone is reached, the EPA will start assigning pollution credits based on the pollution from generating the electricity that powers the car. Regardless of how many units sold, after 2016, all EVs will be assessed some level of pollution. The reason this is important is because the carmakers have to hit a CAFE standard of 34 mpg by 2016. If they count the pollution from the generation of the electricity, then more of their gas cars will have to be smaller. A good thing for society, but not necessarily what the dealers want.

This idea has merit, but only if implemented fairly.

How do you compute the amount of pollution generated from coal and natural gas? Do you take the national average for a kilowatt hour of energy? I've read it's just over one pound of CO2 per kWh. Or do you allow for regional variation? California is among the best in terms of per capita efficiency and a low CO2 grid, and we'll be the first state to mass adopt EVs. Oregon and Washington have an even cleaner grid and will match CA in per capita EV ownership. Seems only fair to allow for our cleaner grid in the calculations.

Not knowing how the EPA will come down on this question, I'd like to make an observation and suggestion.

According to the Brussels based Global Wind Energy Council, 37.5 gigawatts of wind energy were installed last year, bringing the total world capacity to 157.9 gW. The U. S. share of that was about 10 gW last year. This is enough to generate approximately 30 billion kWh each year. The average EV will use about 4,000 kWh per year.

That new wind alone is enough to power over 7 million EVs!

The wind and solar industries are going to be installing more gigawatts of capacity each year for the foreseeable future, so I don't see how the auto industry will ever build enough plug-in cars to catch up to the new renewable energy capacity.

And add to this 6.4 gW of solar energy from PV (worldwide). That's another 2.5 million EVs. And it's even more valuable energy since it's generated during peak demand.

Therefore, we can make the argument that the renewable energy being installed each year will far outpace new demand from plug-in cars, probably for decades to come.

Lastly, and this is very important, if the EPA deigns it necessary to count the upstream pollution from generating the electricity, then by all rights it should count the upstream pollution from extracting, shipping, refining, and transporting the oil that competes with electricity. To cap it off, be sure to include the electricity used to pump it into the tank at the gas station. All of this energy use creates vast waste and massive pollution and absolutely should be accounted for.

It's called a level playing field, and it's the American way!


  1. Way to compute, Paul. Thanks for setting your mind to the issue; we need this kind of thinking. It is essential to the future we are all moving towards, to helping us all make sense of the choices ahead. You are as usual on the cutting edge. And perhaps, you know I am a fan, cars should get smaller. Not what the dealers want, and not what even some innovators want. But perhaps: what we need. At least in part.

  2. Sounds like a good argument for owning and installing your own solar-powered, electric-vehicle-charging-station and lobbying for full credit of the offsets you've invested in. That way, owners of EV's who own their own green power source can eschew any taxes levied do to EPA.

    Does this seem reasonable ? Regardless of what we do, we need to pay true costs in the sense that we are not borrowing further from natural capital, but rather, paying it back.

    As for me and mine, we'll see you out there... on our bikes, of course !

  3. Paul thanks for an interesting article/blog.
    I was wondering how I compute into the equation.
    People ask me all the time how much does my electric car cost me. (usually after how many miles do I get per gallon.) LOL
    Since I installed 6 panels more to my system to cover any pull for the car I feel I have a neg carbon footprint transpo wise. I am sure I give more than I need. So I am probably helping power my neighbors usage indirectly. And I am happy to do it. Some day I might need the extra power.
    Do you think I am correct? Have you talked to any other MINI E drivers to know what a full charge needs and how much it costs for the non solar person and how much solar power it does need?
    Honestly I just wanted to drive on sunshine. Not do the math. : ))
    thanks for helping me get my solar start. Your advice was priceless.

  4. Sharon, (SS Holley) of course you're right. One of the best aspects of driving on electricity is that you have the CHOICE to drive on 100% renewable energy, as you have chosen to do. This point needs to be driven home repeatedly whenever the opportunity arises. I encourage everyone to let your voice be heard by the EPA about this issue. Level the playing field by accounting for the upstream pollution for ALL energy. Our side is more than willing to play that game.

  5. Yes, Paul, at the very least they should do the same calculation for the production and delivery of the gasoline to gas cars.
    The government has already developed these calculations, they are available in a software package downloadable for free from the Argonne National Laboratory at
    It shows EVs clearly lead all other cars in Well-to-Wheels generation of pollution & CO2, even if you don't factor in all the new renewable sources!
    So... BRING IT ON!

  6. And while we're at it; we should tack-on the societal costs to every gallon of gasoline (and DIEsel). Heart disease, lung disease including asthma; and the cost of policing the world to keep oil safe as it journeys from the ground to our shores.
    This would be a truly fair incentive for EVs and other alternative fuels and trans. vehicles.

  7. Mike B from the cold clean North of Canada, says wait a minute, this isn't right. To have a level playing field this same kind of "accounting" should be added to the gazoline burning, fossil fueled, cars also!

  8. If the past is any indicator, the "American Way" includes a playing field tilted about 45 degrees in favor of multinational corporations.
    All we have are truth, logic, and reason:^O

  9. Why is it that the calculation of the upstream "cost" of oil in terms of pollution rarely sees the light of day. Further there is the downstream cost of all the service and repairs necessary to keep an ICE running. That too needs to be properly accounted for; i.e. the manufacturing, distribution, installation, and disposal of oil filters, air filters, fuel filters, spark plugs and wires, gaskets, engine coolant, radiators, exhaust system parts, emissions sensors and valves, fan belts, timing belts.... each of these, over it's short but dirty life, has an energy use/emissions foot print! But then our whole economy is based on faulty math, why should the oil and auto industries be any different. I'll save that for a different rant.

  10. Where does it end?

    Oil comes from oil rich lands.
    To get it to us:

    A supertanker puts out lots of C02
    A super tanker burns a gallon of fuel every 44 feet.
    Making that fuel took incredible amounts of electricity.
    That electricity is made in oil rich lands so it is made by burning fuel
    Burning that fuel puts out a lot of C02
    Making that fuel took incredible amounts of electricity.
    The fuel was burned to make that electricity was made using lots of electricity
    and so on...
    The fuel coming from oil rich lands is more than double dirty. Since the cheap unregulated resource is locally available oil it is used for energy generation for every phase of the operation.
    It is deca-dirty!

  11. THe DOE did this when considering tax credits for hybrids in June 2000: Federal Register /Vol. 65, No. 113 /Monday, June 12, 2000 /Rules and Regulations 36987

    However, they only considered "well-to-wheels" efficiency, which assumes fossil fuels, rather than a "sun-to-wheels" efficiency (after all, where did the energy in oil/coal/natural gas come from?). We should not care what the vehicle efficiency is as long as it comes from vastly abundant solar energy (if you don't like small cars--run what you are driving from renewable sources).

    Even so, here are the numbers to quantify this discussion:

    2. Gasoline-Equivalent Energy Content
    of Electricity Factor
    When comparing gasoline vehicles
    with electric vehicles, it is essential to
    consider the efficiency of the respective
    ‘‘upstream’’ processes in the two fuel
    cycles. A full description of the
    differences in the processes is beyond
    the scope of this rulemaking, but the
    critical difference is that a gasoline
    vehicle burns its fuel on-board the
    vehicle, and an electric vehicle burns its
    fuel (the majority of electricity in the
    U.S. is generated at fossil fuel burning
    powerplants) off-board the vehicle. In
    both cases, the burning of fuels to
    produce work is the least efficient step
    of the respective energy cycles.
    Therefore, the PEF includes a term for
    expressing the relative energy efficiency
    of the full energy cycles of gasoline and
    electricity. This term, the gasolineequivalent
    energy content of electricity
    factor, abbreviated as Eg, is defined as:
    Eg = gasoline-equivalent energy content
    of electricity = (Tg * Tt * C) Tp
    Tg = U.S. average fossil-fuel electricity
    generation efficiency = 0.328
    Tt = U.S. average electricity
    transmission efficiency = 0.924
    Tp = Petroleum refining and distribution
    efficiency = 0.830
    C = Watt-hours of energy per gallon of
    gasoline conversion factor = 33,705
    Eg = (0.328 * 0.924 * 33705)/0.830 =
    12,307 Wh/gal
    The derivation of these values is
    straightforward but lengthy and is
    therefore not discussed in this notice.
    Details on the assumptions,
    calculations, and data sources used to
    derive these values are described in
    materials contained in Docket No. EE–
    RM–99–PEF, which may be reviewed at
    the DOE Freedom of Information
    Reading Room, at the address and times
    stated above.
    3. ‘‘Fuel Content’’ Factor
    The fuel content factor has a value of
    1/0.15 and is included in the PEF for the
    reasons described in the notice of
    proposed rulemaking and the responses
    to comments section of this notice.
    Briefly, these reasons are:
    (i) Consistency with existing
    regulatory and statutory procedures;
    (ii) Provision of similar treatment to
    manufacturers of all types of alternative
    fuel vehicles; and
    (iii) Simplicity and ease of use.
    The fuel content factor value of 1/0.15
    is equivalent to a multiple of 6.67.


  12. Yes we need to level the playing field, including giving EQUAL rebates and tax credits for gas-to-electric zero-emission vehicle conversions. The amount of energy saved by reusing a used car should also be factored into the equation leading to greater energy savings and reduction of pollution.

  13. Are they still planning on using the 230 MPG for the Chevy volt? That is already a totally bogus number designed to support the EV industry. Are you suggesting they need an additional break?

  14. Great post -- and great responses. I agree that ICEs should also get an upstream tax if EVs do (which I think they should), with some possibility for those of us living in cleaner grid states and/or powering our EVs by home-generated renewable energy getting compensation on any tax(es).

    On a lighter not, perhaps they should also calculate MPG pollution for:
    - jacuzzis
    - air conditoners
    - dryers
    - refrigerators, etc.

    I'm betting that in many cases, EV drivers will be using far less electricity annually than homeowners with a giant jacuzzi, huge central air conditioning, and so on...

  15. Great discussion. Here's another viewpoint on the issue, built around the idea that EVs are generally changed with off-peak power.

  16. After lots of feedback, the Volt sticker is likely to be replaced by something showing
    the gas miles per gallon and also the electric miles/KWH. This removes the upstream generation and fossil fuel mining/refining/distribution from the equation. Even so,
    the Volt is almost certain to get 4-5 mi/KWH on the highway, and at 33.7 KWH/gal (see
    preceeding comment) that is 134-167 mpg in terms of pure energy.

    It is a good bet that your friendly neighborhood electric utility can turn any fossil
    fuel into electricity far more efficiently than a mobile internal combustion engine.
    In the case of natural gas, the electrication coalition
    reports that it would be 2X better for natural gas (Honda already sells natural
    gas cars). It's a good bet they could even do better with gasoline/oil, even counting
    distribution losses (again see above comment).

    Electric companies are all over EV charging--off peak charging means more profits AND
    cheaper rates due to better fixed cost utilization. On peak charging means they get to buy
    more peak generators that they use 5 days a month--lower profits and higher costs.
    But nightly charging is off-peak, and
    in California you already get a better rate for nighttime EV charging.

    I have been driving electric pickups/cars for 9 years now, and I found that they are only
    3% of my electric bill. Your mileage may vary, but we don't have much air conditioning up
    here in Oregon west of the Cascades.


  17. Paul, I know this doesn't make your calculation any simpler, but the correct way to make the pollution assessment is to look at the marginal generation that will be added to balance the new marginal load (i.e. EVs).

    In the short term, there aren't enough EVs to affect our generation needs, so today's power mix isn't relevant. By the time EVs do constitute a significant load, we will need new generation to match it, and the choices we make regarding new generation are all that will matter.

  18. Wow, lots of comments on this post. I've noticed a trend of regulators wanting to compensate for environmentally friendly products and services while not holding the status quo industries to the same standard. For example, CARB holding plug-in hybrid conversions to an extremely high standard, and the over-zealous push to calculate the "indirect land use" impacts from corn based ethanol. As much as I support non-food waste biomass replacing corn as a feedstock for ethanol production, how about some calculations for the indirect land use impacts of oil drilling, or the tar sands in Canada, etc.? We need a movement to level the playing field!

    I'm all for additional ways to get more efficient vehicles from automakers, but not at the EXPENSE of reducing the incentive for them to build EVs. This seems so stupid, cars only have tailpipe emissions counted, but my EV that gets all its energy from solar panels will have pollution from coal plants outside of my State arbitrarily added on. This is B.S. corporatism at its worst.

  19. Paul, you are right -- now you need to convince the amight ARB that they are wrong!

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