Tuesday, April 6, 2010

Owning ALL the Emissions

The US Department of Transportation and the US Environmental Protection Agency jointly issued new rules for automobile mileage standards. It’s a rule nearly 30 years in the making. (Such is the power of the auto industry even after taking Federal funds to prevent bankruptcies.) The new rules set required mileage rate at 35.5 miles per gallon by 2016, saving the drivers about $3000 in fuel expenses over the car’s life, and reducing emissions by about a billion tons over the lives of all vehicles. They estimate it will cost an extra $1000 per vehicle to do this, but past estimates have generally been pessimistic, and the actual added cost is likely to be lower over time.

But there was an interesting aspect of the rules that didn’t get much coverage in the media. Instead of counting electric cars as zero-emission vehicles, they are going to be counted as lesser-emission vehicles. I’m not certain how the new thresholds were determined, but car manufacturers will be able to count the first 200,000 electric cars they sell as having no emissions, But for anything above that, they need to count the emissions from the utility that made the power to charge the car.

This makes a lot of sense. I mean, there ARE emissions created by charging a car, just as there are when you heat your electric oven or turn on a light. In the carbon footprint world, these are known as “Scope II” emissions, and are almost universally counted when an organization determines its footprint. And the Government is not being stingy. They will allow manufacturers to count each electric vehicle sold as two vehicles so that they get the benefit of the low emissions on their fleet average mileage (which is technically what the standard actually applies to).

The ostensible purpose of this rule was to ensure that car makers wouldn’t use the sales of ‘zero emission electric cars’ to offset sales of the high end, but fuel hungry, behemoths that are more profitable, but would negatively impact the fleet average. This is a worthy goal. But automakers respond – justly I think – that we should in fact encourage sales of electric cars this way.
So this is a complexifying regulation that brings up all sorts of questions. For example, what utility’s emissions values should they use? A national average? Or should auto builders get credit for the geographic distribution of their sales and use local or regional utility emissions values? What about time of day charging? Emissions per KWH at any utility vary by time of day.

In short, this is a really questionable means of accounting for (if not controlling) carbon emissions. But at the same time, I applaud the regulators’ attempts to bring this problem to the fore. Given the absence of serious, nationwide emissions caps, there are few really elegant mechanisms to do so. It’s easy to come up with better approaches to this problem, but not under the existing Clean Air Act. If industry wants a more fair and coherent emissions control regime, then they should stop standing in the way of a national program, and start holding serious conversations with those trying to build one.

Paul Birkeland lives in Seattle, WA, US, and develops Strategic Energy Management Systems for government, commercial, and industrial organizations through Integrated Renewable Energy.

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