UCS Blog - Clean Vehicles (text only)

California’s Opportunity to Show Leadership with Clean Cars

Today the California Air Resources Board will evaluate a midterm review of its Advanced Clean Car Program (ACC) and decide how it will move forward with standards designed to reduce global warming pollution and air quality pollutants from new vehicles.

The clean-car standards, adopted in 2012, were developed to reduce smog-causing pollutants, particulate matter, and global warming emissions in passenger cars and other vehicles through 2025. One key part of the standards, the zero-emission vehicle (ZEV) regulation, requires auto manufacturers to make an increasing number of plug-in hybrid, battery electric and fuel-cell electric vehicles available to car buyers.

California’s Advanced Clean Car (ACC) standards are working

These clean-car policies are the single biggest measure taken to reduce the state’s global warming emissions and petroleum consumption while meeting our climate goals. Among their achievements so far:

    • Since 2011, the Union of Concerned Scientists estimates the standards have avoided an estimated 13 million metric tons of carbon emissions, 1.2 billion gallons of gasoline, and $4 billion in gasoline costs.
    • More than 260,000 electric vehicles have been sold in California since 2010 and the number of models available to consumers continues to grow.
    • Electric vehicles on California’s roads today are avoiding the burning of 82 million gallons of gasoline each year and have annual fuel savings of $111 million (at 2016 gasoline and electricity prices).
    • Electric vehicles are reducing the state’s global warming emissions by 660,000 metric tons a year. An EV charged on California’s increasingly clean electricity grid has global warming emissions equivalent to a gasoline vehicle with an 87-mile-per-gallon efficiency.

Cumulative ZEV sales in California now exceed a quarter million vehicles.

In-depth review shows vehicle standards are working

The Air Resources Board (ARB) has produced a comprehensive review of the ACC program and the findings are clear: The ACC standards are effective, science-based regulations that are producing economic and public health benefits for Californians. And with technology advancing faster than expected, the current standards can be achieved with even lower costs than anticipated.

Some automakers have argued that the ZEV standards should be weakened, both in California and the other nine states that have adopted California’s ZEV standard. However, the data in ARB’s Midterm Review report fails to support any need to weaken the standard.

  • Rapid progress on EVs over the past 7 years means that automakers can now meet the standards with fewer vehicles: 1.2 million electric vehicles and about 8% of new car sales by 2025, compared to original estimates for 1.5 million and 15% of new car sales.
  • Automakers that are leaders in ZEV technology are already well ahead of targets. For example, General Motors exceeded 5% plug-in vehicle sales in California in 2015.
  • The statewide average for EV sales last year rose to 3.5%, despite some automakers like Honda that were almost completely absent from the ZEV market.
  • ZEV sales in California accelerated in 2016, rising more than 18% compared to the previous year.

Automakers have also requested looser standards in the nine states that have adopted California’s ZEV rules (sometimes termed ‘section 177 states’ after the enabling section of the Clean Air Act). However, this request is not supported by the evidence.  Instead we find:

    • The rate of EV sales in these states is lower than California. However, the current rule allows manufacturers to satisfy their requirements with little to no EV sales in these other ZEV states.
    • Some automakers have responded by not offering cars in these states, especially on the East Coast. For example, the Fiat 500e EV is only offered in California and Oregon, despite annual sales of over 5,000 in California the last three years.
    • A comprehensive study of the plug-in EV market conducted by UCS shows stark differences in the availability of EVs between California and the other ZEV states. For example, between January and June of 2016, Boston had 90 percent fewer EV listings at car dealerships than Oakland, when adjusted for relative car ownership.
    • In order for EV sales to increase outside of California, ARB should allow the 2018-2025 ZEV standards to go into effect because those rules will require ZEV sales in the other nine states. Together with California, those states comprise more than a quarter of all car sales nationally.

Many more plug-in electric vehicles are listed for sale at dealers in California than other clean car states.

Technical experts say stronger standards should be developed for beyond 2025

 To meet California’s goals for air quality improvements and global warming emissions reductions, the state’s transportation systems will need to continue to become cleaner. ARB can help ensure we stay on track by beginning to develop ACC standards for after 2025. The ACC program has been successful in ensuring that the first generation of ZEVs were deployed, and harmful emissions reduced from the entire light-duty fleet. The ARB should continue these standards as recommended through 2025 and start the hard work needed to design a strong ACC program for the post-2025 period.

 

Fact-checking the Trump Administration’s Claims about EPA’s Vehicle Standards

It’s been one week since the administration caved to auto industry lobbyists and reopened the mid-term review of the EPA’s successful vehicle efficiency standards.  In that time, there’s been a lot of hot air around what this means for the industry, so I thought I’d look into the factual basis for some of the more common assertions made around the announcement.

Scott Pruitt, Administrator of the EPA, called this action “good news for consumers”

FALSE.  To date, the vehicle efficiency standards have saved Americans more than $37 billion at the gas pump.  If the administration follows through with rolling back the standards under the mid-term review, the average new car buyer stands to lose about $1600.  Limiting consumer choice to less efficient vehicles is never good news, not for consumers or the country as a whole.

Donald Trump, President of the United States, vowed to “eliminate the industry-killing regulations”

FALSE.  There’s nothing “industry-killing” about these standards.  The auto industry has had back-to-back record-setting sales years, while at the same time exceeding the level of improvement required under EPA’s standards.  More than 300,000 automotive manufacturing jobs have been created since 2009, jobs like those General Motors highlighted last Wednesday building their new 10-speed transmission, a technology developed to meet the very same standards the administration is working now to undo.  Perhaps the President listened a bit too long to the erroneous jobs claims pitched by Mark Fields (Ford), but even a conservative analysis paid for by the auto industry shows that these regulations are good for jobs, netting about 300,000 new jobs for the economy if we move forward with the regulations as-is.

Scott Pruitt, Administrator of the EPA claimed that “CAFE standards should not be costly for automakers or American people.”

TRUE.  And they aren’t, as a rather lengthy and rigorous review already determined.  These standards are poised to save consumers money, increase jobs, and reduce oil usage without posing undue burden on industry.  Automakers may be trying to supplant facts with politics, but it is the American people who stand to lose the most with last week’s action.

Donald Trump, President of the United States, said he didn’t want “an extra thimbleful of fuel” to stop manufacturers making great cars.

Maybe this is the thimble President Trump was talking about? Of course, you could still fill at least a dozen of these with the fuel savings for even just one vehicle thanks to these regulations.  “Uniform Measure/Stack”(1997) by Stephen Cruise, in Toronto’s garment district Photo: Michael Dolan/CC BY 2.0

TWO REALLY BIG THUMBS DOWN.  Firstly, the regulations the administration is threatening to rollback are set to increase the fuel economy of new vehicles from an average of about 25 miles per gallon today to about 36 or 37 miles per gallon—that means well over 2000 fewer gallons of gas over a typical vehicle lifetime, hardly a thimbleful.  Secondly, these rules have been pushing manufacturers to innovate, leading to a greater use of lightweight materials like aluminum, transmissions with a greater spread in gear ratios, smaller turbocharged engines, stop-start systems, and many other fuel-saving technologies which can be found throughout Motor Trend’s various Car/Truck/SUV-of-the-Year winners and other such “great” vehicles.  [Also great but being driven by state policy goals—electric vehicles, which have captured three of the last seven Car-of-the-Year titles.]

Rebecca Lindland, analyst from Kelley Blue Book:  “Consumers want the most fuel efficient version of a vehicle they already want to buy.”

TRUE.  Thankfully, that’s exactly what these rules are designed to protect, that consumers can have more efficient vehicle choices in all types of vehicles year over year.

Philly Murtha, J.D. Power:  “With current lower gasoline prices and increased consumer demand for SUVs and pickup trucks, automakers are in a difficult position.”

FALSE.  Selling more SUVs and trucks actually LOWERS the fuel economy target a manufacturer needs to hit—if anything, that means selling more trucks and SUVs makes it easier for a manufacturer to meet these rules.  Ford’s most efficient F-150, which represents about 1 in 5 sold, well exceeds today’s standards—in fact, it could meet standards out to 2021-2024, depending on the specific configuration.  That means that Ford could sell nothing but that F-150 and still meet the standards for the next 5 years with no additional improvements.

Brent Snavely (Detroit Free Press) and Chris Woodyard (USA Today):  “If the review eventually results in the standards being lowered, automakers potentially wouldn’t have to make as many cars with advanced carbon emission-cutting technology like hybrids, electrics and hydrogen fuel cells in order to hit the minimums.”

PARTIALLY TRUE.  On the one hand, lower targets will certainly mean less deployment of all fuel-efficiency technologies, so that is accurate and terrible news for all. On the other hand, as we’ve noted repeatedly, these standards do not require the deployment of electric vehicles or much in the way of hybridization, so that non sequitur is a completely incorrect mischaracterization of the standards.  For example, automakers’ own data shows that they can meet the standards with improvements to conventional vehicles.

Donald Trump, President of the United States:  “I brought American auto companies to the White House.  Mary Barra is here.  Mark Fields is here.  Sergio is here, and others.  And none of them ever got to see the Oval Office before, because nobody took them into the Oval Office—our Presidents.”

¯\_(ツ)_/¯.  While it may be technically correct that neither Mary Barra nor Mark Fields have, in their short tenures as CEO, met with a sitting president at the White House, auto companies have not had any difficulty getting an audience with the past few presidents.  In fact, Sergio Marchionne probably knows this best of all, having been in extensive meetings with the Obama White House ever since his tenure as CEO began, first with the Chrysler-Fiat merger and bailout and then pursuant to the fuel economy standards to which he signed on.  Also:

(L) President Bush meets with CEOs of the Detroit Three.(R) President Obama meets with 10 automaker CEOs supportive of the fuel economy and global warming emissions standards for passenger vehicles (including Sergio Marchionne, just to his right). Photos: White House Archives/ CC BY 3.0

Bette Grande, Research Fellow at the Heartland Institute:  “The review and subsequent pullback from EPA’s CAFE standards…is a win for oil producers and mineral owners, because when consumers are free to choose the vehicles of their choice, domestic oil demand will increase.”

TRUE.  Bette is right—oil demand will increase, increasing emissions, decreasing national security, and raising prices for everyone.  Yay?

Are Electric Buses Feasible?

One of the largest transit agencies says yes

King County Metro (Seattle area) recently released a report analyzing the feasibility of transitioning its 1,400 buses to zero-emission vehicles. Metro found it can achieve a 100% battery electric bus fleet as soon as 2034 with minimal increases in expenses.

This is a MAJOR announcement from the 2nd largest bus fleet on the west coast and the 9th largest in the United States. It indicates the confidence Metro’s fleet managers have to deploy zero-emission vehicles on a large scale.

Metro’s fleet today consists mostly of diesel (34%) and diesel hybrid (53%) buses. Electric trolley buses powered by overhead wires make up the rest of the fleet (12%).

Transitioning to battery electric buses will reduce Metro’s climate impacts by 80% over the next 30 years compared to its current fleet. The report concluded this level of ambition is needed to meet the county’s goals for reducing global warming emissions and improving public health.

Electric bus technology is here and ready

Metro found that the range and charging times of today’s battery electric buses can meet the needs of 70% of its routes. Anticipated advances in technology will allow the remainder of Metro’s routes to be serviced by electric buses.

Between now and 2020, Metro will incorporate 120 electric buses into its fleet, making it a national leader in zero-emission transit. Based on technology readiness, the report recommends that all new bus purchases be zero-emission thereafter.

Metro recognizes the challenges in adopting a new technology, but it isn’t backing down. It engaged with power utilities, for example, to discover it’s possible to get the amount of power a large battery electric bus fleet would require.

Metro’s human resources department is also exploring how it can have a workforce with the right skill-set to meet the needs of an all-electric bus fleet. Improving the accessibility of jobs in the electric truck and bus industry was a major recommendation of a report we wrote with The Greenlining Institute.

But won’t this break the bank???

Nope. Metro reports the purchase price of a standard 40-foot battery electric bus is cost-competitive today if not cheaper than its current diesel hybrids. Including purchase, maintenance, and operation costs, Metro estimates a 6% increase in expenses to transition their entire fleet to zero-emission vehicles, with a range of -27% to +10%.

Including the monetary benefits of improved air and quieter neighborhoods, the overall costs of a fully zero-emission fleet are reduced to just 2%. These costs are real but often ignored on balanced sheets.

You might think the costs only work out because Washington enjoys cheap electricity, but the analysis was based on an electricity price of $0.15/kWh. This is much higher than the rate Metro pays today and was chosen in anticipation of future electricity rate structures.

Benefiting those most impacted by air pollution

Metro is prioritizing the roll out of zero-emission buses in communities that bear the greatest pollution burden – low-income and communities of color. A major part of the report centered on identifying bus routes that operate in the most polluted communities.

Metro concluded that taking cars off the road through public transit shouldn’t count in meeting its climate goals. Nor should it be able to buy its way to carbon neutrality with carbon offsets. Its principles for equity and reducing local air pollution rightfully played a large role in these recommendations.

A clean fleet powered by clean energy

Not only does Metro recommend a 100% zero-emission fleet, it also recommends these buses be powered by 100% renewable energy (including hydropower). Washington’s large hydroelectric resource gives Metro a big head start on this. In 2005, Seattle City Light, which would power 75% of Metro’s all-electric fleet, became the first carbon-neutral electric utility in the country.

But Washington isn’t unique in the carbon benefits of electric buses. We found that battery electric buses on today’s grid in California have 70% lower global warming emissions than natural gas or diesel buses.

Fuel cell buses with 33% hydrogen from renewable energy (per California law, SB 1505), have 50% lower global warming emissions than natural gas and diesel buses. And across the country, the grid is getting cleaner.

More than just clean buses

Metro has a lot of other great things going on. King County was one of the few transit agencies in the United States to see an increase in ridership last year. And it plans on increasing ridership even more, requiring its fleet to increase from 1,400 to 2,000 buses by 2040. Metro is proof that expanded service and clean buses can go hand in hand.

Metro also helps get people onto buses with discounted transit rates for low-income individuals. And it gets people out of their cars and into clean, shared rides with an electric vehicle carpool program.

I went to college in the Puget Sound region and have many friends and family in the area. It is very inspiring to see a place I love be a leader on clean vehicles and clean air.

If King County Metro’s work inspires you, contact board members on your local transit agency. Let them know zero-emission buses are ready to make your community a better place to live.

P.S. If you live in Los Angeles, tell LA Metro, the largest transit agency on the west coast, to also be a leader on zero-emission buses.

President Trump Has a Wrecking Ball (and it’s Aimed at the Climate)

The wrecking ball that is the Trump presidency is taking aim at the foundation of our country’s response to climate change. Today, the Trump Administration is announcing a re-opening of the fuel efficiency/emissions standards for cars, which can only mean one thing—weakening or repealing them. And it is expected that he will soon issue a directive to EPA to repeal the Clean Power Plan, and may also order EPA to rescind a waiver that it granted to California to set its own vehicle standards.

If the Trump administration succeeds in rolling back all three, the effect will be to increase by billions of tons the emission of global warming gases and other pollutants that endanger our health; burden our children with much higher costs of fighting climate change; cede the United States’ clean energy prominence to other countries, and make it much harder to meet the goals we set for ourselves as part of the 2015 international Paris Agreement on Climate.

We must fight this reprehensible rollback with everything we’ve got.

Global warming pollution and fuel economy standards

In 2012, the Obama Administration issued standards to cut global warming emissions and improve fuel economy for passenger cars. These standards are expected to increase the number of miles per gallon (mpg) for passenger vehicles from about 26 mpg on average today to approximately 36 mpg by 2025. (The figures are based on “real world” driving conditions, and differ from the EPA estimate of achieving approximately 54 mpg).

The first phase of these standards are in effect now, and are working. The second phase of these standards (from 2022-2025) are projected to save consumers approximately $1,500 per car (net savings), reduce oil use by over a billion barrels, and cut carbon pollution by over 500 million metric tons.

The automobile manufacturers were key architects of these standards. But now some are trying to back out of their commitment, even though they are experiencing record sales and new technologies are coming on line that will help them meet these standards more quickly and inexpensively.

Doing the bidding of these car makers, Trump has directed EPA to “reopen” the standards that govern cars built in 2021-2025. While we can’t know for sure what the outcome of this re-opening will be, we have to prepare for the worst—that the intent is to severely weaken or even repeal the standards.

Note that this cannot be achieved with the stroke of a pen. In order for EPA to do this, it must provide notice, issue a draft regulation repealing the plan, take public comment on it, and issue a final regulation. That final regulation would likely be challenged in court, and the Trump administration will have to demonstrate that there is compelling new information that justified changing course. During the rulemaking process that will follow, we must make clear to the Trump administration that these standards are working, and that Americans want lower-polluting and more fuel efficient cars. And we must loudly register our displeasure with those automakers which received massive taxpayer assistance during the last recession, agreed to build more efficient cars in return, and are now reneging on their promise.

California waiver

When the Clean Air Act was passed in the 1970s, it gave the federal government exclusive authority to regulate tailpipe emissions from cars, but it included one exception: California retained the authority to issue its own, stricter standards, provided it received a “waiver” from the EPA. Since that time, California has received approximately 50 waivers from the EPA, which have helped the state dramatically improve air quality for its residents.

As part of the 2012 agreement on joint global warming pollution and fuel economy standards, the Obama Administration worked with California to set national standards sufficient to meet the state’s greenhouse gas emission reduction needs. This avoided separate state and federal standards for reducing global warming pollution from vehicles– a goal of the auto industry.

However, California also set its own standards for deploying electric vehicles and tailpipe emission standards for gasoline and diesel to combat CA’s poor air quality – something it has done several times to protect the health of its citizens. California was granted a waiver to implement all of these standards in January 2013

Reports indicate that Trump may soon direct the EPA to rescind this waiver. The reason for this is simple: it won’t satisfy car makers to relax the EPA’s fuel economy standards while still leaving California’s standards in place.

Over the past 50 years, no EPA Administrator has ever rescinded a waiver granted to California, and there is no provision in the Clean Air Act that allows it. This radical move is not only destructive, it is hypocritical. EPA Administrator Pruitt has called himself a protector of state’s rights and pledged to give states greater latitude to address their own needs. Yet now, in one of his first moves as administrator, he is working to take away California’s right to set its own standards.

Here again, a public process is required. Rescinding this waiver directly affects not only California, but also twelve other states (NY, PA, MA, ME, NJ, CT, DE, OR, WA, VT and DC) that have adopted California’s standards (which they are allowed to do once a waiver is granted). Many of these states are counting on these standards as a means to meet climate change goals and air quality targets required by their own state laws. California and these other states can be expected to challenge the waiver rescission in court, and will have a strong argument that it is arbitrary to rescind a waiver that was granted five years ago, merely because the federal government has decided to weaken its own standards.

Clean Power Plan

In 2015, EPA issued the first-ever limits on carbon dioxide emissions from power plants—which are among the largest sources of this heat trapping gas. The plan would cut CO2 emissions by approximately 32 percent off 2005 levels by 2030 by relying on proven and effective tools, such as renewable energy, energy efficiency, switching from coal to gas, and market-based emission trading. The Clean Power Plan will ensure that all states and utilities advance together towards a cleaner energy sector. It is particularly important to have this rule in place in 2021, when tax incentives for wind and solar energy expire.

Trump’s anticipated presidential directive is likely to call on EPA to repeal this regulation. As is the case with the vehicle standards, the repeal will have to go through a formal rulemaking process. The repeal may seem like a foregone conclusion, because candidate Trump pledged to do away with the plan and Scott Pruitt, the new EPA Administrator, previously sued EPA to block it.

But participating in the public process is extremely important nonetheless. Among other things, we should demand that, if Trump abolishes the Clean Power Plan, he replace it with an alternative that achieves the same level of emission reduction. If he does not, the next step will be the courtroom. It cannot be emphasized strongly enough that EPA has a mandatory duty to address carbon pollution under the Clean Air Act, so killing Obama’s plan without a viable replacement is not only irresponsible, it is illegal.

The stakes are high

Over the past eight years, the United States has become a clean energy leader. We’ve accomplished a massive expansion of wind energy in the great plains, solar in the southwest and southeast, breakthrough battery technologies making electric cars better (and soon less expensive) than their gasoline-fired counterparts, switched to LED lightbulbs, and implemented a wide array of building materials and techniques to cut energy use. With these powerful changes, our country has risen to the challenges posed by climate change while creating millions of jobs in the process.

Some of this progress will continue no matter what the Trump administration does. But Trump’s anticipated three-way rollback will slow this progress down, probably significantly.

To get a glimpse of how high the stakes are, the graph below depicts estimated energy sector CO2 emissions. We focus on the year 2030, when both the Clean Power Plan and the fuel economy standards would be in full effect.

The graph shows that repealing the Clean Power Plan and the fuel economy standards (nationwide and for California) will increase energy-related emissions in 2030 by 439 million metric tons, or approximately 9%.

Cumulative through 2030, the repeal will increase emissions by 2.5 billion metric tons. The graph also shows that without these two policies, energy related emissions will actually increase overall from current levels. Yet under the Paris Agreement that we signed in 2015, we pledged to decrease emissions on an ongoing basis, based on the overwhelming scientific consensus that we are running out of time to cut emissions of greenhouse gases. By taking off the table these emission reductions, the Trump administration makes meeting these goals much more difficult, and transfers to the next generation the burden of billions of tons of carbon-cutting from one generation to the next.

It is a travesty that the Trump administration seeks to undo the progress we’ve made, but it is not surprising. Candidate Trump called global warming a “hoax.” He picked Scott Pruitt to head EPA due to Pruitt’s legal expertise in obstructing EPA with litigation, and Mr. Pruitt has now gone on record saying that he does not believe carbon dioxide emissions are a primary cause of climate change. And he seems to think that virtually all government regulations are detrimental, blind to the positive economic and environmental changes they can achieve.

Any false hope that President Trump might moderate some of his more radical rhetoric once in office must now be laid aside. We can see the wrecking ball and the direction it is swinging. And we must stop it before it is too late.

Photo: Rhys A/CC BY (Flickr)

EPA Pulls Back Sound Policy Judgment at Behest of Auto Industry

Today, EPA Administrator Scott Pruitt rescinded the determination that the EPA standards for 2022-2025 are appropriate.  This decision was made at the request of automakers seeking to supplant more than four years of robust, technical analysis with a political request from industry–a spokesperson for the administration even noted on a press call regarding the announcement that automaker complaints had been taken at face value with no additional analysis or verification, despite the tremendous body of evidence EPA has already put forth supporting the determination.  This decision could have major implications not just for our climate, but for consumers, thanks to an administration willing to bend over backwards for industry.

What does this mean?

This step backwards is the first necessary for the administration to weaken the fuel economy and global warming emissions standards set for 2022-2025 way back in 2012.  These standards were reaffirmed by the previous EPA Administrator Gina McCarthy in January based on the breadth of data, which showed that manufacturers could continue to meet the standards on the books and that moving forward with the standards on the books would provide tremendous benefits to the American public.  While a stroke of a pen may be able to undo this determination, it cannot undo the significant body of evidence underpinning this well-justified determination.

It’s industry’s word versus a mountain of independent, peer-reviewed data

As I wrote in January, the determination that EPA’s 2022-2025 standards were appropriate was based upon a mountain of evidence.  The agency spent tens of millions of dollars on research and analysis, including vehicle testing and simulation that resulted in at least 20 peer-reviewed publications; studies on consumer acceptance of technology and willingness to pay for it which contradicts automaker assertions that the public doesn’t want fuel-efficient vehicles; and updated assessments of technology costs by an outside consultant that looked at how a given technology would impact the parts and engineering costs of other parts of the car, including some of the innovative technologies that weren’t originally anticipated back in 2012.

In addition to this massive amount of work accounted for by EPA, the Department of Transportation (DOT) added its own heap of analysis, including independent assessments of the costs to achieve the standards and the ability for future combustion engine and vehicle technologies to meet the 2025 standards as well as a DOT-funded comprehensive assessment by the National Academies of Science, Engineering, and Medicine.  DOT’s findings were published jointly with EPA in the Draft Technical Assessment Report last summer and said quite clearly that manufacturers could meet the finalized 2025 standards through the deployment of conventional technologies and at a lower cost than originally anticipated.

A further part of the process, of course, came from publicly submitted analyses.  Groups like the International Council on Clean Transportation, the Environmental Defense Fund, and of course the Union of Concerned Scientists augmented the agencies’ research with independent analysis which generally showed that the agencies’ own estimates of technology improvements were consistently conservative.  In fact, automakers could exceed standards set out to 2025 through the deployment of improved conventional gasoline-powered vehicles.  Additional independent research showed how fuel economy standards disproportionately benefit lower income individuals, who tend to purchase cars on the secondary market and for whom fuel costs are a much larger share of income, underscoring the critical importance of these standards in protecting these families from fuel price volatility while saving them up to 2 percent of their annual income since fuel economy standards first went into effect.  Consumer groups as well have pointed to the positive impacts these standards have on all Americans, with thousands of dollars in net savings over the lifetimes of these vehicles that begin the moment the typical new car buyer drives off the lot putting much needed income back in the hands of consumers.

Industry continues to cry ‘wolf’

Standing in opposition to this large body of evidence is the voice of industry, claiming absurd assertions about jobs and cherry-picking data because even studies they paid for don’t support their ridiculous claims.  A recent automaker-funded study even noted that in spite of their own conservative assumptions, these rules are, in fact, job creators.  Of course, this industry fighting progress is nothing new—automakers have tried stunts like this previously. Automakers have claimed amongst other things that reducing tailpipe pollution under the Clean Air Act “could prevent continued production of automobiles” and “do irreparable damage to the American economy;” they have also fought safety features like seat belts and air bags for decades while waging what the Supreme Court called “the regulatory equivalent of war” claiming among other things that such features would lead to decreases in sales.

[Spoiler alert: None of that happened, and now you can breathe a lot easier and have a much safer automobile because regulators didn’t kowtow to industry demands.]

On top of this, they are also claiming that the EPA “rushed to judgment” in its determination, forgetting apparently the four-plus years of analysis and the numerous detailed, daylong technical meetings held by the EPA both with individual automakers and their trade associations, in addition to pages upon pages of industry-submitted analysis which the EPA carefully considered and to which the agency responded to before finalizing its determination.  Contrary to their claims, the automakers aren’t upset about the process—they’re upset about the outcome.  And now they’re looking to bend the ear of an Administration generally opposed to regulation to, once again, fight regulations that result in tremendous public good.

By itself this signature does little, but it portends bad intentions

Rescinding the final determination at the request of the auto industry flies in the face of good, technically sound policymaking; however, it is not in and of itself a binding change in policy.  At least for now, the 2022-2025 standards limiting global warming emissions from passenger vehicles remain on the books.  Unfortunately, this action signals a strong likelihood that this administration will not follow the evidence but will simply cave to industry demands—after all, it took less than a month for Scott Pruitt to overrule a decision built on four-plus years of data just because the auto industry asked.

Any change in these regulations will require a formal rulemaking process—and we at UCS will fight like hell to make sure any such rule continues to build upon the strong, technical foundation that led to the regulations on the books today.

The Consequences of Connecticut’s Tesla Ban

At Tesla’s facility in Greenwich, Connecticut, you can take a look at Tesla cars. You can talk to representatives about electric vehicle technology, and learn how to install charging equipment. You can buy swag featuring the Tesla logo.

But you cannot buy a car. You cannot test drive a car. You cannot talk to a Tesla representative about pricing or financing. You cannot have your car serviced.

This is not a Tesla store.

Tesla’s Greenwich facility, you see, is an “educational gallery,” and not a store. It has to be an educational gallery, because Tesla is legally prohibited from operating a Tesla store in Connecticut. This is due to Connecticut’s dealer franchise laws that require all cars to be sold by independently licensed dealers rather than manufacturers.

If you are a Connecticut resident and you want to buy a Tesla, the first step is to go online. Through Tesla’s web site you can order a car and put down a deposit. The car is then delivered to the nearest store; for most Connecticut consumers, that means a store in White Plains or Westchester County, New York. Customers must then travel to New York where a sales representative can complete the sale.

As this is officially a New York transaction, sales of Teslas to Connecticut residents thus create New York jobs, require payment of New York sales tax, and contribute to the New York economy.

Connecticut’s dealer franchise laws are a major impediment, not only to Tesla, but to other companies that are looking to sell electric vehicles independent of the traditional dealership model, including Elio and BYD. In this post, I want to look at the arguments raised for and against these dealer franchise laws. In particular:

  • What is the justification for laws banning Tesla stores?
  • Do dealer franchise laws benefit consumers?

Spoiler alert: the arguments raised in support of banning direct manufacturer sales are poor.

What is the justification for laws banning Tesla stores?

As I discussed in my last blog post, the ban on Tesla sales is an unintended consequence of laws originally designed to protect auto dealers from unfair competition with automobile manufacturers.

Perhaps recognizing that the protection of car dealerships is not the strongest foundation to build broad public support for your policy, in recent years auto dealers have reinterpreted dealer franchise laws—laws that were explicitly passed to protect dealers—as intended to protect consumers.

The National Automobile Dealers Association for example, defends dealer franchise laws by citing a long list of ways in which consumers benefit from the dealer franchise system. Independent auto dealers create more cutthroat price competition than you’d have in a system dominated by manufacturers. Independent auto dealers are more likely to stick around and be able to service vehicle models even if the manufacturer closes down.

This reading of the law makes little sense.

By its very nature, the prohibition on direct manufacturer sales is a restriction on consumer choice—dealer franchise laws take away the option of a consumer purchasing directly from a manufacturer. If consumers prefer to buy cars from independent dealers, then there is no need for a law to force consumers to do so. The question is whether consumers should be allowed to do anything else. Indeed, all around the world independent dealerships continue to thrive in jurisdictions without laws banning direct sales by manufacturers.

Another problem with NADA’s argument: most independent economists believe that dealer franchise laws impose costs on consumers to the benefit of dealers.

Do dealer franchise laws benefit consumers?

Dealer franchise laws belong to a category of occupational licensing regulations that have been the subject of withering criticism over the past few decades by social scientists, including economists and public choice theorists, such as the recently departed Kenneth Arrow. At their best, occupational licenses act as a way of ensuring that businesses meet reasonable quality and safety standards. At their worst, occupational licensing can by captured by special interest groups and turned into an artificial barrier to entry for new businesses, stifling innovation and rewarding entrenched interests.

A recent open letter from 70 major economists to New Jersey Governor Chris Christie on this issue stated the mainstream economic position bluntly:

There is no justification on any rational economic or public policy grounds for such a restraint of commerce. Rather, the upshot of the regulation is to reduce competition in New Jersey’s automobile market for the benefit of auto dealers and to the detriment of its consumers. It is protectionism for auto dealers, pure and simple. . . . In sum, we have not heard a single argument for a direct distribution ban that makes any sense. To the contrary, these arguments simply bolster our belief that the regulations in question are motivated by economic protectionism that favors dealers at the expense of consumers and innovative technologies.

Independent studies that have looked at the economic impacts of dealer franchise laws generally show that by restricting new distribution methods, these laws impose costs on consumers; one study shows that they increase average vehicle costs by 8.6 percent, or $2,225 per vehicle. For all these reasons, the Federal Trade Commission, along with most independent consumer organizations, including Consumer Federation of America and Consumers for Auto Reliability and Safety support allowing direct sales from manufacturers.

Connecticut should lift the ban on direct manufacturer sales for EVs

Unless you are an independent auto dealer yourself, there is simply no good reason for Connecticut to continue to prohibit Tesla from operating in the state.

The dealer franchise laws that ban direct manufacturer sales are antiquated laws designed to deal with economic circumstances that are not relevant to Tesla. The primary economic impact of these laws is to enrich dealers at the expense of consumers. The Tesla ban acts as an unnecessary impediment to achieving the state’s goals for vehicle electrification and pollution. And the most immediate practical impact of dealer franchise laws is to frustrate and irritate Connecticut residents, while depriving the state of economic activity and tax revenue.

This law should be changed.

Why You Can’t Buy a Tesla in Connecticut (and 5 Other States)

The state of Connecticut is a progressive state, with a strong track record of support for laws and policies that will reduce global warming emissions and a goal of putting over 150,000 electric vehicles on the road by 2025.

Given the policy commitments of the state of Connecticut, one might assume that Connecticut would be a place that would welcome an innovative, important business like Tesla, the largest manufacturer of electric vehicles in the United States. And given the significant fiscal challenges that Connecticut faces, one might think that Connecticut would be excited to see Tesla operate new stores within the state, bringing jobs and tax revenue.

But in fact, Tesla is legally prohibited from operating its Tesla stores in Connecticut.

Under Connecticut’s dealer franchise law, and under the law of many states throughout the country, automobiles may only be purchased through independent car dealerships. Tesla’s cars are sold directly from the manufacturer, which mean that Tesla stores are not welcome in Connecticut.

The problems that Tesla has faced with automotive dealers and state dealer franchise laws represent a combination of unintended consequences, special interest influence, and the challenges of developing new technologies in marketplaces dominated by entrenched interests and outdated laws. The Tesla wars are also a part of a broader story of how changes in technology are impacting laws and regulations governing transportation in the United States.

In this blog post, I want to explore some of the key questions raised by the battle over Tesla. In particular:

  • Why do we have dealer franchise laws?
  • Why doesn’t Tesla sell their cars through franchised dealers?
  • Why do some states allow Tesla stores and others do not? (Hint: it depends on the meaning of ‘its’).

In part 2 of this post, I will look at some of the policy arguments that have been made by auto dealers, by Tesla and by economists on dealer franchise laws.

  • What is the justification for laws banning Tesla stores?
  • What does the evidence suggest about dealer franchise laws?
  • What are the consequences of Connecticut’s ban on Tesla stores?
Why do we have dealer franchise laws?

The car dealership model as we know it today arose in the 1920s and 1930s, as first General Motors, and then eventually all of the “Big Three” American automakers chose to license the rights to sell their cars to independent dealers, rather than selling the cars directly to consumers.

The independent dealership model worked because it allowed both parties to focus on core competencies: the manufacturers could focus on making the best cars possible, while independent dealers made the inroads into local communities that allowed them to most efficiently sell the cars directly to consumers.

From the beginning, one challenge in the independent dealership model is the obvious power imbalance between the “Big Three” automakers who dominated automobile manufacturing, and the thousands of independent dealerships that were licensed to sell their vehicles. Stories abounded of auto manufacturers exploiting their superior market position to gain unfair advantages on independent dealers. For example, manufacturers could force independent dealers to purchase cars that they didn’t want as a condition of maintaining their relationship, or terminate the franchise relationship at will without cause, or coerce profitable dealerships into selling their business at below-market rates.

Beginning in the 1930s and accelerating greatly in the 1950s, legislatures in all 50 states passed a series of laws, known collectively as dealer franchise laws, which were intended to protect independent dealers from abusive practices at the hands of vehicle manufacturers. Among other things, these laws prohibited the Big Three from owning licensed dealerships themselves, or selling cars directly to consumers.

The prohibition on direct manufacturer sales was intended to protect independent auto dealers from unfair competition from their own manufacturers. The classic concern addressed by the ban on direct sales from manufacturers is the independent car dealer who spends money, time and effort building a market for, say, Ford vehicles in a certain town, only to have Ford Motor company jump in and open up a rival direct from manufacturer store that undercuts the independent dealer on price and takes his market share.

By the 1950s when most of these laws were passed, the independent dealer model was so entrenched in the American car market that it was simply presumed that all auto manufacturers would have independent dealerships selling their cars, and that any direct manufacturer sales would necessarily be in competition with an independent dealership. Dealer franchise laws therefore did not contemplate the challenge posed by a company like Tesla, a company that refuses to sell its cars to independent dealerships at all and instead insists that all sales must be direct from the manufacturer itself.

Why doesn’t Tesla distribute through franchised dealers?

Tesla has adopted this policy because they believe that the traditional independent dealership model does not work for electric vehicles. According to Tesla CEO Elon Musk:

Existing franchise dealers have a fundamental conflict of interest between selling gasoline cars, which constitute the vast majority of their business, and selling the new technology of electric cars. It is impossible for them to explain the advantages of going electric without simultaneously undermining their traditional business. This would leave the electric car without a fair opportunity to make its case to an unfamiliar public.

Tesla points to the failure of Fisker and Coda as examples of electric vehicle start-up companies that failed because of their reliance on independent dealerships to sell a new technology. In addition, Tesla argues that because electric vehicles have lower maintenance costs than traditional cars, independent dealerships that make money off of service will always have an incentive to steer consumers away from electric vehicles. Tesla offers service for all of their vehicles for free.

Recent studies confirm that, with a few exceptions, most auto dealers in the Northeast are not making enough of an effort to sell electric vehicles. Between January and June of 2016, dealers in the Bridgeport to New York City metro area had 90 percent fewer EVs listed for sale than Oakland, when adjusted for relative car ownership. A recent report by the Sierra Club found that Tesla stores provide EV customers with far superior service, as Tesla was more likely to have EVs available to test drive, more likely to be knowledgeable about state and local incentives, and more likely to be able to correctly answer technical questions about charging EVs, than traditional car dealerships.

A Tesla store looks and feels more like an Apple store than a car dealership. They are placed in high volume, high traffic areas such as shopping malls. They have almost no inventory, as Tesla cars must be ordered individually from the manufacturer rather than sold on site. There is no haggling over price. And Tesla stores sell only Tesla products, including cars and batteries; with the recent merger with SolarCity, Tesla stores will soon sell solar panels as well.

Why do some states allow Tesla stores and others do not?

Over the past few years, courts and legislatures across the country have struggled with the question of whether and how to apply dealer franchise laws to Tesla stores. Some state courts, including Massachusetts and New York, have found that dealer franchise laws are only intended to apply to manufacturers that have licensed independent dealers, and do not provide a cause of action against Tesla stores. Other states, including New Hampshire and Maryland, have recently changed its law to permit Tesla stores through legislation.

States that currently ban Tesla stores include Texas, West Virginia, Utah and Arizona, in addition to Connecticut. Some states, including Virginia and Indiana, allow a limited number of Tesla stores. New Jersey proposed a regulation that would have banned Tesla stores in 2015, but then relented last year, amending the regulation to allow 4 stores in New Jersey.

Often the difference between a jurisdiction that permits Tesla stores and a jurisdiction that bans Tesla stores comes down to minute differences in statutory language. For example, until 2014 Michigan’s dealer franchise law prohibited auto manufacturers from “[selling] any new motor vehicle directly to a retail customer other than through its franchised dealer.”

The word “its” in the statute arguably suggests that the law only applies to manufacturers that have franchised dealers, and thus does not prohibit Tesla stores. But then a legislator allied to the auto industry slipped a provision into an unrelated piece of legislation removing the word “its” from the statute, and just like that, Tesla stores were banned in Michigan.

Beyond narrow questions of statutory interpretation, judges and legislators wrestling with these questions need to consider the purpose of dealer franchise laws. Are these laws meant to regulate a relationship that arose within the context of the independent dealer system? Or are these laws intended to mandate that the independent dealer system must be the only way automobiles are sold in the United States forever? If it is the latter, then the dealer franchise laws represent not only a ban on Tesla, but a ban on all innovation in distribution methods.

Can such a ban be justified? In part 2 of this post, I’ll explore some of the policy consequences of dealer franchise laws and the Tesla ban, for consumers, and for Connecticut.

How to Ensure Self-Driving Vehicles Don’t Ruin Everything

Zipcar’s former CEO has cast the self-driving future as a “heaven or hell” scenario, and she has a point. Self-driving cars could save lives, smooth traffic congestion, expand access to jobs or schools—especially for people who can’t drive themselves today—and reduce the number of vehicles on our roads. On the other hand, they could worsen smog and local air quality pollution, disrupt the US economy by putting millions of people out of work, justify cuts in public transit funding and services, and force urban planners to focus more on providing space for vehicles instead of for parks, bicyclists, or pedestrians.

To maximize the potential benefits of self-driving vehicles and minimize their potential consequences, UCS developed this set of principles that we will be pushing policymakers, businesses, and other stakeholders to follow. Doing so will ensure that self-driving vehicles reduce oil consumption and global warming emissions, protect public health, and enhance mobility for everyone.

Science-based policy will be key for shaping the introduction of self-driving technology

Many are rallying against any regulation of self-driving technology beyond ensuring it’s safe to use. I’ve even heard the claim that over regulating this technology will literally kill people by slowing the speed at which self-driving cars are introduced, thus delaying their potential safety benefits.

To be fair, this argument has merit. Self-driving vehicles are forecast to reduce the tens of thousands roadway fatalities that occur each year in the US by as much as 90 percent, and can offset the rise of distracted driving that may have caused the biggest spike in traffic deaths in 50 years (though reaching these improved safety levels will take further advances in the technology and widespread deployment).

But, self-driving technology won’t just impact transportation safety. Researchers are forecasting how it will affect traffic congestion, vehicle-related emissions, land-use decisions, public transit systems, data security, and the economy. Unfortunately, the emphasis that many, including the US Department of Transportation, have placed on the safety benefits can be distracting from the need to consider how policy should address the other equally great potential impacts of self-driving technology.

I’m not saying self-driving technology should be regulated to the scrapheap. The technology is highly likely to improve traffic safety and increase access to transportation—both important outcomes. Yet self-driving vehicles will need to be regulated on issues other than safety, as their full breadth of potential impacts won’t be addressed by safety-focused policy or market forces alone.

For example, studies have found that self-driving vehicles could double transportation emissions (already the largest source of climate change emissions in the US), place millions Americans out of work as automated driving replaces truckers and taxi drivers, and/or exacerbate urban sprawl.

The jackpot for winning the race to produce the best self-driving vehicle can still be won even if these negative affects are suffered, and today’s policy frameworks may be insufficient to effectively curtail these future impacts. Let’s not forget that automakers have historically been against regulation (see: seat belts, fuel economy, air bags) and are encouraging policymakers to clear the way for self-driving vehicles not only because they seek to improve transportation safety, but because they see a potential to make a profit.

So science-based policy covering the broader implications of self-driving cars, including how they affect emissions and our economy, will be needed to ensure the best possible self-driving future and these discussions need to happen today. To kickstart these conversations, UCS released these principles that will create a safe, healthy, and equitable autonomous future. Join the conversation on whether and how self-driving technology should be regulated by checking out our new self-driving vehicle web content and signing up for future action alerts here.

What is Oil Used For? What the Super Bowl Commercial Didn’t Tell You…

A commercial during yesterday’s Super Bowl about oil may have given you pause.

Besides the sports car (about to go off-roading), the commercial was about things you probably don’t associate with oil. Like graffiti; makeup; prosthetics; a heart; and outer space.

Is oil really diversifying? Or is this ad just a marketing ploy?

Looking at data from the U.S. Energy Information Administration, it is pretty clear that oil and natural gas are still being used overwhelmingly for what they have always been used for—combustion, whether in vehicles or power plants.

The American Petroleum Institute (API) ran the commercial in question. API is the largest oil trade association in the United States. Member companies include BP, ConocoPhillips, Chevron, ExxonMobil, and Shell. You may have heard of API for their role in a concerted campaign to spread denial about climate change. They merged with America’s Natural Gas Alliance last fall, so it now lobbies for both oil and natural gas interests. This merger came about because major oil companies now have large natural gas assets.

As a chemist, I know that many consumable products like asphalt, paint, and plastics have oil or natural gas as a precursor ingredient. And while these products have many positive impacts in society, they are absolutely tiny fractions of the oil and gas industry and should not be used to justify the bulk of their business. Over 90% of oil and gas is used for combustion, either in power plants or vehicles.

Let’s not discount the many benefits energy provides society

But while coal, oil, and natural gas have been our primary sources of energy for many decades, we will not rely on them in the future. We are moving to a world that gets most of our energy from clean, renewable resources like wind and solar. This is in large part because the cleanest sources of energy are becoming the cheapest. Our cars and trucks can plug into that clean grid for their future fueling needs.

There are many chemists exploring ways to make plastics etc. from non-petroleum resources such as plants. This is great work (and tough chemistry) that will lead to a more sustainable world. But if we are going to stop the worst effects of global warming and clean our air, we must remember the most obvious effects oil and natural gas are having on our communities and our world.

We have solutions

While oil may currently play a role in making paint, plastics, or rocket fuel, it doesn’t “gush art,” “pump life,” or “explore space”–that would be artists, doctors, and scientists. And it is artists painting a picture of environmental justice; doctors treating patients suffering from asthma; and scientists discovering clean energy solutions.

Massachusetts Moves to Limit Pollution from Transportation: 5 Things you Should Know

The state of Massachusetts has been an important leader in the fight to protect our climate from global warming. But there’s one area where Massachusetts continues to struggle: controlling pollution from transportation. New limits on transportation emissions now under consideration by the Massachusetts Department of Environmental Protection (DEP) could determine whether the Commonwealth can stay track to achieve our climate mandates, or whether transportation emissions will undermine the progress the state has been able to make building a clean energy future.

Clean Vehicles, CV

Transportation and the Global Warming Solution Act

The Bay State has passed one of the strongest climate laws in the country, the Global Warming Solutions Act (GWSA), which requires the state to reduce emissions throughout our economy by at least 80 percent of 1990 levels by 2050. Massachusetts also leads the nation in energy efficiency, and last year, passed an energy bill that will see the largest ever procurement of offshore wind in the United States.

Massachusetts has been able to make significant progress on these issues because the people of the Commonwealth care a lot about climate, because our state is uniquely threatened by the impacts of sea level rise and other climate change impacts, and because our state boasts a proud bipartisan tradition of leadership on climate and energy.

But transportation has been a challenge for Massachusetts. Pollution from our cars and trucks is the largest source of emissions in the state, and it’s the one area of our economy where emissions have actually grown since 1990, as increased total driving in the state has outpaced gains in fuel efficiency:

Achieving significant reductions in transportation emissions basically boils down to using a lot less oil. The good news is that we know how to do this! More efficient cars, cleaner fuels, electric vehicles, and a transportation system that gets us where we need to go without spending so much time behind the wheel, can all help cut pollution from transportation.

Kain v. Department of Environmental Protection

This week, Massachusetts will take an important step towards tackling the pollution from transportation, as the state’s Department of Environmental Protection (DEP) considers new limits on emissions in the sector.

These proposed regulations are in response to last year’s landmark decision in Kain v. Department of Environmental Protection, in which the Massachusetts Supreme Judicial Court ordered the state needs to set mandatory and enforceable limits on the total mass of pollution emitted within the state from different sources, including transportation. These proposed regulations represent DEP’s response to the Kain decision. So how did the DEP do? Here’s what you need to know:

#1: DEP is proposing to limit most, but not all, emissions in the transportation sector.

The proposed DEP regulation covers the “surface transportation system” within Massachusetts, which means emissions that come from passenger vehicles, light and heavy duty trucks, and transit systems. The new regulations do not cover aviation or marine transportation. All told, that means that approximately 85 percent of Massachusetts transportation emissions are covered by this regulation.

Leaving aviation and marine travel out of the current regulation may make sense, given that these areas present different administrative challenges. In the long run, however, Massachusetts will need to make progress in these areas as well, and the state should consider additional regulations that will establish limits on boats and airplanes.

#2: The proposed limits are ambitious.

Overall the state is proposing to cut emissions in the transportation sector by approximately 1.87 percent per year for each of the three years covered by this regulation (2018, 2019 and 2020). That’s pretty challenging! Massachusetts has not been able to achieve a 1.87 percent reduction in transportation emissions for three consecutive years since 1990-1993, 25 years ago.

But, while ambitious, a 1.87 percent linear decline isn’t quite enough to achieve our long-term climate goals. Overall, the DEP proposal would put the state on track to achieve a 35% reduction by 2030 and a 57% reduction by 2050. So while these regulations represent an ambitious effort to begin to get transportation emissions under control, we’ll need to accelerate progress over the coming years to achieve our climate mandates.

#3: Achieving these limits will require additional policies.

The two biggest challenges with this regulation are: it isn’t clear how we are going to achieve these limits, and it’s not clear what happens if we fail to achieve them.

Right now, Massachusetts is relying heavily on federal and regional policies to reduce emissions in transportation. In fact, 93 percent of the projected emission reductions in the state’s most recent Clean Energy and Climate Protection plan come from National Greenhouse Gas and Fuel Economy Standards that, if fully implemented, will approximately double the fuel efficiency of new vehicles by 2025. These standards are now very much under threat from a combination of automaker intransigence and the current administration in Washington.

The new federal administration means that Massachusetts and other states are probably on our own when it comes to achieving our climate limits.  Massachusetts needs to think big about new policies that will help our residents and businesses drive less or purchase cleaner vehicles. Aside from reducing emissions in state fleets, the DEP is not yet proposing new policies to achieve the limits that they lay out in this regulation. But they are going to have to if they want to be successful.

#4: It’s not clear how these regulations will be enforced.

What happens if we go over our limit? The regulations are not clear on this very important point.

The most straightforward way to make the limits on transportation emissions enforceable is through a requirement that polluters purchase allowances from a limited pool (or cap). This market-based approach would build on the successful model of the Regional Greenhouse Gas Initiative, which has been really effective in reducing emissions while promoting economic growth in the electricity sector. RGGI is also an important source of funding for Massachusetts’ clean energy and efficiency programs. A market-based approach to ensuring emission reductions is explicitly authorized by Section 7 of the GWSA.

Without some kind of mechanism to ensure that the state actually achieves the reductions, this regulation will not be the kind of mandatory and enforceable limits required by the Supreme Judicial Court.

#5: Achieving long-term reductions in the transportation sector will require regulations that extend past 2020.

One major challenge facing DEP throughout this whole process is that the GWSA regulations that they are in charge of implementing sunset by statute in 2021. Achieving short-term reductions is challenging in the transportation sector, as vehicles, community development patterns, and transportation infrastructure investments all change slowly.

A more sensible approach would be for the state to establish limits through 2030. Several proposals in the Massachusetts legislature would eliminate the 2020 sunset and allow DEP to consider limits on a longer time horizon.

Working together, both parties and all three branches of government in Massachusetts have made significant progress reducing emissions from electricity generation and increasing the efficiency of our homes. Massachusetts’ policies to promote solar energy, for example, have allowed the technology to explode into the mainstream, providing thousands of Massachusetts residents with affordable zero-emission energy. With the growth of new technologies such as electric vehicles, new transportation systems such as car sharing, and ever-increasing use of public transportation and cycling in the Bay State, we have more options then ever before to promote clean transportation. It is time for policy leaders in Massachusetts to bring the same urgency and focus that has lead to so much success in the electric sector to the task of reducing pollution from transportation.

 

What’s Congress Doing to our Methane Waste Regulations?

Yesterday I spoke at a forum in the Capitol on the Bureau of Land Management’s Methane Waste Rule, an event organized by Democratic members of the House Natural Resources Committee. I offered testimony on a panel of experts including a former BLM official involved in developing the rule, a nurse speaking about the public health benefits of the rule, a scientist from Clean Air Task Force who discussed the Colorado rules on which parts of the BLM rule were modeled, and a pastor who talked about the moral imperative to use natural resources responsibly, and limit the harms caused by climate change.

I joined a panel of experts testifying on the BLM methane waste rule (I am wearing a red tie).

Four democratic Representatives asked questions and made statements. These included Congressman Grijalva from Arizona, who is the ranking member on the Committee for Natural Resources, along with Congressman Huffman (CA), Congressman Lowenthal (CA), and Congressman McEachin (VA).

Representatives (from left to right) Lowenthal, Huffman, Grijalva, and McEachin

Republicans are threatening to eliminate the BLM Methane regulation using an obscure, radical, and rarely used congressional trick called the Congressional Review Act (CRA).

The CRA allows Congress, with a simple majority, to completely revoke any rules made in the last 6 months of the Obama administration. It is a blunt tool that would revoke regulations that went through extensive stakeholder review, used evidence-based science, had public notice and comment, and took a few years on average to be finalized.

In addition, it stipulates that any rule that is similar to the rule can NEVER be done again, unless Congress gives explicit permission–thus salting the earth.

The BLM methane regulation updates rules issued in the Carter administration governing how oil and gas are produced on Federal and tribal land. The new rules will reduce leaks, venting, and flaring of natural gas, which not only wastes a resource that belongs to the American people, but also turns it into a health and climate hazard.

Apparently, the oil industry likes the 1979 vintage rules better, and the new Congress is rushing to do their bidding, quickly moving to revoke a rule that was three years in the making. But rolling back the regulatory clock to 1979 would be as dumb as removing requirements for airbags and anti-lock brakes from modern cars.

A lot has changed in the last 38 years, including the rise of fracking and the associated methane pollution from tight oil production. Rapidly reducing methane pollution–the leading non-CO2 pollutant responsible for climate change–is more urgent than ever before.

The last decades have also seen new technologies to measure, manage and utilize natural resources responsibly. An up-to-date regulatory framework for the oil and gas industry is essential to holding a massively polluting industry accountable.

The CRA is touted as a tool to exert control over unauthorized, unnecessary, or unreasonable agency regulation, but the methane and waste prevention rule is clearly authorized, necessary and reasonable.

Former Counselor to the Director of the Bureau of Land Management Alexandra Teitz explains in her testimony that BLM is required by law to prevent waste and ensure that resource extraction on public lands is conducted in a safe and responsible manner. The Government Accountability Office (GAO) estimated that State and Federal taxpayers are losing as much as $23 million per year in royalty revenue due to this waste, and GAO found that the BLM needed to update its rules to address this waste.

The BLM worked on these rules for three years, holding numerous hearings around the country. They received more than 300,000 public comments and made changes to the final regulation based on this feedback. As Dr. David McCabe, Senior Scientist at the Clean Air Task Force explained in his testimony, the waste rule was modeled on policies already implemented in Colorado, Wyoming and North Dakota.

As these states’ experience shows, sensible up-to-date standards work to cut pollution and waste, and their requirements are easily implemented. These rules are not going to stop the oil industry from drilling for oil and gas; they just set reasonable standards of performance that reflect the current best practices modeled in states.

Responsible industries recognize that an up-to-date regulatory framework is necessary to protect the public and ensure that irresponsible actions by a few bad actors do not tarnish the whole industry. Cars, trucks and even appliances are subject to numerous standards that ensure that as technology changes, so do requirements for safety, pollution and efficiency.

The history of oil and gas extraction is filled with egregious examples illustrating the need for strong regulations to protect the public, and it is especially obvious that oil companies operating on public lands, who are extracting resources that belong to the American people, should be held to reasonable standards to avoid waste and unnecessary pollution.

The same day I was speaking to House Democrats, Former ExxonMobil CEO Rex Tillerson was being narrowly confirmed as Secretary of State and Jack Gerard of the American Petroleum Institute was speaking at a hearing on regulations in the Senate.

Under cover of the maelstrom that is DC this last couple weeks, Mr. Gerard invented some alternative facts and head-spinning doublespeak about the CRA. API’s press release on Mr. Gerard’s testimony was titled “smart, science-based regulation needed to advance America’s energy renaissance and jobs.” Apparently even API knows that is what people expect and demand.  But what Mr. Gerard actually said was:

This week, we support the efforts of Congress as it takes the first step to pull back a number of these ill- considered and hasty regulations under the CRA. These include Section 1504 of Dodd-Frank, which places U.S.-based energy companies at a competitive disadvantage in the world marketplace, and BLM’s methane regulations, which are technically flawed and redundant to state regulation. Furthermore, we look forward to the anticipated CRA resolution on EPA’s redundant and unnecessary Risk Management Program rulemaking.

Despite Mr. Gerard’s doublespeak, the CRA has the opposite effect – killing smart, science-based regulations and blocking agencies from issuing any similar updates in the future, unless Congress passes new legislation specifically authorizing it.

The CRA is the opposite of a smart science-based regulation; it is a dirty trick that Congress can use to do the oil industry’s bidding.

Ford Backpedals on Promises, Could Harm American Consumers

Last Tuesday, the CEOs of General Motors (Mary Barra), Ford (Mark Fields), and Fiat-Chrysler (Sergio Marchionne) met with President Trump to discuss the auto industry. On Thursday, we finally got some more details about what they discussed, and it’s pretty bad for everyone.

Ford signed on to rules and is now trying to back out of its commitment

Ford CEO Mark Fields recently met with President Trump to weaken federal oversight of the industry, including the vehicle efficiency regulations that have sparked investments in jobs and are already saving consumers millions of dollars in fuel. Photo: Wikimedia

As part of an overall deal on regulation of the industry, Mark Fields is seeking to weaken the federal vehicle efficiency standards finalized in 2012. These standards were supported at the time by all three Detroit manufacturers, as well as nearly all other automakers.

Included in those rules was a mid-term review of the EPA’s regulations. That comprehensive review was completed by the Obama administration two weeks ago, and its results surprised no one—those rules finalized back in 2012 are easier to achieve than anticipated and at reduced costs to automakers…so sayeth not just the EPA but the Department of Transportation and California Air Resources Board; the National Academies of Science, Engineering, and Medicine; UCS; and countless others.

Now, Mark Fields is jumping at the opportunity to stick it to the American public and back out of that agreement, despite Ford seeing record profits in 2016. And he wouldn’t just be harming the environment with this decision—he’d be harming American workers and American consumers.

Vehicle standards are good for American workers

Ford invested $1.1 billion in the Kansas City assembly plant for its F-150. With the all-aluminum truck continuing to maintain its position as top-selling vehicle in the United States, it’s clear that investments in fuel economy are good for American workers and American consumers.

Since bottoming out in the recession, the US auto industry has added nearly more than 300,000 jobs in manufacturing and assembly. It’s difficult to estimate exactly how many of those jobs are related to efficiency standards, but a recent report from the Department of Energy noted that nearly half of all auto manufacturing and assembly jobs are in technology that improves the fuel economy of the vehicle.

Ford themselves know quite well how these investments pay off—their best-selling vehicle is the F-150, and they just invested $1.1 billion dollars to its Kansas City Assembly plant to manufacture the new aluminum-bodied F-150, adding 900 workers in the process. Alcoa, just one of many suppliers to the F-150, added 200 jobs to provide the aluminum for the new truck. And this is just one of many examples—suppliers around the country are creating jobs as automakers invest in new technologies at unprecedented rates.

Instead of pointing out just how good these standards have been for jobs, providing certainty for the industry and sparking a series of strong investments in the United States, Mark Fields took a cue from the President by providing his own “alternative fact,” repeating a previously debunked claim that these standards could cost 1 million jobs.

(Please see here, here, and here for why this number is fundamentally flawed.) In fact, previous analyses have shown that these standards will lead to more than 50,000 jobs in automotive manufacturing alone.

Beyond the jobs impacts, there is also analysis that these standards help make the industry, and particularly the Detroit automakers, more resilient to shifting market trends. That benefits the workers directly, particularly under the profit-sharing agreements that many UAW workers enjoy. And it also insures the industry against a repeat of the disastrous plummet in sales that led to the bailout of GM and Chrysler and nearly bankrupted Ford when consumers turned away from pricey, inefficient trucks and SUVs and towards more efficient cars.

Should this situation repeat itself (and with gas prices such a volatile commodity, it no doubt could), fuel economy standards would help, leading to profits for the domestic automakers no matter what; if Mark Fields helps scuttle those standards by focusing on the short term, it could cost the Detroit Three about $1 billion annually in the long run.

Vehicle standards are good for American consumers

In addition to protecting workers, these standards protect consumers. More fuel efficient vehicles protect consumers from volatility at the pump. This is especially important for lower income individuals who purchase vehicles on the used car market—their choices are dictated by more affluent individuals who can afford to care less about fuel economy and generally spend more of their money on the vehicle versus the fuel. For low-income households, this is flipped: for this reason, fuel economy standards benefit lower-income individuals disproportionately.

This is one of the many reasons why fuel economy standards are so critical during times of low gas prices.

Moreover, saving money on fuel means more money that can be spent elsewhere in the economy—and that means more jobs for everyone. Taken together, we estimate that the 2012-2025 standards will add $25-30 billion to the economy by 2030, which means about 650,000 total new jobs across the economy.

Regulations aren’t “out of control”—they’re protecting Americans and holding companies accountable

On the same day as the Trump-Detroit Three meeting, Volkswagen approved a settlement with dealers over its Clean Air Act-violating diesel cars. One week before that, Fiat-Chrysler was served notice that some of their vehicles are in violation of the Clean Air Act, too. A month before that, General Motors appealed to the Supreme Court to try to wriggle out of some of the responsibility for an ignition switch defect that led to 124 fatalities.

Over the past few years, Ford, Hyundai, Kia, BMW, and Mercedes have all been forced to adjust their fuel economy labels because they were misleading to consumers. And obviously there is the disastrous Takata airbag scandal enveloping Honda, Toyota, Ford, and basically the entire industry, which has resulted in at least 11 dead.

All of this is to say that it’s pretty darn clear why the auto industry is regulated. And, frankly, it’s appalling that the CEO of Ford is trying to use a new administration to undermine government watchdogging of an industry with quite the history of skirting and combatting regulation.

Maybe Mark Fields would be better served using this as an opportunity to engage more constructively, as it appears his counterpart Mary Barra at GM may be:

“We had a very constructive and wide-ranging discussion about how we can work together on policies that support a strong and competitive economy and auto industry, one that supports the environment and safety. The U.S. is our home market and we are eager to come together to reinvigorate U.S. manufacturing. We all want a vibrant U.S. manufacturing base that is competitive globally and that grows jobs. It’s good for our employees, our dealers, our suppliers and our customers.”

Let’s hope GM is true to their word and Ford changes their tune. Our health, safety, and economy may very well depend on it.

Photo: Wikimedia

Why Immigrants Are Vital to Science in the U.S.

Immigrants are central to advancing science in the United States. An estimated 4.6 million college-educated, foreign-born scientists and engineers comprised over a quarter (27 percent) of the entire science and engineering workforce in the U.S. in 2013.

These millions of scientists and engineers are helping create a healthier, safer society – especially in the area of cancer research. According to a 2013 survey, 42 percent of the researchers at the top seven cancer research centers were found to be foreign-born and the influence of foreign-born researchers at some of the leading U.S. cancer institutions was found to be even higher. At the University of Texas MD Anderson Cancer Center, for example, 62 percent of the cancer researchers were foreign-born and at the Memorial Sloan-Kettering Cancer Center in New York, 56 percent of the researchers were considered immigrants.

Immigrant scientists and engineers tend to be exceptional

Aside from cancer research, the scientists and engineers making the largest impacts in their fields frequently come from immigrants. A study published in Science found that the individuals making exceptional contributions to science and engineering in the U.S. are “disproportionately drawn from the foreign-born.” Moreover, all six of the 2016 Nobel Prize winners affiliated with American universities were foreign-born. Speaking in reference to Brexit, an editor for the London-based Times Higher Education thought the 2016 Nobel Prize class should “serve as a serious warning to those politicians, most notably in the U.K., but also of course in the U.S. and elsewhere, who would seek to place major restrictions on the free movement of international talent.”

And Nobel Laureates

Analysis by George Mason University found that 42 percent of all Nobel Prizes awarded between 1901 and 2015 went to individuals working in the U.S., and that 31 percent of all U.S. Nobel laureates were born outside the U.S. — a figure that’s more than double the highest proportion of immigrants in the general population during those years. Absent immigrant scientists and engineers, the U.S. would have missed out on Nobel Prizes for: (1) figuring out the ribosome (Venkatraman Ramakrishnan, born in India), (2) discovering femtochemistry (Ahmed Zewail, born in Egypt), (3) linking chlorofluorocarbon gases (CFCs) to the depletion of the Earth ozone layer (Mario J. Molina, born in Mexico), and many others.

Immigrant scientists and engineers come for the education and stay for the career

Data suggests that over half of the foreign-born recipients of doctorate degrees in the U.S. remain in the U.S. workforce to pursue their careers, becoming part of the multicultural milieu that has made, and will continue to make, America great.  Let’s not forget the contributions that immigrants have made in advancing science, or the potential contributions to come.

As my colleague Michael noted, many scientists are taking the fight out of the lab and onto the streets. They are organizing marches, preparing to run for office, and joining watchdog teams to monitor and respond to activity. If you’re a scientist and you haven’t signed our letter outlining expectations for the Trump administration, including the promotion of diversity, do so here.

Will Electric Cars Thrive, Survive, or Die Under President Trump?

President Trump just dropped his “America First” energy plan and, not surprisingly, it doesn’t include renewable energy or electric vehicles. It does, however, mention the importance of protecting clean air and clean water though it also encourages the very energy sources that pollute both of these public goods. Weird.

President Trump’s beachhead teams are swiftly infiltrating the federal agencies meaning that the policies that helped electric vehicles during the Obama years could soon get scaled back or dismantled altogether. The electric car has already been killed once, will it be killed again?

(TL:DR – probably not, given the demand for clean transportation outside of the U.S. and the declining cost of electric vehicle batteries).

Federal support for EVs has been important

Electric vehicles (EVs) have needed federal support to compete in a market that has been dominated by the gasoline engine and a reluctance from automakers to invest in new technologies like seat belts or fuel efficiency. Aside from the federal tax credit of up to $7,500 for buying an EV, the Obama Administration enacted a series of initiatives that helped EVs to gain a finger hold in the national vehicle market. The Department of Energy provided low cost capital to Tesla, Ford, and other automakers seeking to develop EV manufacturing plants, the Department of Transportation began to make on-the-go charging easier by identifying highway corridors ripe for EV chargers, signage, and investment, and our national laboratories helped cut battery costs from over $1,000 per kilowatt hour to around $200 per kWh.

Battery costs have continued to fall, helping meet the increased demand for electric vehicles. Source: Bloomberg New Energy Finance.

State support has been critical too

State-based policy has also been instrumental in helping EVs succeed. The California Zero Emission Vehicle Program, for example, requires automakers to sell EVs in California or obtain credits from other automakers that sold EVs in the Golden State (see: Tesla’s business model). In 2018 this program will require automakers to sell EVs in 9 other states that have adopted the California program, and which collectively make up about a quarter of the national vehicle market. Other states have EV policies too, and mayors, governors, and other elected officials across the country have pledged to continue state and local support for EVs.

Thanks in part to federal and state policy, consumers are now able to access many more electric vehicle options compared to 2011. More EV offerings from more automakers are planned in the next couple years, which will help the EV market continue to grow. Note that all BMW i3s were considered BEV, though some were the range-extender models that are PHEVs. Source: ucsusa.org

How President Trump can affect the electric vehicle market

Maybe President Trump will try to undo all of this policy support, maybe he won’t. I can’t find any mention of his possible stance on EVs, though I’m encouraged that he met with Tesla CEO Elon Musk and other automaker CEOs in his first week in office. I’m also discouraged by recent comments from Ford’s CEO on his hope that the President will ease fuel economy standards.

In theory, President Trump and Congress could not only dismantle federal EV support – through repealing the federal EV tax credit and halting federal EV programs – they could also attempt to repeal the sections of the Clean Air Act that both grant California the unique authority to set its own pollution limits and allow other states to follow California’s lead. There’s been no indication that the President or Congress will take this route, but lawmakers have taken swipes at the Clean Air Act in the past and it’s important to recognize the power of the federal government to impede state authority to combat climate change.

Don’t get too worried, though. The UCS #geeksquad is keeping a close eye on Congress and the new Administration and are always ready to help you join the fight against efforts to stop the progress our country has made toward reducing oil use and climate change pollution. Interested in finding out how you can get alerts for future engagement opportunities? Head on over here.

EV sales continue to rise even as gasoline prices decline. Sources: InsideEVs.com and U.S. Energy Information Administration.

The electric vehicle market can survive even without U.S. policy support

Join me on Hypothetical Avenue for a moment, won’t you? Assuming that U.S. policy support for EVs is put on hold, there are several indications that the global EV market will continue to grow.

First and foremost, EVs are simply a great product. The Nissan LEAF, Chevy Volt, and Tesla Model S are among the highest rated vehicles on Consumer Reports, and GM’s Chevy Bolt has already been anointed as Motor Trends’ 2017 Car of the Year. I’ve driven many different EV models and am certain that once you get into an EV and press your foot on the accelerator, you’ll be hooked too. They are too much fun to drive to ever want to go back to a gas engine.

Second, driving and owning an EV will save you money. Even though gas is cheap, driving on electricity remains cheaper – by about half. All-electric vehicles, like the Nissan LEAF or Chevy Bolt, also have fewer moving parts and don’t require oil changes or other types of periodic maintenance, meaning that their maintenance costs are forecast to be 35 percent lower than a comparable gasoline car. Overall, owning an EV can save you thousands in fuel costs over the vehicle’s lifetime.

Driving on electricity is still cheaper than gasoline. Source: egallon.gov.

Third, they pollute considerably less than comparable gasoline vehicles and, when charged by energy sources other than coal, can help abate the heavy air quality pollution that plagues many cities around the world. As I type I’m listening to a news report from London where a recent spike in air pollution was the highest level recorded since April 2011. Cities in China, India, and other densely populated areas also experience poor air quality due, in part, to transportation emissions. Since all-electric vehicles don’t produce any tailpipe emissions, many leaders outside the U.S. recognize the great potential for EVs to make air cleaner and safer – especially for children and the elderly in urban areas who are more vulnerable to air quality-related health impacts.

Fourth, car companies – both newcomers like Tesla and Faraday Future, and also incumbents like GM and BMW – have heavily invested in EVs and staked their part of their reputation on EVs succeeding. The U.S. vehicle market accounts for only a fifth of global vehicle sales and other regions with fast-growing vehicle markets, persistent air pollution problems, and a commitment to combat climate change will continue to generate demand for EVs. While U.S. momentum on fuel economy and EVs may well slow under President Trump, any automaker that considers itself a global player won’t be able to – or won’t want to – simply stop work on next-generation vehicles because the global demand for vehicles that are cheaper and cleaner to drive will persist.

Of course, to generate true mass appeal an EV’s sticker price needs to be at least competitive, if not less than, a comparable gasoline-powered vehicle. Today, the upfront cost of an EV in the U.S. is partially offset by the federal tax credit and any additional state tax credits. EVs are generally more expensive that a similar gasoline-powered vehicle because (a) EVs are not made at the same scale as conventional vehicles and (b) lithium-ion batteries remain somewhat costly to produce. So, as the global vehicle market demands more EVs and they are made at bigger scales, costs will come down to some extent.

But the larger potential cost reduction comes from reducing battery costs, which have fallen 70 percent in the last 18 months and which the National Academies of Science forecast to be cut in half by 2020. In addition, there could be more breakthroughs in battery chemistry research (also applicable to cell phone batteries and other electronics, which are driving investment in battery R&D too) that could make EV batteries even cheaper. These two factors have led some auto industry analysts to forecast that EVs will be cheaper to own than conventional cars by 2022.

But the electric vehicle market will thrive if the U.S. continues to lead the way

Given the rising global demand for vehicles that cut tailpipe emissions and the potential for battery costs to come down to the point at which an EV is either the same price or even cheaper than a similar gas vehicle, EVs will likely remain on a path to success under President Trump – even if he does his best to dismantle those pesky government regulations that protect our health and environment.

However, the optimist in me thinks the President can recognize the potential for the U.S. to seize the opportunity to be the leader in the emerging clean transportation economy and continue producing clean vehicles (and jobs) here at home.

There’s a strong case to be made for why EVs can and should be an American export. Tesla – an American company – may become a global leader in EV sales and will soon begin producing lithium-ion batteries from its “gigafactory” in Nevada. The Nissan LEAF, one of the most popular EVs for sale, is made in Smyrna, Tennessee along with its batteries. And General Motors has not been shy about investing in EVs, with its plug-in hybrid Chevy Volt and all-electric Chevy Bolt both coming from assembly lines in Michigan.

But foreign automakers are just as keen to win the race to electrify the global vehicle market. BMW, the VW conglomerate, and Chinese automaker BYD, for example, have all poured billions into EVs and would gladly become the primary supplier of EVs for households across the U.S.

Tesla’s are being made in Fremont, California, and their battery production is set to ramp up from the Tesla “gigafactory” in Nevada. Source Wikicommons.

Ultimately, the automaker that becomes the dominant EV supplier will likely be the one that operates in a supportive and stable policy environment. Under President Obama, domestic automakers were not only bailed out, but they were given great incentives to make the U.S. the global leader in clean transportation technology. Now it’s up to President Trump to decide whether to continue the hard won progress some U.S. auto companies (notably GM and Tesla) have made toward becoming the dominant EV exporter and leader, or become just another customer.

New Report Shows Electric Vehicle Technology Advancing Faster Than Anticipated

California’s influential Air Resources Board has just released a comprehensive assessment of the status of the state’s “Advanced Clean Car” regulations. While the report is not only about electric vehicles, the state’s Zero Emission Vehicle program is evaluated in detail. Overall, the findings are very positive on how California’s leadership on clean vehicle policy has spurred much of the auto industry to make new technologies available for consumers.

Electric vehicle technologies quickly moving forward

The 662-page report will take some time to digest, but the top line findings are clear: Electric vehicle technology is moving faster than was anticipated just 5 years ago. California leads the nation with over 250,000 EVs sold to date, and the number of plug-in vehicles is now approaching 30 models. The report cites many of factors that are accelerating the EV market, including dramatic improvements in battery performance and costs and the rapidly expanding charging infrastructure in California and the other states that have adopted the Zero Emission Vehicle regulation.

Stage is set to go further with clean car policies

The current pace of deployment also puts us on the road to increasing levels of EV adoption, displacing a growing amount of oil use and harmful emissions. One of the key recommendations in the report is that the Air Resources Board should move to adopt new ZEV standards to extend the current provisions which currently are set to plateau in 2025. The regulation will need to be strengthened to ensure that the state is on a trajectory to meeting both 2030 and later climate targets and the air quality standards in the state’s Central Valley and Los Angeles regions.

Strong signals needed to keep momentum

There are many positive signs for EVs. December 2016 set an all-time high for EV sales in the US, almost double the rate from a year ago. The introduction of the Chevy Bolt, the first long-range battery electric at a mass-market price has generated significant interest, as did Tesla’s announcement of its lower-cost Model 3.

However, not all automakers are shifting to clean technologies with the same effort. Some have zoomed ahead, like General Motors with plug-in cars making up over 5% of their new cars sold in California. On the other hand, several major car companies, like Honda and Fiat Chrysler, have done the bare minimum to comply with California regulations and almost nothing outside of the state. Therefore, the current Zero Emission Vehicle regulation needs to not only continue, but be strengthened. The report lays out the technical evidence for these conclusions.

#dieselgate, pt. II: Sergio’s Revenge

Today, the Environmental Protection Agency announced that Fiat-Chrysler (FCA) violated the Clean Air Act with sales of Ram 1500 and Jeep Grand Cherokee vehicles powered by diesel engines.  This falls on the heels of the Volkswagen (VW) diesel scandal.  The engine at question is FCA’s 3.0-liter “EcoDiesel”—which could turn out to be anything but.

What the allegations say

Since this is an ongoing investigation, there are still a number of unanswered questions.  Here is what EPA has alleged:

  • Fiat-Chrysler did not disclose to EPA that certain software affects the operation of the emissions controls devices found in the Ram 1500 and Jeep Grand Cherokee.
  • The software in question shuts off operation of the emissions control device. While this is allowed in extreme cases to protect the reliability and durability of the controls, EPA found numerous operating conditions that would fall into the category of “normal operation and use” and would therefore not be an allowable exception.
  • Taken together, these have the effect of a defeat device—this means that FCA could be liable for cheating federal emissions regulations and emitting smog-forming pollution well above the legal limit.

For his part, Sergio Marchionne, CEO of FCA, says that “there was zero intent on our side” to cheat on emissions regulations, calling such an idea “unadulterated hogwash” and noting that there’s “nothing in common between the VW reality and what we are describing here.”

According to the EPA, Ram 1500 pickups and Jeep Grand Cherokees powered by the 3.0-liter EcoDiesel engine contain software that may behave as a defeat device, releasing tons of excess smog-forming pollution that impacts public health. (Images courtesy of Motor Trend)

According to the EPA, Ram 1500 pickups and Jeep Grand Cherokees powered by the 3.0-liter EcoDiesel engine contain software that may behave as a defeat device, releasing tons of excess smog-forming pollution that negatively impacts public health. (Images courtesy of Motor Trend: Jeep Grand Cherokee and Ram 1500)

How does the sequel compare to the original?

FCA is correct to note that this is not quite the same thing as what VW did—in the case of VW, the software was explicitly tuned to alter operations dependent solely upon whether or not the vehicle was undergoing a test procedure.  The software at question in the Ram 1500 and Jeep Grand Cherokee is more subtle—the emissions control devices remain fully operational during lab tests and are turned off during some typical on-road driving situations, but at question is whether or not these situations are narrow enough to fall within the exceptions allowed to protect the durability and reliability of the engine and its emissions control systems.  Because the types of situations are so broadly typical of routine driving behavior, these undisclosed shutdown modes were enough to raise a few eyebrows, particularly when considered in tandem.

How do the emissions controls work in the 2014-2016 EcoDiesel Jeep/Ram trucks?

The emissions control system in the Jeep/Ram trucks relies upon two separate systems working together to reduce formation of nitrogen oxides (NOx), one of the key ingredients in the formation of smog: exhaust gas recirculation (EGR), which recirculates exhaust gas back into the engine to reduce the formation of NOx; and selective catalytic reduction (SCR), which activates a fluid which reacts to chemically reduce NOx after its formed.

When one of those systems is turned off, the other can often compensate for a short amount of time.  For reasons related to durability of the engine and/or the controls system, there are narrow operating conditions where such shut-off is allowed.  However, such operation must be disclosed to EPA (which EPA alleges FCA did not do), and it must fall within a narrow band of operating conditions.  Key here is that there were a number of situations identified by EPA where both systems would be simultaneously either turned off or reduced in effectiveness—this means that the emissions system would be compromised, regularly emitting excess NOx emissions during normal vehicle operation and use.  Such conditions would not be generated when the vehicle was tested for emissions, which is another part of the reason this would have the effect of a “defeat device”.

In addition to the EPA allegations, a lawsuit was filed against FCA in December for the same vehicles by consumers who bought these vehicles in part because of the “Eco” and “clean diesel” marketing around them.  Accompanying that lawsuit was data from on-road emissions tests which showed average emissions of around 4-5 times the legal limit measured during real-world driving of a Ram 1500 EcoDiesel, with spikes in NOx as high as 40 times the certified level.

What are the potential health and emissions impacts?

Because of the shortage of details, it is impossible to know the full impact this scandal will have on emissions and public health.  Still, there are a few reasons why the problem here is likely not as severe as the VW scandal.

The affected vehicles by this allegation have only been available since model year (MY) 2014, which means regulators can address this problem much more quickly than the VW scandal, minimizing the impact they have on the environment.  The average vehicle identified here is likely to have traveled just half the mileage of those affected in the VW scandal, on average.  Perhaps most importantly, it also appears that the levels of excess emissions generated by the vehicles in question are likely significantly less than many of those included in the VW scandal—the data provided in the lawsuit shows that excess emissions from these vehicles could be around one-third that of the VW diesel cars, at the tailpipe.  And in total, the MY2014-2016 EcoDiesel Ram 1500 and Jeep Grand Cherokee amount to about one-fifth the sales of the VW diesels covered under “dieselgate”.  Taken all together, the impact from this could thus be roughly a few percent that of the Volkswagen scandal.

While that may not sound like a lot, these software cheats could have helped contribute to at least a handful of premature deaths and increased hospitalizations from air pollution-related cardiovascular distress.  Aside from the significant damage to public health and the environment, cleaning up this mess will also likely require tens, if not hundreds, of millions of dollars in remediation—hopefully payable by FCA and not the taxpayer.

Is there any good news on the horizon?

Another scandal like this is obviously terrible for the American people, especially those near congested roadways.  It is also not great for automakers looking to more efficient diesel engines to meet vehicle efficiency regulations set out to 2025.

Like the VW problem, this scandal will not be easy to fix.  While FCA believes it can address the issue solely via software updates and has offered to do so, VW said the same thing about its 3.0L diesel engines, and we are still waiting for an approved fix for those vehicles.

EPA is rightly utilizing more real-world emissions testing to complement its lab tests, and similarly subtle emissions violations by other automakers could yet be uncovered.  Given how complex and nuanced this investigation’s outcomes, it is possible there could be additional inquiries into other manufacturers—Mercedes, for example, has already been under investigation for similar software.

With the next administration getting ready to take office, it will be important that EPA continue to protect the public health and well-being of the American public by remaining vigilant against automakers, maintaining a level playing field where all are held equally accountable for their actions.

EPA (Correctly) Affirms Vehicle Standards, Despite Automaker Misinformation

EPA finalized its determination today that the current light-duty vehicle global warming emissions standards for 2022-2025 are appropriate. This adjudication affirms what we have said all along—manufacturers are currently ahead of schedule on the first round of standards (2012-2016) and continue to show the many pathways to cost-effectively meeting future standards.

This is a big affirmation for both consumers and the country as a whole:

To date, our analysis shows that the standards have saved consumers more than $34 billion in fuel. By 2030, this number will grow to $450 billion, even after taking into account costs for the technology used to drive those fuel economy improvements.

At the same time, we’ve avoided over 130 million metric tons of global warming emissions. The standards are working for consumers and the environment—there’s no reason to tap the brakes on that progress.

And for all their whining about wanting to weaken the standards, the automakers themselves have provided data that shows exactly why we shouldn’t.

Automaker data shows 2012-2016 compliance was easier, cheaper than expected

As I wrote about when the proposal was released, this decision is more than four years in the making and is backed up by a tremendous amount of benchmarking, modeling, and analysis. The large body of evidence gathered continues to point to new and innovative pathways that would allow manufacturers to not just meet but exceed the standards on the books—and each new data point confirms that fact.

In fact, the automakers themselves submitted data showing just how little technology they are actually applying to their vehicles in order to meet today’s standards, with much lower penetrations of complex/expensive technologies than originally anticipated.

 Comments by the Alliance for Automobile Manufacturers)

The 2012-2016 Final Rule (FR) on which automakers initially signed off envisioned a much higher penetration of more costly technologies would be needed (dashed red lines). However, manufacturers have shown innovative new ways to improve upon cheaper technologies as they overachieve on those standards (orange bars), leaving plenty of cost-effective technologies available for deployment out to 2025. (Source: Comments by the Alliance for Automobile Manufacturers, Attachment 2, pp. 40-43)

Outpacing expectations, they have been able to continue to exceed the standards with even lower cost technologies thanks to investments resulting from the need to meet strong standards. This innovation has generated numerous new technology pathways such as high-compression engines like Mazda’s SkyActiv and 48V mild hybridization—though those technologies are not yet deployed at large scale. This leaves ample room to continue reducing emissions beyond the current 2025 standards with gasoline-powered engines.

As a colleague of mine likes to say, “While automakers continue to pull the lowest hanging fruit, innovation means that the tree is constantly growing new low-hanging fruit.” This is why historically industry has continued to overstate the costs of regulation.

Automaker data shows that 2025 standards can be met through gasoline-powered vehicles

Additionally, while the auto companies claim on one hand that more electrification and other pricier technologies will be needed to comply in the future, their own analysis shows that they can comply through the broad deployment of advanced gasoline-powered vehicles.

 Comments by the Alliance of Automobile Manufacturers

Analysis submitted by the automakers shows that vehicles in 2025 can meet the standards through the deployment of turbocharged (TC), spark-ignited (SI) gasoline engines, complemented by advanced transmissions (HRST) and stop-start (SS). Note the very low penetrations of electrification required. Source: Comments by the Alliance of Automobile Manufacturers, Attachment 1, p. 74)

These gasoline-powered vehicles will be substantially more efficient than today, incorporating advancements such as 48V mild hybridization, which allows for efficient electric boosting of smaller engines and improved efficiency of accessories; high-compression engines running on thermodynamic cycles that are more efficient; dynamic cylinder deactivation that can downsize the engine in real-time to provide the right amount of power at the right time; more efficient transmissions that keep the engine operating at its most efficient point more frequently; and reductions in road load such as improved aerodynamics and low-rolling resistance tires to help reduce the amount of energy needed to drive the vehicle in the first place.

Investments in those technologies are buoyed by the certainty of the strong standards which EPA today affirmed, as noted by automakers: “By extending the standards for many years into the future, the agencies provide manufacturers with substantial lead-time, which is of great value in compliance planning.”

Meeting 2025 standards is no problem for automakers, which is why EPA held firm

All of this is to state the obvious: the automakers themselves show that the 2025 standards are achievable, which is part of why EPA has affirmed the standards set in 2012. So in the inevitable onslaught of automaker whining that will surely follow this announcement, remember this:

  • Automakers signed on to these standards with much hullabaloo when they were finalized;
  • Automakers are currently ahead of the game, deploying efficient technologies at reduced costs compared to original estimates of compliance;
  • Automaker data submitted in the four years hence continues to show that those 2025 standards are achievable with conventional gasoline-powered vehicles (thanks to the continued investment in and deployment of fuel consumption reduction technologies); and
  • Consumers and the environment stand to benefit tremendously by leaving these cost-effective standards in place.

EPA’s decision today confirms that the data is in and crystal clear: the 2022-2025 standards put on the books in 2012 remain feasible for manufacturers and will provide significant benefits for the country and the environment.

What Electric Vehicle Sales in 2016 Mean for the Future of Transportation

I’m a fan of electric vehicles. As I’ve noted, they can be a smart and flexible option to help the grid accommodate variable energy resources like wind and solar. And EVs are the option likely to have the most success at decarbonizing transportation.

I’ve noted that the claim “The only way to do X is Y” is probably incorrect. I expect EVs to become the best way to get transportation CO2 emissions to zero for most applications, but not the only way. Hydrogen fuel cells, cellulosic biofuels, and liquid fuels produced by renewable electricity also exist. Maybe we will use some of these technologies for specific applications. But it is my estimate that EVs will achieve the greatest reductions in transportation carbon emissions.

UCS has shown under the current electricity system, EVs reduce emissions compared to the average gasoline car in all parts of the country, even when considering manufacturing impacts. In most of the country they beat the best gasoline cars. That analysis uses the 2015 version of EPA’s eGRID database, which actually only includes data through 2012. The grid has gotten considerably cleaner even in the past few years.

The grid impact

So, theoretically, what would happen if all light-duty vehicles were EVs?

As a back-of-the-envelope calculation, that would be about a 25% increase in electricity demand. Light-duty vehicles account for about 3 trillion vehicle-miles per year in the United States. EVs get roughly 3 miles per kilowatt-hour. We would need an additional 1 trillion kWh of electricity. The U.S. currently uses about 4 trillion kilowatt-hours per year; an additional 1 trillion kWh represents a 25% increase.

US cars and light trucks produced just over one billion metric tons of CO2 in 2014, or about 20% of all U.S. energy-related CO2 emissions. In 2015, US power plants produced 1,925 million metric tons of CO2 while producing 3,931 billion kWh, for an emissions rate of about 0.5 tons per thousand kWh. The additional trillion kWh for the EVs would result in 500 million tons of emissions, or about half of what light-duty vehicles emit today, for a 10% reduction in energy-related CO2 emissions. That estimate applies if EVs are charged by the grid of today. It does not account for the fact that the grid is getting cleaner through existing market forces and policy actions, nor the ways that EVs can specifically help the grid accommodate greater use of variable renewables, nor actions such as buying green power or using a “green charging” algorithm.

Scenarios of EV market growth

It will be a while before EVs represent even 10% of vehicles, let alone 100%. EV sales were about 0.9% of new car sales in the US in 2016, up from about 0.7% in 2015. With somewhat over half a million sold during the period 2012-2016, EVs are currently about 0.3% of cars on the road.

Sounds small?  Well, compound growth is an amazing thing.  Continuing the 2012-2016 growth rate of 32% per year would put EVs at 10% of all new car sales by 2025, and about 40% by 2030.

Now, that might be a stretch.  It’s too short a time to extrapolate from, and technology diffusion tends to follow an S-shaped “logistic function” rather than a constant growth rate. Still, even with lower growth rates, existing targets are achievable.

The eight states that have signed the Zero Emission Vehicle Memorandum have a combined goal of 3.3 million vehicles on the road by 2025 (and all new vehicles being zero-emission by 2050). I expect that most of these will be EVs, although some may be other technologies. These states represent about a quarter of the US population. If the ZEV states meet their goal, and the other states with three times as many people deploy only half as many EVs, that would be 5 million EVs by 2025.  This would represent roughly 2% of all vehicles on the road in the US, and possibly 5% of new car sales in that year.

US EV sales would need to grow at a rate of 25% per year over 2016-2025 to hit 5 million cumulative sales in 2025 (sales in that year would be 1 million). As shown below, 2016 represented a 37% increase in EV sales over 2015 (the 2012-2016 period saw 32% annual growth).

ev-2016

EV sales in 2016 were up 37% over 2015. Source: Inside EVs.

Two paths

Assuming we hit 2025’s targets, what would happen next? One of two things.

Maybe the market keeps growing. In UCS’s “Half the Oil” report, we present a scenario in which California meets its Zero Emission Vehicle (ZEV) requirements, with 16% of new vehicles being ZEV by 2025. With further growth beyond that, ZEVs would reach 28-36% of light-duty vehicles in California in 2030. This Hawaii-specific study similarly forecasts a “high” case of about 33% of new car sales being EVs by 2030. Other studies feature even faster diffusion.

Or, vehicle sales might fall dramatically. If shared autonomous vehicles become the norm, far fewer vehicles would be needed. At any one time, no more than about 13% of cars are on the road. You might think you still need one car per person for rush hour, but 1) our number of commuters is less than half our number of vehicles; and, 2) these commutes are spread around a fairly broad time and are typically under half an hour. So one vehicle can support several commutes, even before you consider ridesharing. EVs could be grabbing a larger share of a shrinking market – at least in the countries that currently feature widespread car ownership.

Which way will the future take us? Photos from Mercedes-Benz and Wikimedia.

Which way will the future take us? Photos from Mercedes-Benz and Wikimedia.

Considering the progress from Google, Tesla, Apple, and others, full autonomy may be technologically possible by 2020. Regulations would take another few years to catch up. Granted, autonomous vehicles could be privately owned; the degree to which people choose to switch from owning vehicles to buying “transportation as a service” is uncertain. Still, the prospect of shared autonomous vehicles is why I think projections beyond 2030 are especially difficult.

Our transportation system might look much, much different.

Self-Driving Cars in 2017: Navigating the Promises and Pitfalls

I’ve been thinking a lot about self-driving cars lately—and I’m not the only one. Predictions abound about when the technology will be fully ready, but these vehicles are already out there being tested on public roads. In fact, I’m lucky if a week goes by and I don’t see a car with a spinning roof top sensor—even my first-grader is pretty good at spotting them. I live in San Francisco and have already seen a couple of Uber’s self-driving Volvos plying the streets over the past week. I’ve been seeing Chevy Bolts too—presumably being tested by Cruise Automotive. The race for self-driving cars amongst the tech and auto industry is clearly game on and is likely to heat up in 2017.

The Consumer Electronics Show (CES 2017) is the first week in January in Las Vegas and will set the stage for 2017. Once again it appears that self-driving tech is going to be a hot topic with both major and upstart automakers as well as technology providers looking to reveal new products. Fiat Chrysler of America—a laggard in recent EV market analysis—is expected to announce a full electric vehicle at CES, building on the recent release of the plug-in hybrid Pacific minivan.  They’ve also partnered with Google’s self-driving business Waymo and are reportedly delivering 100 Pacificas for autonomous vehicle testing. Nissan CEO Carlo Ghosn is giving a keynote, Hyundai is expected to give rides in a self-driving Ioniq, and Faraday Future has been building anticipation around its CES announcement with numerous teasers. I’m taking the trip to Vegas this year to see what all the hype is about.

image002And no doubt there is a lot of hype. Personally, I’m hopeful about the potential for self-driving technology. I’m lucky enough to do a lot of my daily trips by bicycle with my kids in tow. And I’ve seen enough close calls to always expect the unexpected—but we all know even extra vigilance can’t guarantee 100 percent safety. So wouldn’t it be great if every car actually used their turn signal, or gave 3 feet when passing bicyclists that the law requires, or eliminated the dangers of distracted driving?

But I’m also leery about how these vehicles might cause confusion and disruption. Will their behavior be predictable in the same way as a driver’s? When I get to a stop sign in a car or on a bike, all it takes is a head nod or a hand wave and everyone can pass smoothly through a four-way stop. What happens when some vehicles don’t have drivers? When I walk across the street, I always tell my kids to make eye contact with the driver before they cross to make sure they see them. Now what? With driverless cars, the rules of the road might not change, but the norms will.  Once these vehicles truly hit the streets it’s going to be important to make sure not only that the vehicles operate safely but that those they interact with—from pedestrians, to cyclists, to other motorists and any other public road users—adapt to this new technology as well. And as Brian Wiedenmeier of the SF bicycle Coalition pointed out after a self-driving Uber twice made an illegal right hand turn across a bike lane, just following the rules of the road at this point seems to be a challenge.

Self-driving car technology may be able to make our roads safer, but building the public’s trust in the technology will be important to its acceptance. Uber’s decision this past week to defy an order to comply with self-driving car registration requirements was disappointing, to say the least. In its statement Uber seemed to argue that California’s registration requirements, which 20 companies have already complied with, are too onerous and would stall innovation. Instead of complying with this public safety law (and paying the $150 application fee) in exchange for allowing the company to use public roadways as a laboratory to test their technology, Uber chose to lawyer up. This doesn’t bode well for building trust. And if Uber does succeed in skirting the law, transparency will also be undermined, as reporting on incidents related to the safe operation of the vehicle would no longer be required.

Cooperation between government and industry in deploying self-driving cars is going to be hugely important to build confidence in the technology both by policy makers and the public. And the technology isn’t just about the safety of our roads—though that would be enough of a reason for cooperation. Other areas where these vehicles could have profound impacts include energy, pollution, impacts on public transit, congestion, and labor and workforce concerns—and whether the impacts are positive or negative is yet to be seen. On climate emissions alone, various studies show a wide range of possible outcomes as a result of deploying self-driving cars, from doubling of emissions to cutting them by 50 percent or more. There’s a lot at stake.

These issues are sure to heat up in 2017, as more vehicles are tested on public roads, new research points to the positive and negative outcomes possible with self-driving cars, and policy makers at the local, state and federal level start to consider the actions they can take to ensure companies advance this technology responsibly and steer outcomes toward societal good. Additional accidents involving self-driving cars are sure to bring more scrutiny to the technology as well as the protocols and protections being in put into place by companies and government agencies. UCS will also be taking a closer look at the implications of wide-spread deployment of AVs and ways to ensure they deliver on the promises and avoid the pitfalls.  So stay tuned.

When will self-driving cars be ready for prime-time? Not sure, but 2017 will no doubt be a year for  increased attention, debate, research—and yes—hype around cars that can drive themselves.

 

‘Little’ errors add up: What an electric vehicles study gets right, and what it gets wrong

A new study by consulting firm Arthur D. Little (ADL) claims that the benefits of electric cars, both environmental and economic, are lower than others, including UCS, have shown. However, the differences are largely due to questionable assumptions about battery replacements and the use of electric vehicles as a gasoline car replacement.

What they get right

EVs on average have lower overall greenhouse gas emissions and lower costs to fuel than gasoline cars now, and these benefits are likely to increase over time. This is the conclusion of our report and also the ADL analysis. In our report, “Cleaner Cars from Cradle to Grave”, we found that the average electric vehicle results in about half the climate changing emissions than a comparable gasoline car, even when the manufacturing emissions are included. The ADL study finds a lower benefit, about 20 percent, due to assumptions discussed below. However, they also note that the emissions savings will likely grow over time as electricity generation becomes cleaner, consistent with our findings.

What they get wrong about emissions

The ADL analysis and the UCS analysis of greenhouse gas emissions is largely the same except for two factors: battery replacement and the need for a replacement gasoline car to accompany the electric car. These two factors account for nearly 40 percent of the ADL estimate of emissions from a battery electric car and therefore are critical to understanding the benefits of electric vehicles.

The ADL study assumes that all EVs will need a replacement battery after seven to ten years of use. The study cites the fact that “this is consistent with the warranty that BEV manufacturers offer on their vehicles’ battery packs” to bolster this claim. However, by analogy, gasoline cars would be expected to need a new engine and/or transmission after the expiration of a five-year powertrain warranty. We don’t know what the true lifetime and failure rate for electric car batteries are, especially for today’s second generation battery systems since they’ve only been on the market for a few years. But assuming a battery replacement at 7-10 years is a 100 percent failure rate for the battery system. Making this assumption would require some proof, and yet there’s no evidence that this is the case for battery lifetime.

The largest factor inflating the ADL estimates of emissions is the assertion that drivers of electric vehicles would require a replacement gasoline car for about a quarter of all miles driven, because electric vehicles are driven fewer miles per year than gasoline cars. This questionable assumption is critical to the lower electric car benefits seen in the ADL report: it increases their emission estimates from an electric vehicle like the Nissan LEAF by 28 tons, while the baseline estimate of  LEAF manufacturing and electricity use only totals 69 tons.

The ADL study chooses an unlikely scenario — that an EV buyer would purchase a vehicle that covers only 75 percent of their trips — to arrive at their emissions estimate, rather than doing a straight up mile for mile comparison. This argument is based primarily on early electric vehicle use data from Idaho National Laboratory that showed Nissan LEAF drivers drove on average 9,700 miles per year, while gasoline cars average around 12,000 miles per year. But since that data was collected, charging infrastructure has improved and electric car drivers are going farther. Per California Air Resources Board data, drivers of 2013 and 2014 Nissan LEAFs are going an average of 11,000 miles per year. But perhaps more important, it looks like at least some of the lower mileage in electric cars is not due to the technology, but instead the lease terms that many electric car buyers choose. Auto companies have offered very attractive low-mileage lease terms for electric vehicles, with 10,000 – 12,000 miles per year included in the lease contract. Nissan LEAF drivers that chose a 12,000 mile or lower lease drove on average 9,000 miles per year, while those on a 15,000 mile lease drove over 12,000 miles per year on average. If the lower annual driving for an electric vehicle is not due to technical limitations, then there is no basis for adding gasoline vehicle use to the emissions analysis of electric cars.

However, even if electric cars were being driven fewer miles, the assumption that additional gasoline miles would be needed is biased. Drivers will choose electric cars with a range and capability that meets their travel needs. Someone who requires the ability to regularly drive long distances without refueling is unlikely to choose a short-range battery electric car as a replacement for a gasoline car. That’s not to say that they couldn’t drive electric; however, they would likely choose a longer-range electric vehicle. The comparison chosen in the ADL study overestimates emissions from assumptions about the behavior of the drivers, not the actual emissions from making or using the vehicles.

What they get wrong about costs

While our report focused on the climate-changing emissions from cars, the ADL study also attempts to estimate the difference in costs between electric and gasoline cars. The same choices (100% battery replacement rate and the need for a rental gasoline car) that inflated the emissions estimates also have a large impact on the economic estimates. For example, the cost of the rental gasoline car to make up for miles driven below the national average adds over $10,000 to the ADL estimate of the lifetime electric car cost and adds over 15 percent to the cost estimate. As noted above, these costs are unlikely to occur because a consumer who needs to rent a car 25 percent of the time is not likely to choose a short range EV to begin with.

The next generation of electric cars will be even better

The next generation of electric cars are already starting to show up on dealership lots. Starting with the Chevy Bolt, there are likely to be several battery electric cars that combine longer range, the ability to quickly recharge, and at a more affordable price. These features will make it cheaper to use an electric car and also allow displacement of even more miles that are currently driven using gasoline. Combined with cleaner sources of power, electric cars will likely show even more benefits in the future compared to gasoline vehicles.

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