UCS Blog - The Equation, Clean Vehicles

Massachusetts Senate Unanimously Endorses a Bold Vision for Clean Transportation

Photo: Eric Kilby/Flickr

The Massachusetts Senate yesterday unanimously passed an energy bill that promises to dramatically reshape the vehicles and fuels that power our transportation system.

If enacted, this legislation would make Massachusetts a national and even global leader in the deployment of electric vehicle technology. It would dramatically reduce our consumption of oil, and the pollution that comes from petroleum. It would save lives by significantly improving air quality, especially in urban areas. It would produce a stronger and more resilient modern grid that will provide ratepayers with greater efficiency and reliability. And it would produce long-term cost savings for Massachusetts drivers and transit agencies.

And I’m just talking about the provisions related to transportation. (See here for more about the provisions related to renewable energy and storage, en espanol aqui.)  But even a focus on just the implications for the transportation sector is meaty enough. Here’s why this bill is taking on transportation emissions and what the bill would do.

Transportation and climate goals

Let me start with a little background on transportation and Massachusetts climate policy.

Under Massachusetts climate law (the Global Warming Solutions Act or “GWSA”), the state is required to achieve significant reductions in economy-wide global warming emissions. When it comes to emissions from electricity, we’re making remarkable progress: over the past decade Massachusetts has cut our emissions from electricity impressively, thanks in part to a strong set of policies, including our investments in energy efficiency and our participation in the Regional Greenhouse Gas Initiative (or “RGGI”).

But when it comes to transportation, things have been more difficult. Improving vehicle efficiency standards have helped reduce emissions some since 2008, but the gains in efficiency have been partially offset by increases in total driving and increasing purchases of SUVs and light trucks. Electric vehicles are a technology with extraordinary promise but still represent only about 2 percent of new vehicle sales. The state has committed to putting 300,000 electric vehicles on the road by 2025, but we have a ways to go to achieve that goal.

Overall, transportation emissions are about the same as they were in 1990, and transportation now represents the largest source of pollution in Massachusetts, including over 40% of global warming emissions.

What would this bill do?

The Senate bill would accelerate the rapid electrification of our transportation system, while taking steps to ensure that all residents of Massachusetts benefit from electric vehicle technology.

To start with, the Senate bill envisions the end of diesel fuel in our public transportation system. Heavy duty diesel engines are some of the dirtiest vehicles on the road, contributing significantly to urban air pollution that causes asthma and other respiratory problems. Existing technologies such as electric buses have zero tail pipe emissions and can reduce global warming emissions from diesel equivalents nearly 80 percent on today’s grid. The bill would require the Department of Transportation to replace all diesel engines with zero-emission vehicles in its bus, commuter rail, and marine fleet. This would build on recent announcements in California and New York City to electrify their vehicle fleets.

The bill would also require the Department of Transportation to enact policies that would ensure that 25% of all vehicles on the road are electric by 2026. This would represent a major increase from current levels, as electric vehicles are currently about 2 percent of new vehicles sold in Massachusetts. Achieving sales at those rates will require policies that are strong enough to make electric vehicles affordable for low- and moderate-income residents, in addition to building the infrastructure necessary to keep EVs charged.

As we build out our electric vehicle infrastructure, it’s going to be important for us to also think about the impact of EV charging on our electric grid.  Another important provision of this legislation would require utilities to offer rates that reward electric vehicle drivers for charging their vehicles at night, when electricity use is low. These “time of use” rates can lead to big savings not only for electric vehicle drivers, but for all ratepayers.

The critical role of market-based programs

The Senate bill not only sets out big goals, it also identifies a way to pay for the investments that we need in clean transportation: by requiring the state to establish a market-based program to reduce emissions from transportation fuels (as well as heating fuels).

Under RGGI, Massachusetts and the other states of the Northeast have placed a limit on emissions from power plants. This limit is enforced by a requirement that power plant operators purchase allowances that are sold in regional auctions. By limiting the number of allowances available, RGGI ensures overall emission reductions. Meanwhile, the sale of allowances raises money that is invested in efficiency and renewable energy.

This “cap and invest” model has proven effective in reducing emissions from electricity—and beyond. While RGGI only applies to electricity, other jurisdictions, including California, Ontario and Quebec, have expanded this model into heating and transportation fuels and the result has been billions in new investments in clean transportation. California alone is projected to spend over $2 billion on clean transportation investments this year – money that is going to expanded electric vehicle incentives, electric buses, improved transit services, and more affordable housing near transit.

If Massachusetts adopted a program similar to the California-Ontario-Quebec model, it could raise over $450 million per year in investments in clean transportation. That would be enough to not only make a major new investment in electric vehicles, but also to address critical issues facing our Commonwealth such as public transportation and affordable housing.

The path ahead

With the Senate promising bold action to accelerate the electrification of transportation, the action now turns towards the House of Representatives. The House has shown interest in promoting electric vehicles this session, including a good bill from Rep. Tom Golden, chair of the energy committee, that would encourage car dealers to sell electric vehicles.

One big question is whether legislators in both chambers agree on a sustainable and dedicated source of funding for investments in clean transportation. Too often, the policies we use to promote electric vehicles are based on one-time infusions of funds, such as the $12 million that Gov. Charlie Baker committed to the state’s main electric vehicle incentive in December 2016. The problem with one-time cash infusions is that they expire: the state is now running out of funds and may have to cut back on their rebate program.

The senate’s proposals in that regard—and the many other good transportation provisions in last night’s bill—are welcome indeed.

Eric Kilby

Will Chevron Show Leadership in Climate Solutions? Notes From the 2018 Shareholders’ Meeting

Photo: ArtBrom/Flickr

Last week, I joined the Union of Concerned Scientists at the Chevron shareholders’ meeting in San Ramon, CA. We were there to ask why Chevron leadership, and shareholders, have not pushed for more meaningful action to meet global emissions targets that would keep climate warming well below 2 degrees celsius.

The security to get into Chevron Headquarters in San Ramon was tight – more significant than your typical airport security. In addition to multiple steps of checking of our passes to enter and walking through metal detectors, we were only able to bring in paper and pen, and each of our papers were shuffled through and inspected on the way in. Once seated, we listened to the presentations by the company’s Chair and CEO and by shareholders advocating proposals on environmental, social, and governance issues. During this time, shareholders followed the Board’s recommendation to reject proposals to “transition to a low carbon business model” and improve lobbying disclosures, among other things.

During much of the meeting, I was scribbling down notes and adapting my prepared statement based upon what I was hearing. I also spent some time staring into this infographic that was provided in the Chevron Climate Resiliency Report (data from IEA 2015 World Balance and Final Consumption Report 2015):

This diagram highlights the flow of energy — the width of the bars reflects the relative size of the production/consumption budget — in our current fossil-fuel focused energy system. This diagram allows you to watch the flow of energy towards different areas of our economy that utilize that source. One remarkable aspect of this data, which is pointed out in the Climate Change Resilience Report, is that “about 25% of global oil consumption is used in personal vehicles” (to see this, follow the bar from “oil”, to “transport”, and then to “passenger”). This means every day that we drive in our personal vehicles we are making choices about fossil fuel emissions that add up to something very significant. I was struck by this statistic because it underscores something that I frequently address in my public talks about climate change: personal, individual action is one piece of the puzzle in solving the climate problem. But there are other pieces of the puzzle – government leadership and corporate accountability which I address again below.

At the end of the scheduled shareholder proposals, it was time for the lottery of Q&A. Each of us who had a question or statement had to get a numbered ticket; tickets were pulled randomly and there was no guarantee that all questions would be heard. In total, about a dozen people asked questions or made statements to the Chairman. Of these, almost all of them were on three topics: climate change, human rights, and an ongoing lawsuit with the people of Ecuador due to a decades old environmental disaster.

Here was my statement and question when my number was called:

Good morning Mr. Chairman, members of the Board, and Stakeholders. Your recent Climate Change Resilience report was a step toward responding to investor demands that you disclose your plans for operating in a world where global temperature increase is kept well below two degrees Celsius. However, your company emphasizes potential conflicts rather than synergies between climate solutions and other societal goals and dismisses a rapid transformation of our energy system as “unlikely.”

I am a scientist here in Northern California. One of the areas of my research focuses on the impact of rising carbon dioxide concentrations on the changing chemistry of the ocean. I collaborate with businesses along the coast that are deeply concerned about the impacts of rising carbon dioxide on their financial future. Specifically, rising carbon dioxide concentrations threaten a key part of our history, culture and economy of California – sustainable harvests of food from the sea. As a scientist, I understand the grave risks we are facing without deep reductions in emissions and know that swift action is precisely what is needed to avoid the worst effects of climate change.

You stated this morning, and you describe in the Climate Resilience Report, that a first principle that guides your views on climate change is that “reducing greenhouse gas emissions is a global issue that requires global engagement and action”. Yet, in this report you bet against our ability to tackle meaningful energy transformation. When will Chevron show greater ambition to keep global warming below 2 degrees C?

In his answer, Chair and CEO Michael Wirth was respectful, and thanked me for my work in the scientific community. He explained that the company simply “meets the demands of energy used by people around the world,” and that it does “look at low carbon scenarios” as part of its business plan. However, Mr. Wirth argued that global policies are needed – ones that would require government intervention – and that it isn’t the role of individual companies to make decisions on this matter. This was an interesting answer because it spelled out something that Chevron doesn’t say directly in its public report – the company isn’t planning on taking leadership on climate change until governments lead the way. Which is hard to imagine, since fossil fuel companies spend millions every year lobbying our government to support policies that promote the use of oil and gas.

Why does this matter – and why would a climate scientist attend a Chevron shareholders’ meeting? I pondered this quite a bit when I was asked to join the UCS team for the meeting that day. For me, the decision came down to three things. First, because I am asking Chevron to use the best available science to make decisions for our future. Was a being an ‘advocate’ – yes – I am advocating for the use of science in decision making. Second, because I have made a commitment to not just communicate with those who already agree with me. We need to be able to put ourselves in situations where we work to find common ground and similar values with people in many different communities. Finally, as I’ve discussed above, I think individual responsibility is an aspect of the problem – people need to feel emboldened to make their own decisions that place our planet on a better path. But individuals can’t solve this problem alone: corporate accountability is important here. We need to be asking more of corporations that contribute significantly to our greenhouse gas burden. If they contribute significantly to the problem, they should be contributing significantly to the solution.


Dr. Tessa Hill is a Professor and Chancellor’s Fellow at University of California, Davis, in the Department of Earth & Planetary Sciences. She is resident at UC Davis Bodega Marine Laboratory, a research station on the Northern California Coast. She is part of the Bodega Ocean Acidification Research (BOAR) group at Bodega Marine Laboratory, which aims to understand the impact of ocean acidification on marine species. Tessa leads an industry-academic partnership to understand the consequences of ocean acidification on shellfish farmers. Tessa is a Fellow of the California Academy of Sciences, a AAAS Leshner Public Engagement Fellow, and a recipient of the Presidential Early Career Award for Scientists & Engineers (PECASE).

Our Latest Automaker Rankings: What The Industry Needs to do to Keep Moving Forward

Every few years, UCS takes a look at the auto industry’s emission reduction progress as part of our Automaker Rankings series of reports. This year’s analysis, based on model year (MY) 2017 vehicles, shows that the industry has once again reached the lowest levels yet in both smog-forming and global warming emissions from new vehicles, despite the fact that many off-the-shelf technologies are deployed in less than one-third of all new vehicles.  Unfortunately, this record-setting trend in progress also shows some indications of slowing down, with Ford and Hyundai-Kia showing no progress towards reducing global warming emissions, and Toyota actually moving backwards.

At the same time, the industry spearheaded an effort to re-litigate fuel economy and emissions standards set through 2025, and this report comes out while a proposal from the current administration responding to their request that would completely halt progress in the industry at 2020 levels sits awaiting public release. Therefore, while this year’s Automaker Rankings highlights some of the progress made by leaders in the industry to move forward on the technology front, it’s also critical that on the political front these companies stand up to the administration to ensure the rest of the industry continues to move forward on reducing emissions.

The technology to meet future standards is out there

For me, one of the key takeaways I had from this report is that while standards have in many cases accelerated the deployment of new technologies, some of the most cost-effective strategies to reduce emissions are still sitting on the shelf. The industry’s progress to-date is barely a glimpse of where gasoline-powered vehicles could be in the future as shown in the figure below.

While vehicle standards have led to significant growth in a number of technologies, even many of the most cost-effective technologies to lower emissions have been deployed in only a small fraction of the fleet, leaving plenty of room for further reductions.

On top of this, many of the deployed technologies, like advanced transmissions, still have significant incremental progress that can be made. We’re also seeing novel developments in other technologies like start-stop, where we are beginning in 2018 to see the deployment of higher-voltage (48V) systems that can result in complementary technology such as electric boost and again continue to push out the horizon for combustion engine improvements. For this and many other reasons, it’s baffling to see the industry assert that meeting 2025 vehicle standards requires widespread vehicle electrification.

No more Greenest Automaker

Of course, electric vehicles are one of the reasons for a key difference in this year’s report: we are now including the results of all automakers, not just those largest companies who sell vehicles of all sizes and types. A lot of the development for some of the technologies that could pave the way to a lower-emissions future are coming from some of the smallest manufacturers, whether that’s Tesla’s all-electric fleet or Mazda’s SkyActiv-X spark-assisted charge compression engine, which looks to bring diesel-like operation to a gasoline engine. Ignoring this leadership from smaller automakers would be ignoring some of the most forward-looking technology deployment in the industry.

Additionally, it’s important to recognize that this report is limited to the emissions of the vehicles sold by manufacturers—it does not consider other aspects of operations which also affect the sustainability and “greenness” of a company, whether that’s related to water use at its facilities, renewable power sourcing, or other aspects of the manufacture and distribution of a manufacturer’s fleet.

Considering these two central limitations, we have decided to no longer award a “Greenest Automaker.”  It’s important to recognize the wide difference between the emissions from the fleet of Honda, who has again asserted its leadership to provide the lowest emission fleet from full-line automakers, and Fiat Chrysler, who finds itself producing a fleet better only than McLaren, Ferrari, and Aston Martin—automakers who produce only exotic sports cars meant more for a track than a highway—but that is only part of the story.

The gap between leaders and laggards is huge and pervades all vehicle classes

One of the reasons we have previously ignored small manufacturers is that they provide a narrow spectrum of vehicles—and it’s been a historic complaint from companies like Ford that they should get a pass because people want big trucks. But one of the key findings from this year is that the Detroit Three fall to the bottom of the pack not because they sell big trucks, but because in virtually all classes of vehicles they sell, their cars and trucks emit more than the rest of the industry.  And the reverse is true for a company like Honda.

Honda is the manufacturer with the lowest emissions because it invests broadly in improvements across its entire fleet. Similarly, the Detroit Three don’t perform poorly because they sell a lot of trucks—they perform poorly because their vehicles emit more than the industry average in most classes of vehicle.

The only company whose ranking is significantly affected by the mix of vehicles they sell is Toyota—but that was an intentional decision on their part.  They chose to boost production of their least efficient vehicles, trucks and SUVs, while at the same time bypassing investment in improving those vehicles.  If they want to catapult back to the top of the pack, they’ll need more than the Prius to make them look like a leader—it’s about providing consumers lower emission choices across the entire spectrum of vehicles sold.

A path forward

With every Automaker Rankings, we try to provide the industry with a path forward. And the truth is, the engineers at these companies have been working their butts off to provide a bright future for the industry…should they choose to embrace it.

Manufacturers have made a number of pronouncements about the vehicles planned over the next five years which could easily end up keeping emissions levels on the path envisioned under the 2025 standards now on the books. And we have tried to highlight the role these vehicles can play in creating a more sustainable transportation future.

But too many within the industry have been looking to ignore their role in getting to this low-emissions future, so the question remains:  Will the industry accelerate toward a cleaner future by following their engineers, or continue to deploy their lobbyists to slam on the brakes?

It’s Time to Implement Stronger Autonomous Vehicle Testing Standards

Photo: Grendelkhan/Wikimedia Commons

The widespread introduction of autonomous vehicles could potentially bring about many benefits – advocates argue they will reduce traffic, the burden of driving, and emissions should the cars be electrified. The could also improve access for children, the elderly or people with disabilities – but the most important benefit is improved safety.

U.S. road fatalities increased 5.6 percent from 2015 – 2016. This is a disturbing trend, as this is the largest increase in the last decade. Proponents of the self-driving community will tell you that the cars will help to slash the numbers significantly because the human driver is taken out of the equation. According to the National Highway Traffic and Safety Administration, there were 5,987 pedestrian fatalities in 2016 – the highest number since 1990 – and 847 bicyclist fatalities, the highest since 1991. In addition, fatalities due to drunk driving and speeding went up at least 1 percent. Although fatalities from distractions and drowsiness went down 2.2 and 3.5 percent, respectively, they were offset by an increase in other reckless behaviors (speeding increased 4 percent, alcohol impairment increased 1.7 percent, and unbelted incidents increased 4.6 percent).

Autonomous vehicles are being tested in several states and provinces, such as California, Pennsylvania, and Ontario. The graphic below shows the status of autonomous vehicle testing laws in the various states across the country – 25 of 50 states have passed laws overseeing testing. Uber and Waymo have taken the lead in testing – Waymo has logged over 5 million miles and Uber, although far behind Waymo, has logged a significant number of miles itself with 2 million. California has been working with testing companies under a regulatory framework, while states like Arizona have allowed free reign to the companies to test the vehicles on the public roads, with a backup human in the driver seat to compensate for any failures in the software. However, what happens if the driver gets distracted and loses focus? Or when the autonomous system doesn’t have a sufficient way of warning the driver that they need to take over?

Current Status of State Laws on Self-Driving Cars
Source: Brookings Institution and the National Conference of State Legislatures. Click to enlarge.

The NTSB presents its findings

According to a preliminary report released by the National Transportation Safety Board (NTSB), that is exactly what happened when an Uber self-driving platform controlling a Volvo XC90 autonomous vehicle killed a bicyclist in Tempe, Arizona on March 18. The initial reaction of the chief of the Tempe police on March 19 was that Uber was likely ‘not at fault’ for the incident after viewing the vehicles own video of the event. After a more thorough investigation, however, the NTSB report states that the Uber system “registered…observations of the pedestrian about 6 seconds before impact, when the vehicle was traveling at 43 mph. As the vehicle and pedestrian paths converged, the self-driving system software classified the pedestrian as an unknown object, as a vehicle, and then as a bicycle with varying expectations of future travel path.” The Volvo XC90 had its own emergency braking system, but this system was disabled when the Uber self-driving system was controlling the vehicle, to “reduce the potential for erratic behavior.” The Volvo emergency braking system could have prevented or reduced the severity of the crash, since it detected the bicyclist 1.3 seconds before the collision, and if enabled would have made an emergency stop.  The driver appeared to have been distracted by the computer interface and did not see the bicyclist step out into the street. By the time the driver looked up, saw the bicyclist and pressed the brake, it was too late.

View of the self-driving system data playback at about 1.3 seconds before impact.
Source: National Transportation Safety Board.

Safety advocates across the spectrum have cautioned lawmakers about the rapid pace of testing saying that it is too soon to have them tested on public roadways, interacting with pedestrians and bicyclists. Moreover, reports suggest that Uber’s self-driving system was struggling to navigate public streets, with drivers needing to intervene and take control from the automated system once every 13 miles, compared to more than 5000 miles between interventions for the Waymo systems being tested in California.  Real world testing on public roads is clearly needed to test and improve the self-driving technology but testing on public roads must only be done once public safety can be assured.

Congress is pushing federal legislation too quickly

This fatal crash is a stark reminder of the risks involved in racing to bring automated driving technology to market without adequate oversight. Senator John Thune, the Republican Chairman of the Senate Committee on Commerce, Science, and Transportation, remarked that “the [tragedy underscores the need for Congress to] update rules, direct manufacturers to address safety requirements, and enhance technical expertise of regulators.” Senator Gary Peters also chimed in, saying that “Congress must move quickly to enhance oversight of self-driving vehicles by updating federal safety rules and ensuring regulators have the right tools and resources to oversee the safe testing and deployment of these emerging technologies.”

Yet while state and local governments grapple with responses to this tragedy, the architects of the Senate self-driving bill are renewing their push to get it passed through Congress.  The Detroit News reported that Peters and Thune are still attempting to win support from reluctant senators. The bipartisan duo also is looking at the possibility of trying to attach the measure to another bill that has better prospects for a full vote or passing it as a standalone bill.

This push concerns us as we question whether the AV START Act is the right vehicle to meet those aims. The bill would allow hundreds of thousands more autonomous vehicles on our roads, with lax oversight, and would pre-empt the great work that state and local governments are doing to regulate AV testing in their jurisdictions.

Safety of all users of the road must be the top priority

In our policy brief “Maximizing the Benefits of Self Driving Vehicles,” UCS advocates that “rigorous testing and regulatory oversight of vehicle programming are essential to ensure that self-driving vehicles protect both their occupants and those outside the vehicle.” In October 2017, UCS expressed its concerns on the lack of scientifically-based safeguards in the Senate’s AV START Bill. Already, cities and states are having discussions on how to regulate AVs more strictly. The mayor of Pittsburgh Bill Peduto planned to ask representatives from the AV industry agree to a 25-mph limit on city roads, stating “Pittsburgh should have a very strong voice in whatever Pennsylvania should decide to do,” Peduto told reporters Tuesday. “These are our streets. They belong to the people of the city of Pittsburgh and the people of the city of Pittsburgh should be able to have certain criteria that shows them that safety is being taken first.” However, the city has  limited authority to regulate vehicles on its streets California is taking a different tack, as its Public Utilities Commission recently released guidelines that will allow AVs to pick up passengers – as long as the company holds an autonomous vehicle testing permit from the DMV for at least 90 days before picking up passengers, agrees to not charge for the ride, and files regular reports including the number of miles their self-driving vehicles travel, rides they complete and disabled passengers they are serving.

Uber and other companies will have to reassess their procedures for AV road testing and states will have to re-evaluate how freely they allow self-driving cars to be tested on their roads. Furthermore, municipal governments need to be at the table working with companies to develop robust safety standards. We need to ensure at all levels of government that adequate, sound safeguards are implemented, so that autonomous vehicles can truly achieve the safety benefits they are expected to have.

Grendelkhan /Wikimedia Commons

More Great News for Clean Air and Public Transit

DC Circulator bus

Transit buses are community resources. They help pedestrians get around on rainy days, hot days, and cold days. They help subway riders get home when the trains stop running late at night. They help cyclists get through parts of town that aren’t bike friendly. They help crowds of people get to sporting events. They reduce the number of cars on the road in space-limited downtowns. They provide regular transportation for people that aren’t able to afford a car, people that choose not to have a car, and people that aren’t able to drive a car.

To meet air quality and climate goals, we need widespread electrification of all types of vehicles. Buses are the people’s electric vehicle.

And we’re seeing more and more electric buses hit road. Recent news shows how state and local governments are bringing zero-emission battery and fuel cell technology to the masses.

Major investments in California California State Transportation Agency (CalSTA)

CalSTA recently announced awards for 285 zero-emission buses (in addition to major rail projects) that will be deployed across the state over the next five years. To my knowledge, this is the largest single investment in zero-emission buses in the United States to date. Communities from San Diego to Redding will benefit from these new buses.

A couple of noteworthy awards: funding will provide dozens of buses for new express routes along the highly congested US 101 corridor on the San Francisco Peninsula. Funding will also provide several electric coach buses operated by transit agencies in northern and southern California – yes, electric coach buses exist! These coach buses would also be great fits for companies like Google, Facebook, and Apple that provide transportation for their employees.

Funding for the 285 zero-emission buses comes from the state’s cap and trade revenue and the state’s fuel tax, the latter which increased in 2017 by 12 cents per gallon of gasoline with passage of Senate Bill 1.

California Legislature

The state legislature has authority to annually allocate 40 percent of cap and trade revenues that aren’t subject to continuous appropriations. The 2018 state budget provides $180 million of this cap and trade revenue for clean heavy-duty vehicle incentives, of which at least $35 million was specified for zero-emission transit buses. Budgets recently proposed for 2019 by the state Senate and Assembly indicate a similar commitment ($160 million and $150 million, respectively) for heavy-duty vehicle incentives next year.

California Air Resources Board (CARB)

CARB not only manages vehicle incentive funding allocated by the legislature, but it also directly oversees settlement money to offset the pollution from the Volkswagen #dieselgate scandal. CARB’s proposed plan for this funding could direct up to $65 million for zero-emission transit buses.

Taking the existing zero-emission buses on the road (100+), buses on order (340+), and the sources of funding above, I estimate at least 1,000 zero-emission buses will be on the road within the next five years in California, roughly 10 percent of all transit buses in the state. This means that many transit agencies are getting well ahead of milestones proposed by the California Air Resources Board for transitioning to a zero-emission fleet by 2040.

Strong commitments from transit agencies

Leadership on zero-emission buses is also coming directly from transit agencies and people asking transit agencies to take action. I’ve highlighted the work of King County Metro (Seattle-area) and Los Angeles Metro in previous blogs, but transit agencies large and small across the country are beginning to adopt electric buses. Here’s some of the most recent leadership we’re seeing from transit agencies.

San Francisco Muni

Muni, the transit agency serving San Francisco, recently adopted a resolution committing to all zero-emission buses by 2035. Muni has nearly 600 diesel and diesel hybrid buses. Combined with its 400 trolley buses, Muni is the second largest bus operator in California behind LA Metro.

Santa Monica Big Blue Bus

Another city leading the way in California is Santa Monica, which recently reaffirmed its 2016 commitment to transitioning its 200 bus fleet to zero-emissions by 2030. The city was awarded funding from Senate Bill 1 and cap and trade revenue (see above) for its first 10 electric buses. Santa Monica said this fall will be its last order of natural gas buses. This is a remarkable statement that I expect we’ll be hearing more and more from transit agencies.

It’s not just California

Washington, DC recently announced 14 battery electric buses have joined its fleet. And New York City’s Metropolitan Transportation Authority (MTA), who operates the largest bus fleet in the country with 4,000+ buses, casually made a huge announcement in its new bus plan that it will transition its entire fleet to zero-emission buses. A timeline for MTA’s transition hasn’t been specified yet.

The work ahead

Commitments to fleet transitions are the first step in getting zero-emission buses on the road. Then comes laying out a plan for acquiring the new buses, becoming familiar with the technology, and ultimately integrating the vehicles in significant numbers. A lot of thought, planning, and attention to detail are needed in between.

The transition to zero-emission fleets will require problem solving and teamwork across all aspects of the transit industry including route planners, bus makers, bus purchasers, facility managers, finance departments, mechanics, state and federal grant agencies, and public officials.

Like any new technology, there is a learning curve for the industry to overcome in the early years of adoption – such as figuring out the range an electric bus will get on specific routes in specific weather, because it won’t be the same as the range on the window-sticker. Fortunately, there isn’t any aspect of this learning curve I’ve seen that can’t be overcome.

There’s also myths that must be overcome with any new technology, such as electric buses’ ability to climb hills. The bus maker Proterra recently debunked this myth by climbing its bus up the canyons and mountain passes of every major ski resort near Salt Lake City. Another myth is the ability to operate in cold weather. Debunking this is Worcester Regional Transit Authority in central Massachusetts who has been operating battery electric buses since 2013.

One aspect of the transition to zero-emission buses that must be in place is hydrogen fueling and electric vehicle charging infrastructure. Utility companies must be given the green light to develop this infrastructure. From everything I’ve seen, electricians are more than ready for the job opportunities to build it out.

The magnitude of change needed to improve air quality and reduce climate change can be overwhelming, but I take great relief that we have the technology to overcome these challenges. China already has an estimated 386,000 electric buses on the road, which is more than five times the number of all types of transit buses in the United States. It can be done here too and there’s no time to wait.

Photo: DC Circulator

California Could Pass Innovative Legislation on Key Climate, Energy and Transportation Issues

California State Capitol

California has a well-earned reputation as a world leader in promoting clean energy and other solutions to climate change. However, as anyone paying attention to the climate crisis knows, we have far more work to do. Fortunately, the California Legislature is considering many bills in 2018 that would further address climate change. With three and half months until the Legislature adjourns for the year, UCS is working with lawmakers to make progress on a suite of policy prescriptions to promote renewable energy, clean transportation, and better preparedness for climate change impacts.

Create a clean electricity system

California has made great progress adding renewable energy to the grid. To meet our climate goals, we must continue our clean energy momentum and work to reduce reliance on natural gas power plants. This year UCS is working to:

  • Establish a goal of 100 percent clean energy. Achieving 100 percent clean energy is an ambitious goal we must reach for to create a cleaner and healthier future, and to continue California’s tremendous momentum advancing clean energy.
  • Establish standards for California electricity providers to join a western regional electricity grid. UCS is working to help pass AB 813 (Holden) to prepare the ground for a regional grid that would make it easier and more cost-effective to integrate renewable energy by sharing electricity generation across a larger area.
  • Reduce reliance on natural gas power plants. California needs to study the fleet of natural gas power plants to create a strategy to reduce the use of natural gas electricity generation in an orderly, cost-effective, and equitable manner. In addition, UCS is supporting work to limit the use of the dirtiest natural gas power plants at times and in locations with bad air quality.
Create a clean transportation system

For decades California has led the nation with policies to reduce pollution from vehicles and promote clean fuel and vehicle technologies. As our transportation system faces dramatic changes in coming years—electrification, car-sharing, automation—we must ensure these changes result in reduced emissions and other key objectives (such as safety and accessibility). In 2018, UCS is working to:

  • Pass a state budget that includes much-needed incentives for electric cars, trucks, and buses. Incentives for electric cars vehicles are critical to overcome higher upfront costs that still exist and to increase consumer interest in this new technology. Each year lawmakers must appropriate funding for important incentive programs for light-duty and heavy-duty vehicles and UCS is working to make sure adequate funding is appropriated for the year ahead.
  • Ensure autonomous vehicles (AVs) reduce pollution and congestion and enhance access to mobility. AVs may become the most significant innovation in transportation since the mass introduction of automobiles early last century. However, public policy needs to guide the safe introduction of this emerging technology for widespread adoption of AVs to result in positive outcomes in the years ahead. UCS supports SB 936 (Allen), which will create an expert task force to make recommendations to provide guidance for how we can shape this new transportation technology to achieve these public benefits.
  • Increase use of electric vehicles by ride-hailing services. Ride hailing services—like Uber and Lyft—are a rapidly growing part of our transportation system. As these services grow and carry more and more passengers, it will become increasingly important that they move toward vehicle electrification to reduce pollution—just as electrification is important for personal vehicle use and transit buses alike. SB 1014 (Skinner) looks to address this issue. While UCS supports the concept of this bill, there are important details that remain to be resolved.
Better prepare California for a changing climate

California is facing a “new normal” of increasing variability and extremes in climate conditions with enormous impacts on people, communities, and the infrastructure on which our safety and economies depend. We must start to plan, design and build California’s infrastructure to be “climate-smart” and withstand the new reality of climate change. This year UCS is working to:

  • Create a state adaptation center to support decision-making on state infrastructure projects. The state should establish an office within the state government to provide various state agencies with actionable climate-related information and real-time guidance on specific analytical approaches and data choices as they grapple with decisions about planning and designing infrastructure projects.

I look forward to working on these and other issues on behalf of UCS and our supporters and Science Network members. Hopefully the Legislature will pass legislation advancing many of these priorities this year, keeping California on a path to a safe and sustainable future that utilizes science as a foundation for policy-making.

UCS Joins Lawsuit to Stop Pruitt from Rolling Back Clean Car Standards

UCS joined a coalition of non-profit organizations in filing a lawsuit to challenge EPA Administrator Scott Pruitt’s attempt to roll back a regulation designed to improve vehicle gas mileage, save you money, and tackle transportation-related emissions, the biggest source of climate change pollution in the U.S.

A brief history of the fuel efficiency standards

This suit opens a new chapter in an epic saga that is longer than any George R.R. Martin or Robert Jordan series. Was this saga TL;DF (too long, didn’t follow)? Here is a brief primer.

In 2009 automakers agreed to a federal standard that requires them to gradually raise the average mpg of their vehicles through 2025. But, two days after President Trump took office, automakers and their trade groups asked the White House to weaken the standard. The Trump Administration agreed, and subsequently relied on bogus, industry-funded science to determine that the standards need to be changed.

How, exactly, the standards will be changed is TBD, but even before we allow EPA to get to that stage, UCS and our allies are asking a panel of federal judges to review the EPA decision to reexamine the standard. If the court finds that EPA’s decision to overlook the reams of science-based evidence that supported the original standard was improper, then EPA will have to go back to the drawing board and the current standard will remain intact.

Is this all the automakers fault?

In a word, yes. But blame must also be placed on the Trump Administration, which has turned this program into such a boondoggle that automakers have begun to change their tune and claim that EPA isn’t doing what they asked for. Don’t feel too bad for the automakers, though. They led a bull into a china shop and are now upset that the bull is destroying too much china.

What happens if EPA wins

This isn’t the final chance to stop the fuel efficiency standards from being destroyed. Even if EPA wins this case and the similar suit filed by 17 states and the District of Columbia, EPA still needs to submit an additional rulemaking for public comment that details exactly what the standards will be out to 2025. EPA will receive tens – if not hundreds – of thousands of comments in support of maintaining a strong standard, though it is unlikely they will listen to any of them. So, a weak rule will probably get finalized, which will prompt an opportunity for another lawsuit. That lawsuit will be the final crack at striking down what EPA is trying to do but, given how fast the federal government operates, won’t be initiated for quite some time.

In the interim, it’s important to keep pressure on EPA by having the judiciary rule on whether what they did was within the bounds of their authority. EPA ultimately chose to modify a standard that is based on the best available science, years of stakeholder input, and broad public support – and the small army of attorney’s representing the coalition of NGOs and states will make sure the court hears that argument loud and clear. It will also be important to submit comments to future EPA rulemakings on this issue – even if they don’t persuade the agency. An overwhelming number of comments in support of a strong rule clearly demonstrates how Americans view fuel efficiency standards, and can help a court find that EPA did not act in the public interest in weakening the standards.

Automakers Pretend President Trump Isn’t Giving Them Exactly What They Asked For—We Don’t Buy it.

Today, automakers are meeting with President Trump to discuss his administration’s plans to rollback fuel efficiency and emissions standards on light-duty vehicles. Since reports of the proposal first began to leak, we’ve seen a number of statements from automakers claiming that this wasn’t what they asked for.  Unfortunately, these statements ring hollow—and their own proposals explain why.

You can’t renegotiate a Faustian bargain

It took just two days after President Trump was elected for the Alliance of Automobile Manufacturers to request that his administration put the brakes on any decision regarding the 2022-2025 standards, fearing that the agency would follow the science and not their wishes to weaken the standards. When EPA moved forward with this decision and correctly determined that automakers could not just meet but exceed the standards, and that these vehicle emissions standards remained appropriate, the Alliance again went to the administration to have the process reversed.

Enlisting an ideological administration to pull back on regulations amounts to a Faustian bargain—when regulations stop being based in scientific rigor and instead are based in political expediency, a technically indefensible proposal like freezing progress at 2020 levels is exactly what you get.  This was an entirely foreseeable result, and automakers and their lobbyists are neither so stupid nor naïve as to not see this coming—for them to feign surprise now at the outcome is insulting. Of course, it’s made even worse by the fact that they themselves have been in the driver’s seat as we’ve headed down this road.

What the industry has asked for thus far

From the get-go, automakers have been asking for “harmonization” while failing to acknowledge that these requests come at the cost of increased emissions and fuel usage. In fact, in their first letter to the President, they requested that the administration approve a petition that would result in 150 million barrels of additional oil consumption by overcrediting vehicles that had already been sold and adding “flexibilities” to the program that directly undermine the standards.

Administrator Scott Pruitt and the CEOs of the National Automobile Dealers Association, Alliance of Automobile Manufacturers, and the Association of Global Automakers

Administrator Scott Pruitt and the CEOs of the National Automobile Dealers Association, Alliance of Automobile Manufacturers, and the Association of Global Automakers, smiling as the administration announces its plan to roll back the 2022-2025 vehicle emissions standards (EPA).

Of course, the Alliance has not limited themselves to executive action when it comes to lowering the bar—they’ve asked Congress to intervene as well, with legislation that would result in at least 350 million barrels of additional oil use and put the industry on a path to 2025 that is 8-10 mpg lower than the standards already on the books.  That endpoint is within spitting distance of the current proposal, so it seems hard to argue this isn’t President Trump’s administration just naturally following the Alliance’s lead.

Similarly, while manufacturers like Honda, Ford, and GM have all come out and said they don’t want a full rollback of the standards, some of the details surrounding these announcements raise serious doubts. For example, while Honda has come out with the most vocal support for the standards, requesting that the targets be maintained as is, that came with a major caveat regarding additional incentives for electric vehicles were requested, as did Ford’s. GM’s proposal included a request for credits based on the unproven benefits of autonomous electric vehicles.

The impact of these types of “flexibilities” is massive—for example, extending EV multipliers and ignoring emissions associated with the electricity powering these vehicles would result in additional emissions and oil usage in the near-term, to the tune of over 230 million metric tons just over the lifetimes of vehicles sold through 2025 by our estimate, even at modest EV sales (< 5% in 2025).  That’s equivalent to freezing the standards at 2022 levels—not a far cry from the administration’s proposal—and the impact would be even worse if EV sales outpace those expectations. Similarly, giving away credits for safety or automated vehicle technologies is a strategy which would have serious consequences for the robustness of these rules and may not even result in any real reductions.

What the industry should be asking of the President

If the industry is now having second thoughts, it is time to eschew the sort of wiggle room granted in the public statements thus far and stick with a clear proposal to ensure we maintain the benefits of strong standards. To that end, here is what the automotive CEOs should tell the President in today’s meeting:

  • We can meet the standards as they stand. Ford told its shareholders yesterday that they are planning to exceed the current standards—now they need to say that to the President. Of course, this is consistent with the technical record underpinning the Obama administration determination that these standards are appropriate.
  • These standards have accelerated technology investment. Automotive manufacturers and especially suppliers have both invested significantly in the technology needed to reduce oil use and emissions from light-duty vehicles.
  • To continue that investment, we need certainty. Not only does pulling back on strong standards send the wrong market signal to continue that improvement—it also all but ensures continued uncertainty as these rules wind up in years of litigation.
  • Oil prices are on the rise, and these standards protect our customers from that volatility. Domestic manufacturers were ill-prepared the last time gas prices rose dramatically, and these standards act as a hedge against a volatile, global oil market that finds prices at the highest they’ve been since 2014.
  • Respect state leadership—the entire country benefits. California and the 12 states that follow California’s policies are going to enforce the 2025 standards as they stand today—don’t fight that progress. California stepped up to the plate to set the first-ever vehicle emissions standards, and we continue to reap the benefits of that today nationwide.
  • These standards are job creators—so get out of the way and let us get to work “making America great.” Analysis is clear—these cost-effective standards are great for consumers, and because those savings get reinvested into the economy, they end up creating new jobs not just in the automotive sector but across the economy.

Instead of quibbling about how weak is weak enough, they need to push for strong policy commitments.  Given the repeated asks of the administration to weaken the standards, I find recent automaker pleas a bit dubious—but at the moment, they at least have the ear of the President, so they need to make it count.

If the automakers can’t succeed in putting the genie back in the bottle, we will see more than 200 billion gallons of additional oil use by 2050, costing consumers hundreds of billions of dollars at the pump and forestalling investment in technologies needed to address the challenge of climate change. And they will shoulder the blame for generations to come.

What is the Connection Between New Mobility and Transportation Equity?

My name is Richard Ezike, and I work at the interface between new mobility and transportation equity. When I talk about “new mobility” in my research, I refer to what is arguably the most disruptive technology in transportation in the last century: the autonomous vehicle (AV). Already these cars are being tested on America’s roadways in Chandler, Arizona; Pittsburgh, Pennsylvania; and Silicon Valley, Companies like Uber, Lyft, Waymo, Ford, and General Motors are investing billions of dollars to bring this technology quickly to market. These companies are touting widespread adoption in less than 5-10 years.

However, more discussion is needed on the impacts of these cars on transportation equity because this nexus is often ignored in the spaces where AVs are being debated and discussed. The million-dollar question is: Will AVs help or hurt the mobility of low-income people and people of color? The pursuit to tackle that question has led me here to the Union of Concerned Scientists (UCS).

My project works to address this question from two angles. First, we are working with a transportation consulting firm to study the potential impact of self-driving technology on access, equity, congestion, and transit utilization in the DC Metro Area, where I personally live and work.  They are using a travel demand model developed by the area metropolitan planning organization (MPO), the National Capital Region Transportation Planning Board, to predict the impacts of vehicle miles traveled, vehicle trips, and transit trips by AVs in 2040. By modifying the inputs to the model, we can simulate the impacts of self-driving cars on the future transportation network performance. The detailed nature of the model allows us insight into specific neighborhoods that may gain or lose under a variety of future scenarios.

Second, we are engaging stakeholders to learn their thoughts and concerns about AVs. To date, I have interviewed over 40 stakeholders including local government officials, car dealers, community leaders, and policy makers. I have asked them about the potential impacts of AVs on traffic, labor, the environment, and the economy. In early 2019, we plan to convene stakeholders to discuss our research findings, get feedback, and generate policy recommendations to share with local leaders and community groups.

Using this two-pronged approach will provide our community with both technical and community-based knowledge that will assist in the planning of how AVs can be deployed safely and equitably.

Defining transportation equity

Historically, members from disadvantaged groups (low-income residents, minorities, children, persons with disabilities, and older adults) have experienced the most negative impacts of the transportation system. These groups have lower car ownership levels, the longest commute times and the highest costs for transportation. These same groups also live near inadequate infrastructure, which results in unsafe conditions for cycling and walking and therefore an increased number of fatalities involving pedestrians and cyclists.

Low-income and minority communities are also more likely to be located near highways and other transportation facilities that produce local air pollution; to suffer from negative health effects such as asthma; and to have the least accessibility to key destinations such as parks, hospitals, and grocery stores selling healthy food. Addressing these issues requires a dedicated effort to address equity in the transportation system to provide equal access for all people.

Equity is defined as the fairness, impartiality, and justness of outcomes, including how positive and negative impacts are distributed. Within transportation and infrastructure, the decisions made in the planning stages can significantly affect the level of equity achieved in communities.

Depending on how it is deployed, autonomous vehicle technology could improve transportation inequities; but without guidance, the same detrimental effects to disadvantaged groups may only get worse. Moreover, solving these problems is not a purely technical challenge, but requires meaningful engagement and input from communities with a stake in the outcomes, so they can have a voice in the way their city is developed. Historically, public engagement has been a secondary consideration, although many MPOs are stepping up their efforts. Based on work by Dr. Alex Karner, effective engagement can be broken into three steps:

  1. Identify current unmet needs from the communities this requires engaging with community groups to learn how MPOs can best serve residents.
  2. Provide funds to assist community groups in engagement – Engagement can be time consuming and expensive, and often community groups do not have the bandwidth in time or in funding for outreach. Therefore, the MPOs should provide resources to assist. Karner suggested raising money through state taxes or allocating from available transportation funds
  3. Measure progress of outreach using relevant metrics – MPOs must track how effectively they are engaging communities. They need to know how many people they talked with and if they understood the material being discussed. By tracking that information, MPOs will know if their message is getting across.

Through the duration of my fellowship I have had the opportunity to interview several stakeholders to learn about how they see autonomous vehicles impacting equity. Across the board, there is a definite interest in how the broad impacts of AVs will manifest themselves in society, and at UCS my research will help to bring these various groups together. My engagement with these groups is helping to identify unmet needs, identify relevant metrics from stakeholders, and stress the importance of safe and equitable AV deployment. 

Why new mobility and equity must function together

I have talked with transit advocates who are concerned about the impacts on transit agency jobs and public transit options in general, as they are concerned that AVs will replace public transit but may not meet the needs of transit dependent communities while eliminating thousands of transit worker jobs.

I have spoken to business owners who believe the benefits of autonomous vehicles, such as increased access to the transportation system for the disabled and senior citizens, outweigh any potential pitfalls.  I have heard varying viewpoints from several local government officials from very concerned to “we have not thought about AVs yet,” and some state departments of transportation are taking a hands-off approach.

These discussions reiterate that the paradigm shift is happening. Autonomous car technology is here, and billions of dollars are being spent to put these cars on the roads as fast as possible. However, the conversations that are most needed –potential impacts on transportation equity and accessibility, the effects on public transit, and the environmental considerations – are not happening quickly enough. They need to happen more often, and soon. Through my fellowship at UCS, I aim to increase this awareness and provide new research, analysis and recommendations to advance equitable transportation outcomes.

Regulators Should Think Twice Before Handing Out Pollution Credits for Self-Driving Cars

A new report out by Securing America’s Future Energy (SAFE) suggests that automakers should get credits towards meeting emission and fuel economy standards for connected and automated vehicles (AVs) and related advanced driver assist systems—technologies that may or may not save any fuel. Doing so would not only increase pollution and fuel use, but would seriously undermine the integrity and enforceability of regulations that have delivered enormous benefits to our environment, our pocketbooks, and our national security.  The tens of thousands of traffic related fatalities every year in the U.S. demands that automakers and regulators must continue to make our cars safer.  But trying to encourage greater deployment of safety technologies by undermining pollution standards is the wrong approach.

Here’s why regulators should reject giving emissions credits to manufacturers for deploying safety and self-driving technologies.

Including emissions credits for safety and self-driving technologies in 2022-2025 vehicle standards would be a windfall for automakers, resulting in less deployment of proven efficiency technologies and more pollution.

There are more questions than answers about the potential impacts of various safety technologies and self-driving capabilities on vehicle and overall transportation system emissions, which I’ll get into more below.  But for now, let’s just take a big leap of faith and assume that some safety technologies actually do lower an individual vehicle’s emissions.

One example is adaptive cruise control.  This technology automatically adapts a vehicle’s speed to keep a safe distance from a vehicle ahead and theoretically could perform more efficiently than a human driver.  It is widely available and featured on vehicles like the Toyota Camry, Honda Accord and Ford Fusion.  One study examined this technology and found changes in efficiency could range from +3 to -5 percent during various types of driving. While there is some evidence that under certain conditions there might be a slight fuel economy benefit from this technology when it is in use, that same evidence indicates that increased fuel use and emissions are also possible.

In another recent study of self-driving cars, researchers found that while eco-driving capabilities could potentially provide savings, the increase in electric power demand, added weight, and aerodynamic impacts of sensors and computers would increase fuel use and emissions.  Both of these examples demonstrate the importance of testing and verifying any assumed change in emissions from the deployment of safety and self-driving technology as emissions reductions are anything but certain.

But even if credible testing and data were available, giving off-cycle credits for this technology within existing standards would be a giveaway to the auto industry.

Why? Adaptive cruise control is already being deployed on millions of cars – 1 in 5 new vehicles produced for the US market in model year 2017 were equipped with adaptive cruise control. Automatic emergency braking is another example, where automakers have already made commitments to make it standard on nearly all cars by 2022. Giving credits for these technologies would be a windfall for manufacturers and result in less deployment of proven fuel efficiency technologies.

The ICCT also identified this issue of providing credits for tech deployment that is already occurring in their review of the current off-cycle credit program and concluded that the program greatly reduces the deployment of other efficiency technology. They also identified the lack of empirical evidence to validate claimed fuel economy and emissions benefits from several technologies already included in the program as another big problem. And currently there is little empirical data to validate any efficiency benefits of safety and self-driving technologies.

Providing credits for emissions and fuel consumption impacts that are difficult to measure and not directly related to a vehicle – like possible impacts on traffic congestion—would increase pollution and undermine the standards.

Expanding the off-cycle program for safety technologies that might directly impact a vehicle’s emissions is just the tip of the iceberg.   The off-cycle credit program, like the vehicle standards in general, is limited to emissions directly related to the performance of a vehicle. But some automakers, and SAFE, are interested in allowing credits based on potential changes in emissions from the transportation system as whole. For example, automakers could earn credits toward compliance with vehicle standards for some future changes in traffic congestion that might result from the deployment of improved vehicle safety technologies. This would be a major change to the per-vehicle basis of the fuel economy regulations that were established in the 1970’s.

There are several serious problems with including speculative, indirect emissions impacts in existing vehicle standards.

1. Providing credits for emissions reductions that may or may not ever happen in the future will increase pollution in the short term and may never result in emission reductions in the long term

We only need to look back at the flex fuel vehicle (FFV) loophole to find an example of this kind of failed policy. Automakers were given fuel economy credits for selling cars capable of running on fuel that is 85 percent ethanol (known as E85), under the theory that this would help drive E85 to market and we would use less oil. Several automakers used it as a compliance strategy and avoided investing in other fuel efficiency technologies. But the cars almost never actually used E85, which means instead of getting more efficient vehicles, we got more oil use. The increased fuel consumption resulting from the FFV loophole is estimated to be in the billions of gallons.

Crediting future emissions reductions based on hopes and dreams has been tried before and doesn’t work.

2. Ignoring the potential negative impacts from self-driving technologies is a HUGE problem.

Self-driving cars have the potential for both positive AND negative impacts on pollution and energy use.

The biggest X-factor is how drivers will respond to these new technologies, which make vehicles safer, but also makes them easier to drive (or not drive at all as the case may be). A paper by Wadud et. al examined a range of direct and indirect impacts self-driving vehicles could potentially have on emissions.  And there are several possibilities, some of which could reduce emissions while others could increase emissions dramatically (see figure).   Increased emissions could result from higher highways speeds enabled by increased vehicle safety, increased vehicle size or features as drivers expect more features in their vehicles while their car drives them around, and most importantly, increases in the amount of vehicle travel overall.  Combined, these effects could increase emissions by more than 100% according to the study.

Automated vehicles could have both positive and negative impacts on energy consumption and emissions. Wadud et al.

We’ve already experienced increased highway speeds as vehicles have become safer with seatbelts, air bags and a host of other safety technologies.  And it’s not hard to imagine increases in vehicle miles traveled as cars take over the task of driving so we can do other things.  Just think about for a minute—what different choices might you make if you didn’t have to drive your own car?  Living farther from work or taking that extra trip during Friday rush hour might not seem so bad anymore when you can read a book or watch a movie while your car chauffeurs you to wherever you want to go.

Based on the current scientific literature, SAFE’s estimate of potential efficiency improvements from automated vehicles is misleading at best. Their analysis ignores any possible disbenefits, like increased vehicle travel, even while specifically acknowledging AVs “can also give drivers one thing of tremendous value to most Americans – an increase in personal or productive time”. The analysis also uses the upper range of efficiency benefits from a handful of studies estimated over limited driving situations, and inappropriately applies them to all driving.  The conclusion that a handful of safety technologies could reduce emissions 18-25%  across the entire vehicle fleet is not supported by current evidence, ignores any other effects of self-driving cars, and is not a sound basis for policymaking decisions.

My point isn’t that we should prevent self-driving technology and the many potential benefits it could deliver if done responsibly.

But vehicle standards aimed at reducing emissions and fuel consumption shouldn’t include credits for potential positive changes to transportation system emissions while ignoring the negative ones.

3. Finally, regulatory enforceability and accountability—the key to the success of today’s vehicle standards—would be severely undermined

The effectiveness of vehicle standards, any standards for that matter, is having effective enforcement which ensures regulated entities are all participating on a level playing field and that the actual benefits of the standards are realized.  We’ve seen the importance of enforcement over the decades as automakers have been held accountable for the performance of their products. Think ‘VW diesel scandal’ for one, and the numerous examples of erroneous fuel economy labels (Ford and Hyundai-Kia to name just two). These enforcement actions have one important thing in common: regulators were able to perform tests on the vehicles to determine if they were performing as the automakers claimed, and demonstrate that they were not.

Current vehicle standards are robust because they are predicated on direct emissions and fuel savings benefits that are verifiable on a vehicle level. An automaker makes a car, it’s tested, and they are held accountable for the results. How might a regulator, or an automaker, test and verify the congestion impacts of an individual Cadillac STS with Super Cruise?

Providing credits to automakers for emission reduction benefits that cannot be verified or attributed to an individual manufacturer, nevermind an individual vehicle make or model would be a massive change in approach to the program introduced through a mechanism – the off-cycle credit provisions – which was never intended to be more than small part of automaker compliance.

Where’s our insurance policy?

SAFE makes the case that giving away credits to automakers now, even without proof that these technologies reduce fuel use and emissions, is worth it because it would allow EPA and NHTSA to run a research program to understand the impacts on fuel economy of self-driving technology. But why should we accept increased pollution for collecting information? A better path forward for regulators is to indicate their intention to consider the direct vehicle emissions and fuel economy impacts of safety and self-driving technology in setting post-2025 vehicle standards and implement a testing program now to collect the necessary data to see whether giving credits for these technologies is appropriate. This would motivate automakers to do their own testing and to work with EPA and NHTSA to develop appropriate test procedures for ensuring the claimed benefits are actually occurring.

If safety and self-driving technology off-cycle credits are a proposed solution to the current impasse over 2022-2025 vehicle standards between federal regulators, the auto industry, and California, then we all need to be clear about the costs. They would provide windfall credits to auto companies for something they are already doing, while stalling deployment of proven efficiency technologies and increasing emissions.  If indirect changes in transportation system emissions and fuel consumption are included, such as some theoretical impacts on congestion sometime in the future that may or may not happen, the move would risk undermining the foundation of the standards themselves.

We should not be forced to make a choice between improving vehicle safety and reducing emissions. We need to protect the public from vehicle crashes and protect the public from pollution. If there is proven safety technology that is saving lives, automakers should deploy it and safety regulators should require it. But moving from a regulatory structure that is built on verifiable and enforceable emission reductions to one that is based on speculation and indirect impacts is a dangerous move that should be avoided.


How Important is it for Self-Driving Cars to be Electric?

A Waymo self-driving car on the road in Mountain View, CA, making a left turn. CC-BY-2.0 (Wikicommons).

The rapid development of self-driving technology has raised many important questions such as the safety of automated vehicles (AVs) and how they could radically alter transportation systems. These are critical questions, but AVs also have the potential to result in significant changes to the global warming emissions from personal transportation.

An interesting recent study from the University of Michigan and Ford Motor Company lays out the details of the likely changes in emissions from using an AV system on both electric and gasoline cars. The main takeaway from the study is that adding AV equipment to a car adds weight, aerodynamic drag, and electrical power consumption that leads to increased fuel consumption. There is the potential to offset emissions from more efficient driving by connected and automated vehicles, but by far the largest impact on emissions is the choice of fuel: gasoline versus electricity.

Direct emissions versus behavioral and usage changes

Switching from human control to fully automated driving will have direct effects on emissions as well as changes to the amount we use vehicles. Direct emissions changes include reductions in efficiency from factors like increased drag from sensor equipment and the power consumption of required computing and communications equipment. Positive direct impacts could include more efficient driving, such as smooth and precise acceleration control in an automated system.

Automation will also change how we use cars and how much we use them, indirectly affecting emissions, though the effect of AVs on these indirect emissions is much more speculative. While some changes, like “right-sizing’ (for example, having smaller one or two occupant cars available for solo trips), could decrease emissions, many of the usage changes considered would increase vehicle usage and therefore emissions. Making long distance driving easier or more productive could encourage people to live farther from their jobs. Having fully automated vehicles will mean more people can use a car. The elderly, blind, youth, and people with disabilities could switch from transit to a car, or simply add trips that would not have been able to happen otherwise. While many of these uses of AVs would be beneficial, it’s important to understand the potential emissions from AVs and how we could minimize the total contribution of global warming pollution from personal transportation.

That’s why this new study is important: it lets us at least estimate the direct, short-term implications of AV technologies on emissions. While it doesn’t examine the potential impacts of driving more, it does shed light on the direct effects of adding these new features to cars.

AV equipment increases fuel consumption, especially for gasoline vehicles

Focusing on the physical changes to the vehicle, the addition of self-driving and sensor equipment has three major changes to the fuel consumption (and therefore emissions) of the AV. First, the additional weight of the equipment decreases efficiency. Second, AVs that have sensor equipment like cameras and LiDAR (laser-based imaging) often require side bulges and roof-mounted equipment pods. Like a conventional cargo rack, these additions are detrimental to fuel economy as they increase the vehicle’s aerodynamic drag. Lastly, the sensors and computing equipment that enable self-driving require additional electrical power beyond a conventional vehicle. For a gasoline car, this means added load on the engine to power an alternator (and therefore higher gasoline consumption), while a battery electric car will have reduced overall driving efficiency (and therefore shorter range between recharges).

Waymo’s AV minivan adds sensors and computing systems that increase weight, drag, and electrical power consumption. This model was used as an example of a ‘large’ sized AV system in the referenced study. Image source: Waymo

The researchers from Michigan and Ford examined three sizes of AV systems that could be added to vehicles: an AV system with sensors like a Tesla Model S, a medium-sized system with smaller external sensors similar to a Ford AV prototype, and finally a large AV system modeled after Waymo’s modified Chrysler Pacifica AV. While all AV systems have a negative impact on fuel consumption and emissions, the largest impact is seen in the increased drag from the large AV system.

AV systems can increase global warming emission attributed to driving. The largest impact is seen on larger AV systems due to drag from the sensor units.

Improved driving behavior and other savings from AVs are possible in the long run

The study also points out the possibility of fuel savings from having self-driving and connected cars. These savings could come from several sources. For example, AVs could have more efficient acceleration and braking (“eco-driving”), especially if they are communicating with other cars to anticipate speed changes in traffic. AVs could also communicate with infrastructure like traffic signals to reduce idling and stop-and-go driving. On highways, groups of connected AVs could drive much closer together than a human driver could. This ‘platooning’ technology can increase fuel efficiency by reducing aerodynamic resistance, similar to the drafting that competitive cyclists and NASCAR drivers use to save energy. There is also a potential for AV technology to increase fuel consumption because cars could potentially drive safely on the highway at higher speeds and high speeds reduce efficiency.

These factors are currently harder to quantify than the impact of the AV equipment, and some of the potential benefits require having most or all cars on the road be at least connected, if not fully automated. For example, platooning would require multiple AVs traveling on the same roadway at the same time, which would require a critical mass of AVs to be deployed. The researchers in this study estimate a potential emissions savings on average of 14 percent from these technologies if fully implemented. However, they do not consider changes to vehicles that are already producing some of these benefits, such as improved aerodynamics (which gives some of the same benefits as platooning) or stop-start systems (which already act to reduce some of the adverse impacts of stop-and-go traffic and intersections).

Early AV models are more likely to have higher emissions

The study also considered the impact of the much more power-hungry equipment used in early developmental AV systems. For example, early prototypes have been reported to require in excess of 2,000 W of power, mostly for on-board computing. Increased computer power requirements in these early prototypes, for example going from the from these early AVs (see table). This is especially true for the less-efficient gasoline-engine driven vehicles, where increased electric power requirements would increase emissions over 60 grams CO2 equivalent per mile.  That’s equal to reducing the fuel economy of a 35MPG car to 29MPG, or like adding the emissions from running 10-25 iMac computers using a gasoline generator for every car. Since early AVs will not have enough numbers on the road to take advantage of platooning and connected vehicle savings, it is very likely that in the near-term AVs will contribute higher net emissions than a conventionally driven vehicle using the same fuel.


Emissions from AV system’s electricity use. Baseline system is 200W computer system, prototype uses 2,000W computing system. AV system size Baseline AV system, battery electric vehicle (gCO2eq/mi) Baseline AV system, gasoline vehicle (gCO2eq/mi) Prototype AV system, battery electric vehicle (gCO2eq/mi) Prototype AV system, gasoline vehicle (gCO2eq/mi) small 3.0 8.0 25.9 70.3 medium 3.2 8.6 26.1 71.0 large 4.3 11.8 27.3 74.1


Switching from gasoline to electricity is by far the most important factor in reducing emissions


The choice of fuel (gasoline versus electricity) is the most important choice for reducing emissions. Emissions estimates based on Ford Focus gasoline and battery-electric models and includes ‘well-to-wheel’ emissions for fuel production, distribution, and use in the vehicle. Emissions related to vehicle or AV system production are not included in this chart.

The most important determinant of direct emissions from vehicles is not the AV system, but is the choice of gasoline or electricity. Choosing a electric vehicle instead of the gasoline version for this analysis reduces global warming emissions from 20 to over 80 percent, depending on the emissions from electricity generation. The addition of AV equipment only increases this difference, making it clear that electric drive is required to have AVs that maximize emissions reductions.

What will the future hold? Some AV companies, like Waymo (spun off from Google) and Cruise Automation (partnered with General Motors) are using EVs and have plans to continue using electric drive in their AVs. Other companies have been less progressive, such as Ford announcing that they anticipate using gasoline-only hybrids for their AVs. If AVs have the transformative effect on mobility and safety that many predict, it will be vital to encourage the use of cleaner electricity instead of gasoline in these future vehicles.



Scott Pruitt’s Regulatory Rollback Recipe  

Vehicle pollution is a major issue for human health and the environment.

EPA Administrator Scott Pruitt continues to stack the deck in favor of industry interests. At least two members appointed by Pruitt to the EPA Science Advisory Board received funding to conduct misleading research that EPA used to justify reexamining vehicle fuel efficiency standards – a regulation forecast to save consumers over $1 trillion, cut global warming emissions by billions of metric tons, and advance 21st century vehicle technology.

This shameless attempt to use shoddy research that was funded by the oil industry and used by automaker trade groups to overturn a regulation that is based on sound science and widespread public support is a perfect example of how Pruitt intends to rollback regulations at the behest of his industry-tied former donors.

Pruitt’s plan is a simple (though perhaps illegal) five-step recipe. Here’s exactly how he has been cooking up a regulatory repeal (or re-peel) soup of equal parts corruption, paranoia, and apathy.

Step 1: Separate independent science from the record, then discard

Make it exceedingly difficult for academic scientists to join the advisory committees that help your agency set pollution thresholds, compliance deadlines, and cost estimates.  These committees are supposed to represent the viewpoints of both independent scientific experts and industry stakeholders, but you can argue that the composition of these committees is solely at your discretion. So go ahead and kick those academic nerds off the advisory committees and replace them with industry-funded friends.

Step 2: Liberally add industry-funded junk science to your liking

Promote the “studies” of your new industry-funded advisory committee friends. Bonus points if they use junk science to show that health benefits from reducing smog “may not occur,” rising carbon dioxide levels are beneficial to humanity, or that people don’t want more fuel efficient cars and trucks. At the same time, give your employees new talking points on climate change to ensure any public facing communications either cast doubt on the science your agency has previously relied on or doesn’t mention it at all. Ruthlessly reassign or fire any employee who fails to comply.

Step 3: Bake junk science into the record

This step is important. Copy the text from industry-funded studies into your official justification to reevaluate, suspend, or rollback rules that science has already shown to be effective. The fastest and easiest way to do this is to just copy the text verbatim. Don’t worry that the administrative record supporting the original enactment of these regulations is chockfull of academic, peer-reviewed studies and thousands of public comments that demonstrate why these regulations are reasonable, achievable, and necessary. Also ignore trepidation from agency career staff who think you are opening the agency to legal challenges or failing to use sound science to justify your agenda.

Step 4: Set legality setting to uncertain, and wait until lawsuits have settled

Use the vast legal resources at your disposal to make any legal challenges to your efforts take as long as possible, which, in the federal court system, can be a very long time indeed. While the courts struggle with whether you have overstepped your authority, your rollback will remain in place – effectively stymying the impact of the regulation on industry for potentially years.

Step 5: Clean your workspace to eliminate traces of corruption and outrageously bad ethics

Make sure you have the support of your boss as you engage in some light to medium graft and corruption. You will probably need a soundproof “privacy booth” that costs taxpayers close to $43,000, a security detail that costs $3 million and protects against non-existent death threats, and a cheap condo rented from the wife of corporate lobbyist for the fossil fuel and auto industries. Keep public leaks of your missteps to a minimum and refrain from using social media to say anything of value.

Overall, this recipe is a disaster for both independent science, and public health. Help UCS push back against Pruitt’s effort to cook this regulatory rollback soup by checking out our new nationwide mobilization effort called Science Rising. This effort isn’t a one-day march—it is a series of local activities, events, and actions organized by many different groups. Our shared goal is to ensure that science is front-and-center in the decision-making processes that affect us all—and to fight back against efforts that sideline science from its crucial role in our democracy.

Will you join us to keep #ScienceRising?


Newsflash: Better Fuel Efficiency is Good For Jobs

Factory worker in a car assembly line.

For all the rhetoric coming from the administration around proposed rollbacks to the EPA’s vehicle emission standards, one would think that existing standards are somehow inflicting damage on our economy.  EPA administrator Scott Pruitt even gave a shout out to the “Jobs” signs at the event where he announced the EPA will be rolling back the standards.  But he’s got it all wrong. Keeping the standards strong is the best way to help grow jobs and support our economy.  Investing in technology advancement in the auto industry and saving consumers money on fuel – both outcomes of clean car standards – help to create jobs and make our economy stronger.

“I love these signs, particularly the ones that say ‘Jobs’.” EPA Administrator Pruitt, April 3, 2018 in announcing rollbacks to federal vehicle emission standards. Analysis by Synapse Energy Economics shows that keeping emissions and efficiency standards strong will create jobs.

A new analysis by Synapse Energy Economics examined the existing state and federal clean car standards currently on the books through 2025 to estimate their impact on US jobs and the US economy.  They found clean car standards will:

  • Add more than 100,000 jobs in 2025 with that number increasing to more than 250,000 in 2035.
  • Increase US gross domestic product by more than $13 billion in 2025 and more than $16 billion in 2035.
  • Save consumers nearly $40 billion in annual fuel costs by 2025 and $90 billion by 2035

For details, visit see our fact sheet: Cleaner Cars Are Good for Jobs.

Why the good news?

So wait a minute.  Doesn’t it cost money to make cars more efficient and less polluting?  Yes.  But just like that more efficient refrigerator might cost a little extra upfront, the lower operating costs more than make up for it, leaving more money in your pocket to spend how you like.

It turns out, savings from improved fuel efficiency adds up to billions of dollars every year. To date, Americans have already saved more than $57 billion dollars at the pump since 2010 because of clean car standards. And spending those savings on things other than gasoline is a whole lot better for our economy. (This is old news – I wrote about this in 2011).

In addition, the standards drive the auto industry to innovate. That means more R&D, manufacturing and engineering, creating jobs throughout the supply chain.

What did Indiana University get wrong?

In the administration’s final determination notice to revise the standards, they cite a study by Indiana University, paid for by the Alliance of Automobile Manufacturers, which concluded that clean car standards would cause near-term job losses, but be positive in the long-run.  However, Synapse’s analysis found both short-term and long-term economic benefits.  Why the difference?

Indiana University study’s macro-economic modeling assumes all consumers use cash to purchase their vehicle—in fact, only 30 percent do so—and assumes consumers do not factor fuel economy into their vehicle purchasing decisions, even though evidence shows consumers value fuel economy as well as price when purchasing a vehicle. These erroneous assumptions led to erroneous results that just don’t hold up.

Bottom line: Federal and state clean car standards drive the deployment of more fuel-efficient vehicles. Developing and building these vehicles creates thousands of new jobs, while the money consumers save on fuel can be spent on other goods and services, boosting the economy overall.

The administration’s actions to weaken standards will hurt US jobs and the US auto industry, despite what their signs say and how much Administrator Pruitt loves them (starting at minute 2:33).

5 Things the EPA Gets Wrong as it Re-Evaluates the Fuel Efficiency Standards (and One Thing it Ignores)

Industry Representatives and Administrator Pruitt looking quite pleased at the press conference where they rolled out their rollback of the fuel efficiency standards. Left to right - Peter Welch, NADA, Administrator Pruitt, Mitch Bainwal, Alliance, John Bozzella, Global. Screenshot from C-SPAN

On Monday April 2nd, the EPA released a “redetermination” of the incredibly popular and successful car and light truck global warming emissions standards – spoiler alert – EPA said that the standards are not appropriate and need to be weakened.  As a reminder, the Obama administration previously completed the mid-term evaluation of the standards and issued a Final Determination that the standards are appropriate out through 2025.  Within a month of taking office, Administrator Pruitt promised that he would redo the Final Determination and voilà – here it is.

Reading the EPA’s redetermination is mind-boggling – it is basically a regurgitation of industry talking points put forward by the Alliance of Automobile Manufacturers (Alliance) and Global Automakers (Global) in the public record.

Some comments that were in opposition to the auto industry talking points were alluded to in the document, but there is no substantive evaluation of any of them. Nothing approaching a robust technical debate of any information is presented in this report — it is simply declarative, substituting the political will of the Administrator to side with industry for the hard, ignoring the scientific rigor found in the 2017 Final Determination.

Although the redetermination is full of questionable assumptions and strange conclusions, we picked five falsehoods that are core to their reasoning and explain why they’re wrong.

Falsehood 1

What they say: Vehicle costs were underestimated in the EPA’s original record that was foundational to the first Final Determination.

Why they’re wrong: When it comes to technology costs, EPA ignores the large number of peer-reviewed publications from its own technical staff showing how manufacturers can meet the 2025 standards, even without significant penetration of plug-in electric vehicles or strong hybrids.  It takes at face value automaker claims about the level of technologies needed to achieve the standards, without actually examining the studies cited by the automakers in making those erroneous claims, studies which in fact contradict the automakers’ assertions that significant penetration of advanced technology is necessary.  It also ignores the latest evidence on the vehicle costs needed to meet the rules.

Falsehood 2

What they say: Gas prices have changed since the rule was finalized in 2012.

Why they’re wrong: Gas price projections did change between 2012 and 2018.  However, when the agency updated their analysis for the mid-term evaluation and did the Final Determination in January 2017, they took that into account.  The projected gas prices used in the previous administrations’ Proposed and Final Determinations are nearly identical to current gas price projections.  Why the current EPA decided to focus on this and say it was a reason to re-evaluate the Final Determination is beyond me.

In one place, the redetermination exclaims that “lifetime fuel savings to consumers can change by almost 200 percent per vehicles based on the assumption on gas prices according to the 2016 Proposed Determination (Table IV.12).”  This is true.  A quick look at the table (below) clearly shows that fuel savings can go from good to great depending on the gas prices expected in 2025, ranging from $1,439 to $4,209 over the lifetime of the average vehicle, which is all good news for consumers.

Falsehood 3

What they say: “Consumers’ preferences are not necessarily aligned to meet emission standards and there is uncertainty on this issue that merits further consideration.”

Why they’re wrong: They got out of their way to say that consumers don’t want fuel efficient vehicles, which is not the data we’ve seen.

They cite an automaker point that only 5% of 2017 sales of normal gasoline-powered vehicles would meet 2025 standards. I don’t know why they would expect today’s vehicles to meet standards 8 years out.  The whole point of the standards is to make sure that vehicles get more efficient over time.

Auto manufacturers redesign vehicles every five years or so – it is in these product redesigns that they make major changes in the body style, and the efficiency of the engine and other components.  In eight years, all vehicles are going through at least one redesign, which is plenty of opportunity to make vehicles more efficient so they meet the standards.

It’s worth noting that models of popular vehicles like the Ford F-150 and Toyota Camry already meet targets well into the future—there is lots of opportunity to improve the efficiency of these vehicles and ample technology to do so, as reams and reams of research ignored by the agency can attest.

In addition, the way the standards work, not every vehicle needs to be exactly in compliance every year because they are based on an average.  There are flexibilities built into the program that allow manufacturers to bank and borrow credits over time because it is understood that vehicles will be more efficient right after a redesign and may be less efficient than the standards when it’s approaching its next redesign.

They also show misleading data on the uptake of electric vehicles by consumers.  Plug-in electric vehicle sales are increasing every year and as more models are introduced in varying sizes, more consumers will be able to consider them as an option for their lifestyle. Moreover, hybrid sales also grew from 2016 to 2017; conveniently, EPA excluded 2017 because it was a chart lifted from Alliance comments rather than analyzed with any sort of independent rationale.

Lastly, multiple polls have shown that consumers value fuel economy strongly. A NRDC poll from 2016 showed that 95% of Americans agree that “Automakers should continue to improve fuel economy for all vehicle types” and 79% of Americans believe that “The U.S. government should continue to increase fuel efficiency standards and enforce them”. Consumers Union has also published multiple polls that show that nearly 9 in 10 Americans think that automakers should continue to raise vehicle fuel economy.  And a poll released by the American Lung Association last week showed that after people hear balanced arguments from each side, their support for the standards increases slightly. It’s like I’m not alone in wanting to spend less money at the gas station.

Falsehood 4

What they say:  Consumers will be priced out of the market by these standards.

Why they’re wrong: Consumers are the greatest beneficiary of these savings.  As noted above, consumers stand to save thousands of dollars in fuel costs over the lifetime of their vehicles. In fact, consumers that finance their vehicles save money as soon as they drive their new cars off the lot, as the marginal cost of the fuel saving technology on their monthly payment is far exceeded by the money they save on fuel every month.

They also say that average new car sales transaction costs have increased as a result of the standards, a point which has been debunked repeatedly.  For example, Consumers Union showed that new car prices have remained relatively flat over the past 20 years with respect to inflation, and used car prices have fallen.  Similarly, auto analysts Alan Baum and Dan Luria showed that transaction prices are on the rise as a direct result of automakers upselling luxury packages to increasingly wealthy consumers.  All of this ignores consumers who are currently saving money due to paying less at the pump, which recent research shows disproportionately benefits low-income individuals, again a study acknowledged and ignored by Administrator Pruitt.

Falsehood 5

What they say: The growing preference for larger vehicles over cars make it harder to comply with the standards.

Why they’re wrong: The popularity of SUVs and light trucks doesn’t undermine the standards—it reinforces the need to maintain their strength.  Rather than setting a single greenhouse gas emission target for the average vehicle sold by a manufacturer, which is what the original vehicle standards did in the 1970’s, the new vehicle standards consider the size and type of the vehicles sold to determine each manufacturer’s target. This ensures that all vehicles improve their efficiency, including trucks and SUVs, while giving automakers flexibility in hitting their targets, based on the vehicles they sell. This system means that no particular vehicle model needs to be “in compliance”; some vehicles can achieve greater fuel economy and others less in a given year and the manufacturer’s fleet can still be in compliance with the standards.

What’s missing from the redetermination?

What they don’t say: Weakening the global warming emission standards endangers public health and welfare by contributing to global warming

Missing from the Revised Final Determination is any mention of climate change or its impacts, which endangers Americans now and into the future and is the reason that EPA sets these standards. Scientists warn that we must significantly reduce emissions of global warming pollutants to avoid the worst effects of climate change, including sea level rise, wildfires, and infectious diseases.  As it stands now, no other federal policy is delivering greater global warming emissions reductions than these vehicle standards. If the EPA completely rolls back the regulations, as some have signaled, that will mean an additional half billion tons of global warming emissions just from the vehicles sold between 2022-2025.  Doing so would make hitting our obligations under the Paris Climate Accord a virtual impossibility, significantly damaging our ability to hold global warming to 2 degrees Celsius.

We knew that this day was coming, but the extent to which this redetermination relies solely on industry arguments and ignores the robust analytics that underlie the original Final Determination is confounding.  It makes me think about the story that came out around Administrator Pruitt’s confirmation, when we learned that he took a letter written by a Devon energy lobbyist and put it on his OK Attorney General letterhead and submitted it to the Department of Interior.

This redetermination feels like that – like he just read the Alliance and Global comments and used their quotes to rewrite the determination.  It’s a slap in the face to everyone who cares about data, analytics, scientific integrity, and our climate.  We know he’s going to propose rolling back the standards in the proposed rule that we expect to see this summer.  The question is by how much.  We will keep a close eye on this and let you know what he proposes and ask for your help in keeping the standards strong.


EPA Rolls Back Fuel Efficiency Standards at the Request of Automakers

Vehicle pollution is a major issue for human health and the environment.

In what comes as a surprise to absolutely no one following the current administration, today EPA Administrator Scott Pruitt issued a redetermination of the appropriateness of the EPA’s vehicle regulations through 2025 and found that they should be made less stringent.  In doing so, he is overturning thousands of pages of hard evidence, and the consequences will be limiting consumer choice, increasing emissions, and undercutting the economy.

This decision is not based on evidence

Last year, I pointed out the strong body of evidence supporting the previous administration’s determination that the standards are appropriate.  The justification for today’s action is considerably slimmer.  Rather than pointing to the fact that these standards are cost-effective for consumers, that we have the technology to meet and exceed these standards by 2025, and that these standards have tremendous positive impacts on the economy, the ideologues currently at the EPA have decided to ignore this evidence and misconstrue how the standards work.

The administrator doesn’t seem to understand that lower gas prices actually underscore the importance of having strong efficiency standards, increasing sales of SUVs don’t affect the ability of manufacturers to meet the standards, and these standards are job creators, which means putting them on hold is going to COST jobs, not protect them.  Sadly, the flimsy document put forth by Administrator Pruitt is just another example of how little this administration cares about facts.

This decision is bad news for the environment

Unfortunately, here’s a fact that is unavoidable: transportation is the leading source of carbon dioxide emissions in the United States.  With more vehicles traveling further each day, it’s critical to ensure that those vehicles are using less fuel.  If the EPA completely rolls back the regulations, as some have signaled, that will mean an additional half billion tons of global warming emissions just from the vehicles sold between 2022-2025.  Doing so would make achieving hitting our obligations under the Paris Climate Accord a virtual impossibility, significantly damaging our ability to hold global warming to 2 degrees Celsius.

Of course, burning more oil isn’t just bad for the environment—it’s bad for national security and terrible for the nation’s pocketbook.

This decision is not good for consumers

These standards have been increasing the availability of more fuel-efficient vehicles in every single class of vehicle—that’s how they were designed.  That means that whether a consumer is looking to buy a small car or a giant pick-up, they are going to save money the moment they drive off the lot thanks to fuel savings that more than compensate for any costs associated with fuel-saving technologies.  This decision will now limit those savings and put manufacturers back in the driver’s seat, effectively determining what consumers are allowed to buy.

Unfortunately, the only way that we have gotten more efficient vehicles on the market for consumers is with strong efficiency standards.  The last time we saw a market shift towards SUVs and pick-ups, it happened under flattened vehicle efficiency standards—the result was that new vehicles averaged worse fuel economy and produced more emissions.  And that increased fuel use hit American consumers especially hard once gas prices started to rise again.

This decision is bad for business

At the turn of the millennium, manufacturers were selling gas guzzlers at a tremendous clip—but in doing so, they entirely neglected investment in their car fleet.  As soon as gas prices began to rise again, sales of these largest vehicles fell, as Americans clamored for more efficient options.  And when it came to the Detroit Three, those efficient choices simply weren’t there, sales plummeted, and taxpayers had to bail out the industry.  The actions the industry has taken to push the administration to weaken these rules is setting us up for a repeat of history.

Moreover, by putting more of consumers’ hard-earned dollars into the tank to pay for gas instead of being able to reinject that into the economy, this action will cost jobs.  An independent analysis released this week shows that the economy is slated to grow by more than $16 billion, creating 265,000 jobs by 2035, if the standards are held today, a large chunk of which are explicitly created in automotive manufacturing and its supply chain.  Suppliers themselves are well aware of the benefits these rules have provided and the negative consequences of a rollback—unlike automakers, they have also been willing to step out and support strong standards.

This decision relinquishes leadership on climate back to the states

Under the Clean Air Act, California has the authority to set more stringent vehicle emissions standards, and states have the right to adopt these standards.  Prior to the federal EPA standards, California and 13 other states adopted strong emissions standards for passenger vehicles through 2025 and hold a waiver from the EPA to maintain those standards.  However, because those rules are so similar to the ones currently on the books, they had been willing to accept as compliance with those rules compliance with the federal program.

Today’s action by Administrator Pruitt completely undermines the promise of a single national program by weakening the federal program.   The states understand the technical and economic evidence that shows manufacturers can achieve strong standards in 2025—and they face the consequences of global warming if they do not.  They have therefore signaled that they will no longer follow the federal program.  These states make up more than 1/3 of the new vehicle market, ensuring that folks in California and New York are going to have more efficient vehicle choices than those back in Detroit or Pruitt’s home state of Oklahoma.

This decision is a disaster of the automakers’ making

We’ve seen lip service given by automakers about not wanting a rollback of the standards, but this is nothing but puffery as they try to distance themselves from an unpopular administration that has given them exactly what they asked for.  Too-late claims about needing to act on climate change ring hollow given the industry’s continued efforts to undermine the nation’s strongest climate policy at every turn—if automakers truly wanted to act on climate, they would support the rules as they stand, not beg the administration to change them.

Inevitably, what this means is that the Administration is angling for a court battle over its technically unjustifiable standards, creating uncertainty in the process.  Of course, this is nothing new—the Pruitt administration has found itself at the center of a number of lawsuits for failing to adequately uphold the mission of the agency to protect public health and the environment.

This decision is not the end of the line

The industry is now facing complete uncertainty—exactly the situation that the previous administration sought to avoid by finalizing the rules in 2017.  But by pushing for a new rule as they have, the auto industry can only blame itself for this chaos.  And unfortunately, it would be the rest of us that will have to bear the cost, not only by paying more at the pump but by dealing with the ensuing impacts on the climate from veering away from the sustainable pathway we need to be on in 2025 and beyond.

The one sliver of hope is that this action is just the first step in the process, which means there is still time to right this wrong.  The administration’s next step will be to propose what it would set as a replacement for the cost-effective standards now on the books—giving an opportunity for stakeholders and the public writ large to weigh in.

In responding to that proposal, the industry needs to stand up for the science and protect the environment, or they’ll remain guilty of using an ideological administration to ignore the facts, costing the public deeply.  And you can bet the public will be watching—and hopefully giving the agency and the industry a piece of its mind.

No Shortcuts for Dirty Diesel Engines

Over the past eight years, I have studied air pollution of the United States and other countries around the world. My career has been centered around using high-performance computer models to identify the biggest air pollution offenders. The air pollution research community is well aware that the U.S. diesel truck fleet has the potential to spew hundreds of thousands of tons of air pollutants each year, if left uncontrolled.

Thankfully, over the past few decades, the U.S. government has made excellent strides in regulating heavy-duty diesel pollution in the form of emissions standards. So, when I was informed by UCS advocates that EPA Administrator Scott Pruitt proposed last November to allow glider vehicles to be exempt from modern emission control standards, I was floored. To be completely honest, I was angry.

You’re probably wondering what a glider vehicle is and why this action made me so upset. Glider vehicles are heavy-duty trucks with new bodies and refurbished engines with old or non-existent emissions control technology. Engines in these trucks can date back to the 1990s. The proposal would exempt glider vehicles from the current emissions standards that are in place for new heavy-duty trucks. This loophole has been exploited by a few small manufacturers, and the industry has grown exponentially over the last 6-8 years.

Effective emissions testing

EPA’s proposal cited a glider manufacturer-funded study by Tennessee Technological University (TTU), which claimed that glider vehicle emissions were no worse or even better than those from modern engines. The study has since been renounced by TTU President Philip Oldham for its questionable methods and execution.

So, how should heavy-duty engine emissions be tested? This is no small task as testing requires expert operation of advanced equipment. The air pollution community has published several peer-reviewed studies about proper emissions testing practices. Effective emissions rate testing involves simulating cycles for many scenarios: cold start, congestion-related stop and go traffic (creeping), arterial road traffic (transient), and highway cruising. Emissions testing on glider vehicles should be held to these standards, and lawmakers should be wary of testing that shortcuts trusted practices. The now renounced TTU study did not use standard test cycles during their glider vehicle testing, they did not repeat their trials, and PM2.5 emissions were subjectively quantified by visual inspection. Subsequently, a proper study was conducted by an EPA staff member in Ann Arbor, and particulate emissions from the glider engines were so high that the testing equipment shut down. Clearly, the petition did not have a solid study to stand on.

University of California Riverside College of Engineering Center for Environmental Research and Technology (CE-CERT) heavy-duty engine emissions tester.

Diesel pollution has real effects on human health

Detailed studies have been published in well-respected journals by researchers in the air quality community to understand the links between diesel exhaust exposure and human health. I was fortunate to take part in a major collaboration between Georgia Tech and Emory University to investigate the links between air pollution and health in the southeastern United States. My colleagues at Emory University showed that the odds of preterm birth for expecting mothers increases with increased exposure to traffic-related air pollutants, nitrogen dioxide (NO2) and elemental carbon (component of soot). NO2 and soot are the glider vehicle pollutants of greatest concern.

Health effects from exposure to pollutants can be estimated with reactivity tests that measure oxidant production potential. Oxidant production within the body creates an imbalance with anti-oxidants, leading to the breakdown of cellular material and the disruption cell homeostasis. Inhaled pollution has been linked to oxidant-generation potential in the lungs, causing inflammation and decreased lung capacity. My colleagues at Georgia Tech found that in Atlanta, GA, heavy-duty diesel pollution was estimated to cause approximately 14% of oxidative potential. Allowing more glider vehicles into the heavy-duty truck fleet increases the risk of respiratory and gestational ailments for susceptible individuals living or working near highways.

Low-income neighborhoods hurt most

Further, allowing more dirty diesel vehicles on the road will reverse pollution reductions, especially near highways. Frankly, this is what makes the proposal so dangerous. The likelihood of living near a highway increases with decreasing median household income. Therefore, an increase in roadway pollution from poorly-regulated engines would disproportionately affect poorer neighborhoods with fewer healthcare resources. People of color who already have higher risks for ailments, such as asthma and heart disease, also tend to live closer to highways. So, while the proposal will save truck owners from paying for modern emission control technology, poor people and people of color will most likely bear the heaviest public health burden if the proposal goes into effect.

Stop dirty diesel

Simply put, the glider vehicle proposal should not go forward. The emissions study cited by the proposal was poorly conducted (and ultimately withdrawn), poor people and people of color will suffer from increased roadway pollution, and susceptible groups will have increased health risks. Please let science lead this cause. Slightly cheaper trucks are a terrible substitute for human health.

Dr. Cesunica E. Ivey is an incoming Assistant Professor of Chemical and Environmental Engineering at the University of California Riverside. She is currently a visiting scientist in Princeton University’s Atmospheric and Oceanic Sciences Department. Dr. Ivey studied environmental engineering at the Georgia Institute of Technology, and her research expertise is in modeling regional air pollution from natural and anthropogenic sources.

Organizations: American Geophysical Union; American Association of Aerosol Research, 500 Women Scientists

Science Network Voices gives Equation readers access to the depth of expertise and broad perspective on current issues that our Science Network members bring to UCS. The views expressed in Science Network posts are those of the author alone.


Automakers Turn to Climate Deniers in Quest to Lower Fuel Economy Regulations

Last month, the Alliance for Automobile Manufacturers submitted a report to the National Highway Traffic Safety Administration/Department of Transportation calling into question impacts of climate change and tailpipe pollutants in an effort to undercut the need for fuel economy regulation.  The Alliance is the trade group for Chrysler, Ford, General Motors, and Toyota, among others.  The report funded by the Alliance was written by industry shills with ties to the Heartland Institute and General Motors, and it flies in the face of automaker claims by the likes of Ford and Toyota that they are taking climate change seriously.

Taking a page straight out of the Disinformation Playbook

The group the Alliance funded to put together the report has a long history of working against environmental regulations—that’s pretty much their schtick.  Past clients include the American Petroleum Institute, the American Coal Council, the U.S. Chamber of Commerce, Monsanto, the American Enterprise Institute, and, of course, the Alliance.

The report follows a familiar pattern, generally calling into question the science behind the health impacts of [insert pollutant here], frequently based on a convoluted and biased modeling effort masquerading as science.

If you’re familiar with the Disinformation Playbook, then what’s in the Alliance’s paid-for report will sound familiar:

Automakers are running plays straight out of the Disinformation Playbook in order to try to weaken consumer and environmental protections.

  • “The Fake”—The papers cited to support weakening environmental protections are often paid for by industry and/or published in journals with weak peer-review standards and disclosure policies. For example, the Alliance report cites studies by Tony Cox which were directly funded by the American Petroleum Institute in order to cast doubt on the proven health impacts of soot.  Furthermore, the journals in which the articles were published are known homes for questionable industry-funded research, such as Regulatory Toxicology and Pharmacology.
  • “The Fix”—Two authors cited by the Alliance (Stanley Young and Tony Cox) are now in advisory roles for the EPA as part of the administration’s move toward soliciting their advice from industry-funded scientists. And the Alliance already has strong support within the Department of Transportation for its pitch—Deputy Secretary Jeff Rosen defended GM in liability litigation and fought the EPA’s regulation of carbon dioxide while at the Office of Management and Budget, and his previous employer (Kirkland and Ellis) was employed at least twice by the Alliance in suits to prevent California from regulating global warming emissions from vehicles.
  • “The Diversion”—Rather than summarizing the most recent body of research on climate impacts, as would be done by anyone genuinely interested in ensuring policy is based on the best science, the report cherry-picks studies to weaken the case for acting on climate and reducing emissions from vehicles, either by selecting outliers or misconstruing the findings of the research. For example, the Alliance selected “key points” from a paper on drought variation that seem to diminish the role of climate change on drought and flood, ignoring the paper’s other findings related to increasing temperatures and a “substantial intensification of the global hydrologic cycle [that] is likely in a warming world.” More recent studies citing this work build upon these ignored findings based on the most current data and find evidence for the increasing role of this temperature trend, including work by the authors of the cited study.
History repeating itself

Part of me is not surprised that the automakers have adopted this strategy to mislead on the science, because it’s a tactic they’ve used in the past time and time again, as I outlined in the UCS report Time for a U-turn:

These tactics are par for the course for the Alliance – our report Time for a U-Turn details more than six decades of industry interference with state and federal safeguards, encompassing all facets of protections: fuel economy, safety, and air quality.

  • 1950s: Automakers denied that smog was a problem and colluded to delay deployment of pollution controls in an effort to forestall regulation.  They also ran the same play on seatbelts, claiming that “nobody knows” if they save lives despite a decade of definitive research.
  • 1980s: Automakers claimed that there would be no health benefits for stronger pollution standards under the Clean Air Act.  This delay of course eventually led to state action and amendments to the Act in 1990 because of the nationwide problem with smog that finally even Congress couldn’t ignore.
  • 1990s: The lead voice for the automakers on revisions to “soot and smog” air quality requirements claimed that a temporary 20 to 30 percent reduction in lung function wasn’t a health effect.  It was also in the 1990s that automakers began their climate skepticism, claiming that climate models were too uncertain to act upon.  Chrysler CEO Robert Eaton even penned a Washington Post op-ed opposing ratification of the Kyoto Protocol, claiming action on climate was “unwise and unnecessary.”

In our report, we called for the industry to make a U-turn on its behavior, but the sad fact of the matter is that the auto industry does not seem to want to change, and this most recent submission to the government shows us just how much they are still mired in their questionable tactics of old.

It’s time for automakers to lead

The vehicle efficiency standards set back in 2012 were the result of support from the automakers, who worked closely with regulators to design the regulations.  For an industry with a decades-long history of fighting regulation, this about-face was the result of a harsh confrontation with reality.

Just before the Great Recession, the Detroit Three had fallen on hard times as a result of neglecting to invest in the efficiency of their passenger car fleet.  When gas prices rose, the companies’ sales and profits dropped like a rock, requiring massive loans.  In this context, the industry seemed to finally recognize the value in industry-wide efficiency standards that hadn’t been raised in decades.

Today, however, that leadership is nowhere to be found.  Automakers are urging he current administration to weaken standards, and Pruitt’s EPA and Chao’s DOT seem dead-set to do exactly that.  While suppliers recognize the harm that pulling back on these standards will do to the industry, automakers are stuck in the same mindset that cost the country, and our environment, so deeply in the past.

Now, not only are automakers trying to weaken the standards—they are calling into question the need for regulations at all.  NHTSA would do well to ignore this rubbish in order to make sure its decisions are best on the best available science, but if automakers like Ford and Toyota truly think that climate change needs to be addressed, then it is incumbent upon them to keep their trade association from putting out this kind of anti-science drivel.

Automakers need to stand up for science and call out this nonsense, or they stand complicit on the side of rhetoric and lies in weakening our environmental protections just to pad their profits.


Scientists Stand Up Against Shoddy Science on Glider Vehicles

That shiny new truck could have a 15-year-old engine that doesn’t meet today’s standards, and you might never know…except for the plumes of pollution behind it, if it’s a glider vehicle. Photo: Jeremy Rempel. CC-BY-ND 2.0 (Flickr)The newest twists and turns in the glider vehicle saga

Glider vehicles have gone from being a niche issue to a major conversation piece both here in DC and now also in Tennessee.  The villains are still Environmental Protection Agency (EPA) Administrator Scott Pruitt, Fitzgerald Glider Kits, and Congresswoman Diane Black.  The new heroes are the Tennessee Tech University (TTU) faculty and students.

First a quick recap of the issue: Glider vehicles are new truck bodies that have old, polluting engines in them.  As noted in my colleague Dave Cooke’s previous blogs, the particulate matter (PM) emissions alone from these vehicles will cause an additional 1600 premature deaths annually (assuming they make 10,000 vehicles a year). And the nitrogen oxide (NOx) emissions are 10x that of the emissions from the Volkswagen diesel cars that were outfitted with defeat devices for every year this loophole remains open.

These dirty polluting trucks are terrible for the environment, our health (particularly the health of people who live along trucking corridors, predominantly people of color, which was acknowledged in an early draft of the proposal to roll back the rule), and for companies and dealers that sell new trucks that actually meet the current PM and NOx emissions standards.

The glider vehicle loophole was closed as part of the Heavy-Duty Fuel Economy and Greenhouse Gas Emissions regulations that were finalized in 2016 – Administrator Pruitt is looking to repeal the part of the rule that limits the number of glider vehicles that can be sold with pre-2010 engines.

But EPA Administrator Scott Pruitt doesn’t seem to care about any of that.  There are several different layers of malfeasance happening here, many of them come directly out of my colleagues’ Disinformation Playbook.  I’ll start with the science interference.

The newest twist in this story is about the “study” that TTU performed and Fitzgerald included in their request that the agency repeal the rule that limits the production of super polluting glider vehicles.  I will admit, here at UCS, we were incredulous about the brevity of the “data” and lack of methodology included in the “study” – it’s basically a table with almost no information – it includes carbon monoxide (CO) emissions, which have been under control in transportation for some time, an acknowledgement that all trucks they tested have higher NOx emissions than allowed, and said that the PM emissions were “below the threshold detection point” (because they didn’t measure it! check out Dave’s blog on this point – it’s gold). Because we are a bunch of science nerds, we wondered who would have signed off on this testing?  What was the level of scientific rigor?  Did no one at the university notice that the study was designed, bought, and paid for by Fitzgerald?

Tennessee Tech University faculty fight back

Unknown to us, there was a giant debate happening among the faculty at Tennessee Tech University about this very “study.”  It turns out that this “study” really is just a politically-driven hack job and the faculty at Tennessee Tech University aren’t having it.

The Faculty Senate business meeting minutes are amazing and downright enjoyable to read.  They appear to have first talked about it on January 29th and the Faculty Senators just ripped into Tom Brewer (more on him later), asking all of the questions you would expect – who conducted this research? Did you actually not measure PM? Do you not realize this looks like a conflict of interest? etc.  The very next day, they approved a resolution that starts by saying that their reputation has been damaged by this “study” and demands an external investigation of the person who led it (Tom Brewer), that TTU President Oldham withdraw university support for the “study,” that all research and associations with Fitzgerald are suspended, and that there is an immediate internal investigation of the “study.”

It took until February 19th, but TTU President Oldham sent a letter to the EPA asking them to disregard the “study,” as they were going to submit it for peer-review.  A win for science!!

I promised more information about Tom Brewer, the person who apparently oversaw the “research” for the “study.”  Brewer has a BA in business administration and previously worked in product administration at GM, was the president of the Board of the Tennessee Automotive Manufacturers Association, and was brought to TTU to be “an industry liaison.”  This is the “expert” that ran the study.  Fitzgerald apparently has “no engineers experts on staff” nor any of the appropriate equipment to conduct the testing.

Corporate cronyism

There is a political story that underlies all of this – namely that Fitzgerald, the largest glider vehicle manufacturer, happens to be located in Congresswoman Diane Black’s district (she’s running for Governor of Tennessee this year, if you want to keep tabs on her).  Representative Black has long sought to ensure that these zombie trucks continue to be sold in high numbers – she has repeatedly introduced (unsuccessful) appropriations riders to stop glider vehicles from being regulated.  She is also the person that TTU sent their “study” to and it was that letter that got forwarded on and included in the Fitzgerald request to roll back any regulations for glider vehicles.

In addition, it is worth noting the timing of this whole withdrawal process.  At one point, Fitzgerald said that they would still be able to make a profit if sales volumes were capped; this stance changed shortly after Administrator Pruitt was confirmed, however.  Last year, Fitzgerald met with Administrator Pruitt in May, submitted their petition for reconsideration in July, and the notice that this was going to be revisited came out in August. In December, EPA held a hearing at which several UCS supporters testified (thank you!!) and over 26,000 UCS supporters sent comment letters to EPA requesting that this loophole stay closed – our supporters are awesome!

Fitzgerald is clearly working to exert their influence at every turn.  They are sponsoring university research that they are refusing to release details of (The Fake in the playbook).  And about at the same time, Fitzgerald gifted land to the university to build a Center for Intelligent Mobility (The Screen in the playbook).  They are clearly behind the entire repeal effort happening at the EPA and are the reason that Congresswoman Black has been championing zombie trucks for years (The Fix in the playbook).

The uproar at Tennessee Tech University, the blatant political motivations that have been in the mainstream press here, here, and here, Congressional scrutiny, and common decency aren’t likely enough to keep this loophole you could drive a truck  through closed.  I think it’s incredibly likely that Administrator Pruitt goes ahead with his proposal to allow unregulated glider vehicle sales.  It’s up to all of us to let him know that that’s not ok.  Please take this action to speak out against this and we’ll keep you updated on the next steps.


California’s Clean Fuels Standard Poised to Get Even Better

California State CapitolPhoto: Rafał Konieczny CC-BY-SA-4.0 (Wikimedia)

Next month, the California Air Resource Board (CARB) is considering amendments to extend and strengthen the state’s pioneering Low Carbon Fuels Standard (LCFS).  The LCFS works in concert with other climate and vehicle policies to cut oil use and transportation emissions by promoting the use of cleaner transportation fuels ranging from biofuels to renewable electricity.

CARB staff’s proposal to the board would extend the policy to 2030 and double the emissions reduction target from a 10 percent reduction in average fuel carbon intensity in 2020 to a 20 percent reduction in 2030.  CARB is also increasing opportunities for renewable electricity and adopting rules to account for carbon capture and storage (CCS) used in the production of transportation fuels.

What is a Low Carbon Fuels Standard?

The LCFS was established in 2009 to provide a steadily growing market for cleaner transportation fuels. The program regulates the “carbon intensity” (i.e., the amount of global warming emissions per unit of energy output) of fuels, taking into account the emissions generated over each fuel’s life cycle, from extraction and production to delivery and use. Under the LCFS, petroleum refineries and fuel importers must gradually reduce the average carbon intensity of the fuels they sell, according to a schedule that currently requires a 10 percent reduction in 2020 relative to 2010. To comply with the law, petroleum refiners and importers can either blend low carbon fuels into the fuel they sell, buy credits generated by low-carbon fuel producers and users, or both.  In 2016, the largest sources of clean fuel credits were ethanol, renewable diesel, biodiesel, electricity, and biomethane.

What is CARB proposing to change?

In the amendments proposed by CARB staff earlier this week, the 10 percent target for 2020 is replaced by a 20 percent target for 2030.  CARB also proposes adjustments to the schedule for 2019 and 2020 so that requirements for low carbon fuels grow at a steady rate between now and 2030.  This is a change compared to earlier discussion of the LCFS extension in the scoping plan, which had not proposed any schedule changes prior to 2020 and had proposed an 18 percent target for 2030.

The new schedule strengthens the program in several ways.

  • A 20 percent target for 2030 will deliver more support for low carbon fuels over the long term than either the current 10 percent standard or the previously proposed 18 percent standard.
  • The proposed schedule grows steadily and predictably at 1.25 percent a year, while the earlier proposals had stringency that increased rapidly from 2018 to 2020, was frozen in place from 2020 to 2022, and then grew 1 percent a year thereafter.

The proposal is simpler and more predictable, and sends a clear message to the market for low carbon fuels that demand will grow steadily over the long term.  CARB’s analysis shows that the proposed standard is readily achievable, and in the coming weeks we will share some additional analysis, which suggests that even more ambitious targets are feasible.

The growing importance of electricity as a transportation fuel

It’s been clear for a while that powering cars with electricity is cleaner and cheaper than using gasoline, and our latest analyses shows this trend is accelerating.  EVs in California emit as much carbon pollution on full lifecycle basis as a gasoline car getting more than 100 miles per gallon, and save EV drivers from $571 to $1077 per year in fuel costs, depending on where they charge.

Photo: RedBoy [Matt]/Creative Commons (Flickr)

As more EVs hit the road, electricity is playing an increasingly important role in the LCFS. Our recent fact sheet, California’s Clean Fuel Standard Boosts The Electric Vehicle Market, explains the how the LCFS is making EVs more cost effective not just for private car drivers, but also for transit agencies and others.

Electricity used by cars, trucks, rail lines, and even forklifts comprised a growing share of the emissions reductions credited under the LCFS, rising from less than 1 percent in 2011 to 10 percent in 2016. These emissions reductions create value, about $92 million in 2016, which is helping to accelerate the transition to electric drive.  Thanks to LCFS EV credits, utilities are giving rebates or level 2 chargers to their customers that own an EV.  And LCFS credits are also helping public transit fleets go electric.  At credit values of $100 per metric ton of emissions avoided, transit agencies earn about $9,000 per year for each electric bus in their fleets.

The LCFS amendments include more flexible provisions to recognize EVs that charge up with renewable power.  Electric vehicles charged with renewable power are among the cleanest ways to get around, and its important to recognize this potential and support it within the LCFS.  In the next decade we will see EVs move into new roles, including some high mileage applications like hauling freight and providing autonomous taxi rides.  Because LCFS credit generation is directly tied to the quantity of low carbon fuel use, electric vehicles that drive the most miles and displace the most fuel generate the most credits.  The LCFS is poised to play an even more important role accelerating the electrification of the transportation system in years to come.

Carbon capture and storage creates big opportunities to clean up many fuels

CARB is also proposing a new protocol to account for Carbon Capture and Sequestration (CCS) within the LCFS.  CCS is often discussed in the context of reducing emissions from fossil fuel fired power plants, but transportation fuel producers have some unique opportunities to capture and sequester carbon as well.  One of the most advanced CCS facilities in America is actually operating at a corn ethanol plant in Illinois.  Ethanol production is a natural candidate for carbon capture because the fermentation process used to convert corn to ethanol releases nearly pure carbon dioxide, which can be captured without the complex and energy intensive process required to separate a dilute stream of carbon dioxide from other exhaust gasses at power plants.  Also, many ethanol plants are located near geological formations well suited to sequestering carbon. But ethanol producers are not the only fuel producers who could sequester carbon.  Oil refiners or companies that extract oil also have opportunities to integrate CCS into their operations.

Photo: Archer Daniels Midland

Accounting for the carbon benefits of CCS is complex.  CARB’s rules will clarify what must be done to ensure the permanence of the storage, and to account for energy and emissions associated with the CCS process.  Getting this right is complicated and important.  As if often the case, CARB’s work will advance the state of practice for regulators around the world.  This is even more important now that the U.S. Environmental Protection Agency is hamstrung by its administrator.

The CCS provisions in the LCFS are a concrete means of holding fuel producers accountable for the emissions from their supply chains, and theyalso make the LCFS more flexible.  If an oil refinery implements CCS, it can reduce the emissions associated with its fuel production within its own facility, helping meet its own obligations under the LCFS instead of relying solely on other parties to produce cleaner fuel.  When a corn ethanol facility implements CCS, it can produce more climate benefit from the same fuel it produces today.  This gives the cleanest ethanol producers a chance to generate more credits and make more money without expanding the amount of corn used to make ethanol, thus avoiding increases in emissions associated with farming or land use.

CARB’s CCS protocol and rules create a powerful incentive for biofuel producers, oil refineries, and other fuel producers to capture and sequester carbon dioxide that is currently released into the atmosphere. A recent change in federal tax policy makes CCS projects even more attractive, offering a tax credit of $50 per ton of carbon dioxide sequestered.  Together, these policies may jump start commercial deployment of CCS.

A flexible policy that gets better over time

The flexibility of the LCFS is one of its key strengths.  As I described in my recent report, Fueling a Clean Transportation Future, all of our transportation fuels can get cleaner if fuel producers are held accountable to reduce their emissions.  Looking into the future, it’s impossible to know what mix of low carbon biofuels, vehicle electrification, CCS or other strategies to cut emissions from fuel production will progress most rapidly.  But by setting steadily growing long term goals, the LCFS supports innovation and progress across the transportation fuel sector.  By adopting these amendments, extending the LCFS to 2030 and doubling the emissions reduction targets, the California Air Resources Board will be speeding California on its way to a clean transportation future.

New Data Show Electric Vehicles Continue to Get Cleaner

New data from the US EPA on power plant greenhouse gas emissions are in, and electric vehicles (EV) in the US are even cleaner than they were before. The climate change emissions created by driving on electricity depend on where you live, but on average, an EV driving on electricity in the U.S. today is equivalent to a conventional gasoline car that gets 80 MPG, up from 73 MPG in our 2017 update.

Cleaner electricity means cleaner EVs

Based on data on power plant emissions released in February 2018, driving on electricity is cleaner than gasoline for most drivers in the US. Seventy-five percent of people now live in places where driving on electricity is cleaner than a 50 MPG gasoline car. And based on where people have already bought EVs, electric vehicles now have greenhouse gas emissions equal to an 80 MPG car, much lower than any gasoline-only car available.

Map of EV emissions in the US

To compare the climate-changing emissions from electric vehicles to gasoline-powered cars, we analyzed all of the emissions from fueling and driving both types of vehicles. For a gasoline car, that means looking at emissions from extracting crude oil from the ground, getting the oil to a refinery and making gasoline, and transporting gasoline to filling stations, in addition to combustion emissions from the tailpipe.

For electric vehicles, the calculation includes both power plant emissions and emissions from the production of coal, natural gas and other fuels power plants use. Our analysis relies on emissions estimates for gasoline and fuels production from Argonne National Laboratory and power plants emissions data recently released by the US EPA.

EVs getting cleaner over time

An important difference between EVs and conventional cars is that existing EVs can get cleaner—and, over time, they are getting cleaner. It’s difficult to make burning gasoline cleaner, and electricity is trending cleaner over time as we shift away from coal and add more renewables. This means that EVs that were sold years ago can run much cleaner than when they were purchased. Our initial analysis of EV emissions used data from 2009, while this update incorporates 2016 data. By switching between these two maps, you can see the improvement made in many regions of the US.



More efficient EVs now available too

The maps shown above are based the efficiency of the average EV. However, there are now options on the market that are even more efficient. Using one of these more efficient EVs (Hyundai Ioniq BEV, Prius Prime, and Tesla Model 3) means lower emissions. With these cleaner EVs, 99 percent of the country is in a region where electricity emissions would be lower than a 50 MPG gasoline vehicle.

How do other EVs compare? Use our EV emissions tool to estimate the emissions from a specific EV in your area.

The most efficient EVs are much cleaner than even the best gasoline cars in many regions of the US. Currently the most efficient EVs are the Hyundai Ioniq BEV, Tesla Model 3, and the Toyota Prius Prime (while operating on electricity).

A trend that’s likely to continue

Electric vehicles produce less emissions now because the electric grid is getting cleaner. Over the last ten years, the fraction of power from coal has fallen from nearly 50 percent to 30 percent. Over the same time, utility-scale renewable power like solar and wind power have grown to make up 10 percent of electricity generation.

This analysis relies on data from power plants for 2016, the most current data that includes details on the geographic location of emissions. However, based on the overall data on from 2017, it looks like emissions will continue to fall, with both coal and natural gas declining while renewable power continues to increase.

The falling emissions from electric power over the last decade also highlights the need to work to clean up electricity generation and transportation now. While we are moving in the right direction with renewable power and growing numbers of EV models, it takes time to replace existing power plants and gasoline cars. It’s vital that we accelerate the adoption of EVs, even if all power is not yet from renewable or low-carbon sources.

Utility-scale electric power generation. Power from coal has dropped over the last decade and clean renewable power has increased. Data Source: US Department of Energy, Energy Information Agency.