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VW Settlement: A Needed Jolt for Electric Trucks and Buses, But More Is Needed

It has been nearly three years since the Volkswagen diesel scandal first broke. Since then, a handful of settlements have been reached, one of which provides states funding to offset the extra nitrogen oxide (NOx) pollution emitted by defective Volkswagens.

A dozen states have recently finalized such funding plans and others are taking public comment on draft plans. These plans offset a majority of the pollution by providing financial incentives for the purchase of clean trucks and buses.

And rightfully so. Trucks and buses make up a small fraction of vehicles on the road (7 percent), but a disproportionately large fraction of emissions. In fifteen states, heavy-duty vehicles make up the largest source of NOx emissions from the transportation sector, despite being significantly outnumbered by cars.

For many states, the Volkswagen settlement likely represents their largest single investment in clean technologies for heavy-duty vehicles. Combined with the allure of a scandal, there’s a deserved buzz about these spending plans.

As news around the Volkswagen settlements continues, there’s two important things to keep in mind: (1) this settlement is only a fraction of the incentive funding we need to spur the deployment of electric trucks and buses, and (2) if history is our guide, incentives are only part of the equation. Solutions to global warming and air pollution ultimately rest on large scale market shifts in response to plans, commitments, and standards, such as vehicle fuel efficiency standards and renewable electricity standards.

Righting the wrongs of the Volkswagen diesel scandal

If you haven’t followed the Volkswagen diesel scandal, here’s a quick recap: In 2015, Volkswagen (and its subsidiary Audi) admitted to intentionally cheating on emissions tests affecting 580,000 diesel cars sold in the United States since 2009. The cars’ emissions of NOx (a precursor to ground level ozone, aka smog) are a head-shaking 10 to 40 times higher than what’s allowed under law.

Settlements were reached between the California Air Resources Board (which led the investigation against Volkswagen), the US EPA, and Volkswagen requiring the company to (1) buy back or fix the polluting vehicles (estimated at $10 billion); (2) invest in charging infrastructure and consumer education for electric vehicles ($2 billion); and (3) provide funding to states and tribes to offset the extra pollution emitted by the cars ($2.9 billion).*

States are taking public comment on plans to offset pollution from Volkswagens

Actions eligible to offset pollution include replacing old trucks, buses, and freight equipment. Up to 15 percent of a state’s plan can also be used for electric vehicle charging infrastructure and hydrogen fueling stations.

States have discretion as to which types of vehicles and equipment to invest in, whether zero-emission battery and fuel cell technologies or combustion technologies. Importantly, plans must consider how the investments can benefit communities that bear a disproportionate share of air pollution.

A dozen states have already approved Volkswagen mitigation plans

Plans from Wyoming, Ohio, Connecticut, Pennsylvania, Maine, Utah, and Wisconsin remain broad, with many types of trucks and buses eligible for funding. In these cases, important decisions will come as the funding is awarded to specific applicants.

Other states’ plans have provided more details. Georgia’s focuses exclusively on electric shuttle buses at Hartsfield-Jackson International Airport and new buses for the XpressGA commuter service. Minnesota’s plan uses a phased approach, evaluating its funding priorities over time. Arizona’s plan focuses exclusively on public fleet vehicles, with most funding going towards school buses. Oregon’s plan only allows funding for school buses but, unfortunately, caps funding at $50,000 per vehicle. This amount is likely not enough to encourage school districts to buy electric buses, which are the best option for children’s health.

California recently approved the largest Volkswagen mitigation plan

As the state with the largest number of defective Volkswagens, California will receive the largest amount of funding to offset the vehicles’ pollution ($423 million). California’s recently approved plan provides the strongest signal amongst states’ plans for electrification, directing $300 million towards zero-emission buses, trucks, and equipment. More than 50 percent of California’s plan will benefit low-income or disadvantaged communities.

California’s plan strikes an appropriate balance, with significant funding going towards the cleanest (zero-emission) technologies and a more measured amount ($60 million) for combustion vehicles and equipment in categories where zero-emission technology is less developed. This combination of investments is expected to more than offset the Volkswagen pollution. UCS joined many other groups across the state in supporting California’s plan.

Table showing allocations of investments in California's Volkswagen environmental mitigation funding plan

Putting the Volkswagen settlement into perspective

As large of a windfall as the $2.9 billion Volkswagen settlement is, it won’t be enough to meet our clean air and climate goals. In fact, its primary intention is to offset just the emissions from Volkswagen cars that were above the legal limit. But to meet our air quality and climate goals, we have to reduce a lot more pollution than from 580,000 Volkswagens.

State budgets: less flashy, but equally important investments

Last week, an even larger commitment to clean vehicles continued with passage of California’s annual budget and allocation of the state’s cap and trade revenues. State budgets don’t have the same intrigue or news hook of an emissions scandal, but represent opportunities for the sustained investments needed to achieve our climate and air quality goals.

While the recently approved budget for low carbon transportation ($467 million) is lower than the current year’s funding ($560 million), California has quietly invested $1.2 billion in clean vehicles over the last five years. These investments are much larger than the state’s share of the Volkswagen environmental mitigation settlement ($423 million), which will be spread out over the next few years.

California’s funding for low carbon transportation has supported everything from electric car rebates (on top of the federal tax credit) to vouchers for electric trucks and buses. Demand for the incentive funding has often exceeded the supply, indicating consumers and fleet owners are more than ready to adopt clean vehicles.

Electric truck and bus support is limited beyond California

While fourteen states provide purchase incentives for electric cars, only New York offers incentives comparable to California’s for electric trucks and buses, but from a smaller overall pot of funding ($19 million in New York vs. $180 million in California this year).

Utah and Colorado offer a tax credit for heavy-duty electric vehicles, but the credits are capped at $20,000, which doesn’t offset much of the additional cost of an electric truck. Georgia used to have a similar tax credit, but it expired.

For comparison, California and New York’s rebates are roughly $100,000 per truck or bus, depending on the size and type of the vehicle. And the rebate structure is much better for fleets, allowing the savings to be had upfront, rather than waiting for a tax credit several months later.

Federal support for heavy-duty electric vehicles has also been limited to a relatively small amount of funding for transit buses and airport shuttle buses. This is in contrast to the $7,500 federal tax credit for electric cars, which has been critical to uptake of these vehicles. Electric trucks and buses need similar incentives to spur widespread adoption.

The Volkswagen settlement could be a catalyst

While investments from the Volkswagen settlement are only a start in reaching the number of electric trucks and buses we need on the roads, they may prove critical in demonstrating the market readiness and benefits of these vehicles to justify additional investments. The availability of electric trucks and buses is increasing rapidly and public policy must keep up with these advances.

* Two other settlements – for $4.3 billion – addressed Volkswagen’s criminal and civil penalties for cheating on emissions tests and lying about cheating.

Three Revolutions and the Future of Cars: An Interview with Dr. Dan Sperling

There are a number of benefits we can expect to see with the introduction of autonomous vehicles (AVs), including more convenient transportation. One possible consequence resulting from this would be an increase in the number of miles that people drive, creating more vehicle pollution. To avoid this outcome, experts like Dr. Dan Sperling* from the University of California, Davis, are stressing the need to incentivize low-carbon vehicles (like electric cars) and an increased number of passengers per trip (sometimes called sharing or pooling).

My colleague Abby Figueroa sat down with Dr. Sperling to discuss the future of transportation and his book Three Revolutions: Steering Automated, Shared, and Electric Vehicles to a Better Future.

I extracted some key excerpts from the interview. You can listen to the complete interview here:

Abby Figueroa (AF):  So you have a book that you’ve wrote recently, “Three Revolutions” where you talk about what needs to happen next in transportation. Let’s talk about those three revolutions. Let’s start with the first one, electric vehicles. What’s going on with electric vehicles these days?

Dr. Daniel Sperling, Distinguished Professor of Civil Engineering and Environmental Science and Policy, and founding Director of the Institute of Transportation Studies at the University of California, Davis (ITS-Davis).

Dan Sperling (DS): Well, electric vehicles is a fascinating topic that I’ve spent many years on. And now as was mentioned earlier, I’m a board member for the California Air Resources Board. So California is fighting with the Trump administration over electric vehicle rules but electric vehicles are here to…not only here to stay, they’re going to dominate. There’s almost no question about it. Every car company in the world has made a major investment. They’ve got the technology, they’ve got the supply chains, they’re really just waiting for policy to really push them and consumers to start buying them. But they’re ready to go. And they’ve got the technology. So it’s really a question of how intent are we as a society in making it happen. Certainly in California, we’re really committed and we’re going to see massive introduction of electric vehicles in the coming years.


AF: So electric vehicles is the first revolution that needs to happen in transportation so that we can start reaping the benefits of reduced carbon emissions and better safety and less pollution. The second revolution you talk about in your book is automation, self-driving cars. Tell us a little bit about what’s going on in that world right now. How close are we to self-driving cars becoming a reality?

DS: Well, automation also is inevitable. It’s definitely going to happen, there’s almost no question. In this case, not just the automotive industry, but many other related companies, all the high-tech software companies, Silicon Valley companies, Google, are all making huge investments. So automation is definitely going to happen. In fact, our cars already are partly automated. Today, you can get some cars that will drive themselves on freeways right now, the Tesla, Audi, Cadillac, Mercedes.


AF: The car companies are racing forward with the technology. And the legislators and the cities are racing to try to keep up with the policies. And I think with reason people are excited and some folks are feeling more cautious and wary of it all. What’s the future looking like once we have these automation, these self-driving cars on the roads? How does that change our commute and the way we get around our communities?

DS: Well, the automated vehicles could play out in two different ways. They could be just basically superimposed on our current transportation system. In other words, we now go out and we buy our own car so now we would just go out and buy our own automated car. And so it would be the same except that it would be automated. If that were the case, that is what leads to what we sometimes call, the hell scenario…

AF: The dream or the nightmare that you called it in your book…

DS: In my book I call it, The Nightmare Scenario. And that’s because if you have an automated car, you can spend time in that car doing anything you want. You can eat, sleep, tweet, text, it can be your office. It can be your hotel room. And so you’re going to be much more willing to take long trips because you don’t mind so much being in the car. And it won’t be just being in the car more, cars will be empty part of the time. You go to a meeting, you don’t know quite when you’re gonna get out, you don’t wanna pay for parking, you just have the car circle around the block. You know, we refer to single-occupant vehicles, we’re going to have zero occupant vehicles, you know, zombie cars.

AF: That would be the nightmare scenario. That’s worse than the parking lots full of cars. It’s just cars roaming on the road with no one in them.

DS: So the other way it can play out, and that’s what we call the Heaven scenario, the dream scenario, is that these vehicles are used mostly or even totally as a mobility service, as a pooling service, meaning you take Lyft line or Uber pool and some other micro-transit companies like Via or Chariot. And you automate it and now you get rid of your cars, you don’t own cars anymore. And you just hit that button, car comes, takes you where you wanna go.

AF: Is there someone in the car with us?

DS: There’s no one in the car. And the cost is really cheap because you don’t have the driver, the automation won’t cost that much and the car will get really cheap because it’s being used so efficiently. Right now, our cars, they sit 95% of the time on average. Now we’re gonna use it 12 hours, 15 hours, 18 hours.

AF: Much more efficient.

DS: Much more efficient, so we won’t need as many. And because people are gonna pool in it, you know, there are multiple people in these cars. And these cars might not be cars like we know them now, they could get a little bigger, be more like a van, small vans. You know, probably there’ll be a differentiation of service, some people will want a more exclusive service and pay more, but the point of this is, that if we do have this pooling, that is by far the best strategy we can imagine to create a sustainable transportation system.

Because it’s cheaper, it requires less road space, less parking space, it provides more accessibility to more people, low income, physically disadvantaged, disabled.


AF: So of the three revolutions, electrification, automation/self-driving, and pooling, which one or which combination of those three are the ones that can have the best impact on our carbon emissions, the best positive climate impact?

DS: Well, if we had all electric vehicles, that would probably be the best for just reducing greenhouse gases, because there you can get, as we decarbonize our electricity system, we’re talking about a 80%, 90% reduction in greenhouse gases.

AF: And transportation is the leading cause or source of emission right now. So that’s the huge…

DS: In California, it’s over 40% of the total and nationally it’s over 30%. That’s right. So electric vehicles, if you just looked at it carbon, then electric vehicles is necessary. It’s kind of like given you have to do that. The rest of this, the pooling combined with the automation can help us reduce vehicle use. So then we can knock off another 20%, 30%, 40%, 50%.

AF: So electrification makes cars cleaner. And automation and pooling takes cars off the road.

DS: Yes.

AF: So those two things combined will help our carbon emissions again.

DS: Yeah, maybe a better way of saying it is it reduces vehicle miles traveled. It reduces vehicle use. So we’ll have less vehicles around because there’s more people in each vehicle.

AF: And they’re being more efficient. The cars aren’t parked 95% of the time.

DS: Exactly.

AF: Got it. So all the three revolutions really are interconnected, if we are to get to this dream scenario?

DS: Yes.


* Dr. Daniel Sperling is Distinguished Professor of Civil Engineering and Environmental Science and Policy, and founding Director of the Institute of Transportation Studies at the University of California, Davis (ITS-Davis). He holds the transportation seat on the California Air Resources Board and served as Chair of the Transportation Research Board of the National Academies in 2015-16.  Among his many prizes are the 2013 Blue Planet Prize from the Asahi Glass Foundation Prize for being “a pioneer in opening up new fields of study to create more efficient, low-carbon, and environmentally beneficial transportation systems.” He served twice as lead author for the IPCC (sharing the 2007 Nobel Peace Prize), has testified 7 times to the US Congress, authored or co-authored over 250 technical papers and 12 books, including Three Revolutions: Steering Automated, Shared, and Electric Vehicles to a Better Future (Island Press, 2018), is widely cited in leading newspapers, been interviewed many times on NPR radio, including Science Friday, Talk of the Nation and Fresh Air, and in 2009 was featured on The Daily Show with Jon Stewart.

Grendelkhan /Wikimedia Commons

Court Says Agency Can’t Indefinitely Delay Implementation of Obama-era Rules

Photo: Allen and Allen (allenandallen.com)/Flickr

Here is a beacon of good news to temporarily brighten your dark and stormy social media feeds. The U.S. Court of Appeals for the Second Circuit struck down an attempt by the Trump Administration to indefinitely delay a rule that was set to increase the fines automakers must pay for failing to meet fuel economy targets. Though Elaine Chao and the Department of Transportation have already begun a rulemaking to rollback the fine increase that was finalized during the last days of the Obama Administration, at least they now cannot indefinitely delay the effectiveness of the rule while they go through the rigmarole of rolling it back.

How did we get here: A brief history of CAFE fines and penalties

Get your waders on and join me in the weeds of the Corporate Average Fuel Economy (CAFE) standard, a regulation administrated by the National Highway Traffic Safety Administration (NHTSA) and not to be confused with, though inextricably linked to, the EPA rules that govern tailpipe emissions.

CAFE was created by the Energy Policy and Conservation Act (EPCA), which required NHTSA to set a penalty for automakers who fail to meet any federal fuel economy target. When EPCA became law in 1975, the CAFE penalty was set at $5.00 per tenth of an mpg per vehicle sold. Though Congress passed a law in 1990 requiring federal agencies to adjust civil penalties for inflation, NHTSA updated these fines just once, in 1997, up to just $5.50. This 50-cent increase was far short of what the fine should have been if it was truly adjusted inflation. According to the Department of Labor, $5.00 in January 1975 actually had the same buying power as $15.27 in January 1997.

In 2015 Congress updated its Inflation Adjustment Act to prevent agencies like NHTSA from setting artificially low penalties. In response, NHTSA (under President Obama) recalculated CAFE fines based on a formula laid out by Congress and set a new penalty of $14.00 per tenth of an mpg per vehicle. This recalculation was slated to go into effect for model year 2019 vehicles, and was finalized on December 28, 2016 – just 2 working days before President Trump and his cadre of regulation-slashing cabinet members and agency administrators took office.

Here is what President Trump is trying to do to reduce CAFE fines and penalties

In late January 2017, NHSTA published a series of rulemakings that delayed the effective date of the penalty increase – first for 60 days, then for 90 more days, then another 14 days, and finally, in July 2017, indefinitely while the agency reconsidered the penalty increase via a separate rulemaking. The decision to indefinitely delay the penalty increase was then challenged in the Second Circuit by a host of advocacy organizations and several states attorneys general. The two major trade groups representing automakers also joined the suit on the side of the government, who argued that federal agencies have an inherent authority to indefinitely delay a rule while it is being reconsidered. A panel of three judges (two of whom were appointed by a Republican president) disagreed.

This ruling may do nothing to incentivize automakers to improve fuel economy improvements

I know this is a good news post, but I do need to sprinkle in some bad news. The bad news is that NHTSA is moving forward with another rulemaking that will flatline the CAFE penalty at $5.50 per tenth of a mpg per vehicle – effectively rolling back the penalty increase that the Obama Admin worked to put in place. In that rulemaking, NHTSA argues that the CAFE penalty is not a “civil monetary penalty” as defined in the law requiring agencies to adjust penalties for inflation, and therefore does not need to be adjusted. I can’t wait for a court to get involved in these semantics if (when) this rule is challenged.

But this ruling could help other courts rule against the Trump Administration

On the one hand, the Second Circuit ruling on the indefinite delay rule may do nothing to incentivize automakers to meet fuel economy targets, since the penalty for missing mpg targets will likely be flatlined anyway. On the other hand, the finding that federal agencies cannot indefinitely delay a rule while it is pending reconsideration is a holding that could be applicable in other ongoing lawsuits and may become a major thorn in the side of President Trump’s rollback agenda – especially if other federal circuits agree with the Second Circuit here.

For example, UCS is a plaintiff in a lawsuit challenging an attempt by the EPA to effectively indefinitely delay standards designed to prevent accidents at facilities that use or store hazardous chemicals. This case resides in the D.C. Court of Appeals, who may now look to the Second Circuit in determining whether EPA exceeded its statutory authority when indefinitely delaying a rule. You better believe our attorneys at Earthjustice sent the Second Circuit opinion on the CAFE penalties to the D.C. Court of Appeals, who is expected to issue a final ruling on the Trump Admin’s decision to delay the effectiveness of chemical safety standards in the next several months.

More broadly, the Trump Administration’s M.O is to first delay the effective date of Obama-era rules – sometimes for months, other times indefinitely – and then roll them back. If the courts agree that an indefinite delay of a rule is inappropriate, this Second Circuit decision becomes a strong piece of judicial opinion (aka jurisprudence) for future challenges to President Trump’s attempt to erode public health and economic protections across all federal agencies.


Explaining Land Use Implications of Autonomous Vehicles: Meet Dr. Jonathan Levine

Aerial view of urban sprawl in Nevada.Urban sprawl in Nevada. Photo by USDA NRCS

Autonomous vehicles (AVs) will change more than our streets, and over time could change the structure of cities, towns and neighborhoods.  As explained in our policy brief Maximizing the Benefits of Self-Driving Vehicles, “self-driving vehicles could increase the use of personal vehicles, exacerbating sprawl, congestion, and pollution. Alternatively, the use of self-driving vehicles predominately for shared rides could reduce the need for parking and expansion of roads, creating the potential to repurpose public space for uses such as businesses, green space, and walking and bicycling infrastructure.”

Meet Jonathan Levine, a Professor of Urban and Regional Planning at the University of Michigan whose research focuses on the intersection of transportation and and land-use policy.

How AVs and other changes in transportation affect sprawl will depend on policies regarding land use. Why is land use policy important in realizing a positive role for AVs in a clean transportation future? Meet Jonathan Levine*, a Professor of Urban and Regional Planning at the Taubman College of Architecture and Urban Planning at the University of Michigan in Ann Arbor. Dr. Levine’s research centers on the potential and rationales for policy reform in transportation and land use. He is also interested in the design of institutions for emerging transportation systems – which may be based in large measure on self-driving electric vehicles – to serve metropolitan-accessibility goals.

I had the opportunity to meet Professor Levine as both of us served on the Policy and Social Justice Panel at the U.S Department of Transportation Center for Connected and Automated Transportation’s Global Symposium on Connected and Automated Transportation and Infrastructure in March 2018. I asked him about the importance of land use considerations as autonomous vehicles become more prevalent on American roadways.

RCE: There is a lot of speculation not as to if, but when self-driving vehicle technology is coming.  People are talking about what changes this technology will bring to vehicles and our transportation choices, but your work takes a broader view, including land use.  Can you explain briefly what you mean by land use, and why this is an important element of transportation systems?

JL: Land use is the question of what happens and where across a metropolitan area.  Land-use patterns can be concentrated or spread out, centralized or decentralized, and mixed- or single-use.  The purpose of transportation is not movement per se, but access, or the ability to reach destinations.  Thinking of it in this way, an assessment of the quality of service provided by transportation systems must consider both the speed of movement and the location of destinations.

RCE: What are the potential pitfalls if we do not address land use concerns?

JL: In general, if we do not address land use, there will be an ultimate impediment to access to transportation for consumers and constituents. Two examples of this impediment include parking and zoning. In many cities, when a new residential or commercial building is constructed, there must be a minimum number of parking spots attached. This requirement of parking increases housing costs in the area. Furthermore, when zoning laws encourage low density development, that density is eventually capped and cannot increase.  Both pre-existing land-use policies would impede development of a customer and constituent base.

RCE: What are some of the benefits we could see if we get changes in land use right? How do AVs play into making these easier or harder to achieve?

JL: Policy is important in achieving positive outcomes regarding land use. Too often in history, leaps in technology in the transportation system led to increases in the footprint of cities. What AVs could potentially do is encourage infill development in the cities, reducing their outward expansion making their per-capita environmental footprints smaller. The benefits are not restricted to cities; employing AVs to operate in coordination with public transit to encourage transit-oriented development can make suburbs more attractive to live in.

RCE: Here in the Washington DC metro area, we have what some call the “East-West divide,” where much of the region’s wealth and opportunity is concentrated in the west, and much of the poverty and social burden in the east. Improving transportation connections between east and west is one way to bridge the gap, but your work points in a different direction.  Can improving accessibility to destinations address challenges like the East-West divide?

JL: AVs could potentially address this access challenge in the area. They can be flexible and adaptable and need to work with sharing to reduce costs.  The accessibility approach would focus on areas of low transit accessibility and high proportions of people who are unable to rely on the private car for many of their trips.  With transit-AV coordination, shared AVs can help fill in these accessibility gaps.  Coordination might come in the form of congestion pricing or other access controls such as high-occupancy-vehicle lanes in heavily traveled transit-rich corridors, regulations or incentives spurring AVs to fill in the gaps, and extension of transit subsidies to shared AVs under certain circumstances.

RCE: What should community leaders keep in mind as they prepare for AVs to re-shape our cities? Do you have any recommendations they should advocate for to achieve the best outcomes?

JL: The future of AVs in cities and regions is not just a matter for technology and business-model development.  Policy at the state and especially municipal level will shape AV futures for better or for worse.  In many cases, the relevant policies are holdovers from an earlier auto era; in this sense planning for AVs is already underway without community leaders being aware.  But these holdover policies need reform to position cities and regions for a desirable AV future.

In addition, community leaders should recognize that the data currently being produced by on-demand mobility are immensely valuable.  They should seek leverage to gain access to that data for planning for integrating shared mobility in the short term and AVs in the longer term.


* Dr. Jonathan Levine is a Professor of Urban and Regional Planning at the Taubman College of Architecture and Urban Planning at the University of Michigan. His current work focuses on the transformation of the transportation and land-use planning paradigm from a mobility to an accessibility basis. Dr. Levine was recognized along with his colleagues with the 2010 Chester Rapkin Award for best paper in the Journal of Planning Education and Research, and in 2001 the Association of Collegiate Schools of Planning and U.S. Department of Housing and Urban Development awarded him the Excellence in Urban Policy Scholarship Award. He is the author of Zoned Out: Regulation, Markets, and Choices in Transportation and Metropolitan Land Use (Resources for the Future 2006) and The Accessibility Shift: Transforming Transportation and Land-Use Planning (forthcoming, 2019).

Utilities Should Invest in Electric Vehicle Infrastructure

Photo: SanJoaquinRTD/Wikimedia Commons

For more than a century, our cars and trucks have been fueled almost exclusively by oil. Today, electric vehicles (EVs) give us the potential to power our vehicles with a diverse set of energy sources, including clean and renewable energy. But to make that happen, we need to build the infrastructure that can keep our vehicles fueled and make owning an electric vehicle as convenient as a conventional car.

Across the country, many utilities are stepping up to build the EV infrastructure that we need. Some recent investments include:

  • The California Public Utilities Commission recently approved $738 million in electric vehicle infrastructure proposed by PG&E, SCE and SDG&E, inincludingundreds of millions for charging heavy duty vehicles such as buses and trucks.
  • Utilities in Maryland have recently proposed a $104 million investment in charging infrastructure that would create 24,000 charging stations across the state.
  • The Massachusetts Department of Public Utilities recently approved a $45 million investment by Eversource. A comparable investment by Massachusetts’ other major utility National Grid is still pending in front of the DPU.
  • Ohio has recently approved a $10 million pilot for electric vehicle charging stations.

These investments raise important public policy questions. What electric vehicle infrastructure is most important to speed up adoption? How should we design electricity rates to maximize the value of electric vehicles to ratepayers and the grid? How can our infrastructure best support all types of electric vehicles, including heavy duty electric vehicles such as trucks and buses? How can we use infrastructure to support electrification of shared vehicle fleets?

Today, the Union of Concerned Scientists is releasing a fact sheet outlining 10 principles that we see as particularly important to guide utility investment in electric vehicle infrastructure. In this fact sheet, we argue that utility investment in electric vehicle charging infrastructure is important public policy and ultimately a good deal for ratepayers.

Why should utilities invest in electric vehicle infrastructure?

Electric vehicles (EVs) represent both an enormous opportunity and a significant challenge for our utilities. Converting our vehicle fleet to electricity could add as much as 1,000 terawatt hours of demand onto our electric grid, an increase of about 25 percent of current levels. If managed correctly, this large and flexible load could significantly increase the efficiency of our electric system, which would benefit not only EV drivers but also all ratepayers, providing lower costs.

In the long run, widespread deployment of EVs could also be a source of energy storage, filling a critical need as our electricity system moves away from fossil fuels toward intermittent sources of power, such as wind and solar. Without proper management of EV charging, however, the additional power needed to fuel EVs could require significant new capacity, increasing pollution and imposing additional costs on ratepayers.

Building more EV infrastructure will help more people and businesses make the switch to electric vehicles, saving money and reducing emissions. Consumer studies have consistently found that inadequate access to charging infrastructure remains one of the most pressing obstacles to EV adoption. We have had over a hundred years to build the massive infrastructure necessary to support our gasoline and diesel vehicles. Creating an EV charging network that can compete with our oil infrastructure will require tens of thousands of new charging stations.

What principles should guide utility investments?
  • Provide chargers where people live and work. Most EV charging happens at home, and as affordable, long-range EVs are becoming available, overnight home charging can provide drivers with all the charge they need on most days. So providing universal access to home charging is a top priority. Workplace charging can be a valuable perk that can spur adoption through personal and professional networks.
  • Create a network of high-speed chargers along highways. While most charging will happen at home, a network of fast chargers along highways—capable of recharging an EV in 30 minutes or less—will be a critical component of our infrastructure, allowing EV drivers to access charging for road trips and emergency uses.
  • Maximize benefits to ratepayers and the grid. EVs can provide significant benefits to ratepayers and improve the efficiency of the electric grid if electric vehicle charging occurs during times of low demand or high production of renewable energy. Utilities should create policies that encourage drivers to charge their vehicles during these ‘offpeak’ hours.
  • Establish fair electricity rates for EV charging. EV charging rates should be fair, transparent and provide value to EV drivers. High demand charges can make it difficult to create a viable business model for high speed charging stations, which can be particularly important for electrification of heavy duty and shared vehicles.
  • Support electrification of trucks and buses. Heavy-duty vehicles such as trucks and buses are major contributors to global warming pollution as well as to local air pollution, such as emissions of NOx and particulate matter that cause significant health problems. Investments in charging infrastructure and station equipment can help make these technologies cost effective for fleet managers and transit agencies.
  • Support electrification of new mobility services. Ride hailing services such as Uber and Lyft play an increasing role in our transportation system and must be electrified. Utilities should work with these companies and others to ensure that they have the charging infrastructure and rate design that they need to move to EVs.
  • Ensure low-income communities benefit from electrification. Integration of EVs into ride- and car-sharing networks, installation of more charging stations in apartment buildings, and electrification of transit and freight vehicles can help ensure that low-income residents benefit from the transition to electric transportation.
  • Create an open and competitive market for EV charging. Utilities should work with the auto industry and suppliers of charging equipment to ensure that we retain a competitive market for EV charging that encourages innovation and consumer choice and provides EV drivers with a consistent, high quality experience.

Taken together, universal access to residential charging, widespread availability of workplace charging, and high speed chargers along critical transportation corridors can make driving an EV cheaper, cleaner, and more convenient than any other car. And inducing smart charging and integration with renewables can ensure that the transition to EVs makes our grid stronger and more efficient – and save ratepayers millions in the process.

We encourage utilities and agencies to move forward with ambitious projects to build out EV infrastructure and create the clean transportation system that we need.

Photo: SanJoaquinRTD

Clean and Modern Transportation in Maryland: Wishful Thinking or a Possibility?

Photo: Famartin/Wikimedia Commons

The Maryland transportation system faces a myriad of challenges. Poor air quality, rising global warming emissions, and a crumbling transportation infrastructure, to name a few. To address these issues, the state is considering strategies that would lower transportation-related emissions, bring in funding and enable the state to build a modern, clean and equitable transportation system.

Why does Maryland need to invest in a cleaner, more modern transportation system?

Transportation is the largest source of CO2 pollution in the state, responsible for almost half of statewide emissions from fossil fuel combustion. The state cannot achieve the long term goals under the Greenhouse Gas Reduction Act (GGRA) without making significant reductions in emissions from transportation

Figure 1 – Maryland CO2 emissions from fossil-fuel combustion for all sectors of economy, 1990-2015

Transportation is also a leading source of local air pollution that has been shown to be the main cause of over 3,000 asthma attacks, 500 preventable deaths and $1.8 billion in combined health costs annually in the state. Communities surrounding the Port of Baltimore, such as Curtis Bay, are particularly vulnerable to the impact of transportation emissions and experience elevated  rates of respiratory illness, cancer and heart disease. A study shows that in 2010 Baltimore’s rate of asthma-related hospitalizations was almost three times higher than the U.S. average and recent data indicates that this trend has not changed.

In addition, climate change is exacerbating Maryland’s vulnerability to extreme weather events, especially along the state’s 3,000 miles of shoreline and in communities prone to flooding. Maryland is one of the states most vulnerable to sea-level rise. Climate change will exacerbate challenges to Maryland’s existing road and public transportation infrastructure, which already suffers from poor conditions and inadequate funding. One quarter of Maryland’s 32,037 miles of public roads are in poor condition. Creating a clean and modern transportation system is an opportunity to harden our critical infrastructure.

We can do better.

What do we need to do to get there?

The only way to meet the climate target by 2030 is to move away from fossil fuels, which means putting more electric vehicles (EVs) on our roads. A recent study estimates that EVs produce less than half the emissions of a comparable gasoline-powered car, even when the higher emissions associated with EV manufacturing is considered. Where you live determines the emissions from the electricity which powers your EV, but the study shows that in regions covering two-thirds of the U.S. population,  driving an EV emits less than a 50 mile-per-gallon gasoline car.

Electric buses and trucks can help relieve the burden of air pollution from diesel fuel. We can start by electrifying Maryland’s bus fleet, including at least 7,000 diesel school buses as well as light trucks, so pedestrians, bikers, 623,000 school children and people who live in low-income communities near highways will breathe cleaner air.

With electrification, more of the dollars spent on energy resources will remain in the region, helping to create jobs.  While much of the state’s electricity is still produced from fossil fuels, the cost per mile is much lower for EVs, and Maryland’s commitment to increasing renewable power means the share of fossil fuels used in the state will fall over time.

Not just that, but electrification will save drivers money on fuel and will insulate them from the fluctuating price of gasoline. In the last decade, the price of gasoline in the state has fluctuated between a low of $1.5 per gallon and a high of $4.10 per gallon. A difference of almost threefold in a household’s expenditure with gasoline is especially burdensome for low- and middle-income families.  A study shows that for the U.S., the cost of electricity to refuel an EV using the standard rate plan is often lower than the equivalent cost of gasoline and is always lower using a time-of-use rate. In Baltimore the average price of electricity as vehicle fuel is between 75 cents  and slightly over one dollar per gallon and is lower than the lowest electricity price in the last decade. The average fuel savings for a Baltimore EV driver was estimated to be over $600 per year.

It is also important to make investments in public transportation and in affordable housing near public transportation, so people can move around without driving a car, saving them money and easing the burden of traffic for all Maryland residents.

With the right investments, we can have a transportation system in Maryland that is cleaner and more resilient than our current system. A new proposal under consideration in Maryland can help the state fund some of these critical investments and reduce emissions at the same time.


One policy mechanism under consideration for transportation in Maryland and other Northeast and Mid-Atlantic states is known as cap-and-invest. This policy places a limit, or cap, on greenhouse gas emissions from polluters and requires them to purchase allowances – or rights to emit CO2 – from the state, based on how much they pollute. By limiting the number of allowances available, the state guarantees overall emission reductions.  The proceeds from the auctions are then invested by the state in clean energy and transportation projects. Cap-and-invest also gives regulated parties the incentive to switch to less polluting products and processes, often minimizing consumer costs while giving them the flexibility to comply in a manner that best suits their circumstances.

Cap-and-invest is already working for the power sector. In 2009, Maryland and eight other Northeastern and Mid-Atlantic states collaborated to implement a successful power sector cap-and-invest program known as the Regional Greenhouse Gas Initiative (RGGI).  Thanks in part to this program, Maryland’s electricity sector reduced emissions by a third between 2009 and 2015.

Up to 2017, the allowance proceeds from RGGI have brought in $2.8 billion for the region. By investing in efficiency, RGGI has contributed significantly to emissions reductions and economic growth while saving consumers money.  In 2015 alone, RGGI-funded projects in the region have been estimated to expect to return $2.31 billion in lifetime energy bill savings to at least 161,000 homes and 6,000 businesses. In Maryland, by September 2017, RGGI had generated $574 million in cumulative funds, which  has allowed the state to make significant investments in emissions reduction, energy efficiency programs, and in reducing electricity bill costs for residents, who have saved an estimated $457 million in lifetime electricity bills.

RGGI cleaned the air in the region. In the nine Northeast and mid-Atlantic states, RGGI helped avoid up to 830 premature deaths, averted up to 9,900 asthma attacks and saved an average of $5.7 billion in health costs between 2009 and 2014. Neighboring states, such as the District of Columbia, Pennsylvania, Virginia and West Virginia also saw a decrease in mortality, respiratory and heart diseases. In Pennsylvania, for instance, the valuation of avoided health effects due to RGGI amounted to anywhere from $800 million to $1.8 billion dollars in the same period.

So far, cap-and-invest covers power plants, but not emissions from transportation. Other jurisdictions, however, including California and Quebec, have expanded cap-and-invest to transportation, resulting in billions in new funding for clean transportation. This year California will spend $695 million on clean vehicle incentives, $1.2 billion on public transportation and over $700 million on affordable housing and sustainable community programs thanks to their cap-and-invest program. It has been estimated that cap and invest for transportation in Maryland could be as high as $450 million per year.

Though RGGI has been successful in reducing emissions from the electricity sector, the transportation sector has been left trailing behind. In 1990, the state’s power sector was a larger emitter than the transportation sector. But roles were quickly reversed:  by 2015 transportation’s share had gone way up, while the electricity sector’s share had gone way down.

In 2009, Maryland’s General Assembly passed the Greenhouse Gas Reduction Act, which mandates that by 2020 the state must reduce its economy-wide greenhouse gas emissions to a level equivalent to 25% below 2006 emissions levels. In 2016 the GGRA was reauthorized and its goal extended to a 40% reduction by 2030.

Without a cap on emissions from gasoline and diesel, reaching our economy-wide 2030 goal is not likely, regardless of the success of the cap on electricity emissions.

What’s next for transportation cap and invest in Maryland?

Discussions on transportation pricing policies are under way in Maryland and other states in the region.

The Transportation & Climate Initiative (TCI), a collaboration of eleven Northeastern and Mid-Atlantic states, and the District of Columbia, works to promote clean and efficient transportation in the region while taking into account the importance of individual state priorities. TCI is hosting listening sessions in several states to bring in input on potential policy approaches, including cap-and-invest and other strategies, to reduce emissions and fund improvements in the region’s transportation system.

The Maryland Commission on Climate Change (MCCC) advises the Maryland Governor and General Assembly on how to reduce greenhouse gas emissions and on adaptation to climate change. The Mitigation Working group of the Commission focuses on market-based and other programs to reduce emissions, and discussions on carbon pricing are under way.  The MCCC  holds meetings open to the public where time is set aside for public comment. Encouraging state leadership to hold listening sessions is a highly valuable initiative.

The Union of Concerned Scientists works with a broad coalition of community-based partners on emission-reduction strategies and strategies for obtaining funding for a clean, modern and equitable transportation system, and on how to best invest these funds.

State-based collaborative efforts have become imperative in this day and age, and Maryland has a significant role to play in these efforts. The state’s commitment to clean energy and its success in developing a clean power sector has led to Maryland becoming one of the most energy efficient states in the country. This commitment, together with an active participation in a regional collaboration, are a winning combination. Building a clean, modern and equitable transportation system in Maryland is within reach and is the next step.

Photo: Famartin/Wikimedia Commons

A Tale of Four Cities: How Smart Growth Can Shape the Future of the Washington, D.C. / Baltimore Region

Sorry Ben, there are now three things certain in life: death, taxes, and bumper-to-bumper traffic on I-95 from Washington, D.C. to Baltimore. Though these three things are certain today, they may not be tomorrow. While I’d love to discuss when science will allow humans to upload their consciousness to the cloud, and download themselves into a new body (aka “sleeve”), a new study has prompted me to think about the future of regional traffic as not just dependent on autonomous vehicles or better mass transit.

Researchers at the University of Maryland National Center for Smart Growth analyzed what the Washington, D.C / Baltimore region may look like from now until 2040. The “Engaging the Future” report contrasts four possible futures against a baseline scenario in which the region adds nearly 1 million additional commuters. Under the baseline “do-nothing” scenario, commute times could quadruple despite large increases in rail ridership.

Congestion in the region, already bad, is forecast to get significantly worse. In spite of large increases in rail ridership, vehicle miles traveled and hours traveled are set to increase, which will worsen traffic – especially on highways. Source: National Center for Smart Growth

So, what can be done? The researchers played with different inputs in their model, which can all be found on page 3. For the sake of simplicity, I’ll focus on three: (1) self-driving vehicles, (2) better public transit, and (3) fuel price. Assuming growth or decline in these three factors produced the following four future scenarios for the region.

Revenge of the Nerds: Cheap fuel and autonomous vehicles incentivize driving and sprawl

This is a future of rapid economic growth driven by low fuel prices, widespread adoption of self-driving vehicles, and a retreat from government regulation in the face of such economic success. When combined, these factors increase the capacity of existing expressways, reduce the cost of driving, and make travel time more productive as commuters can watch Netflix as their car drives them to work. If most people are in self-driving cars, congestion could be reduced as cars are able to travel closer together and cause fewer crashes, allowing existing highways to accommodate more vehicles. As a result, ridership on transit plummets, emissions from transportation rise, and more farmland and forests are converted into housing.

The widespread use of autonomous vehicles increases highway capacity by 50 percent, which dramatically reduces congestion. But as residents decentralize due to new housing patterns, vehicle miles and emissions increase. Source: National Center for Smart Growth

Free for All: Self-driving cars fail to take hold, low fuel prices exacerbate sprawl as more jobs and people move into the region

This scenario assumes little government regulation and a slow but steadily growing economy led by job and population growth throughout the region. Low fuel prices mean no major investments in mass transit, but public-private partnerships are forecast to invest in new tolled highways and the construction of an additional bridge to the Eastern Shore of Maryland. In this scenario, employment and housing disperses from urban areas, and households fill the formerly protected agricultural preserves of the inner suburbs, especially in Montgomery, Prince George’s, and Baltimore Counties. Though sprawl worsens, and mass transit ridership declines, congestion and transit time improve as jobs move to the suburbs, closer to commuters.

This scenario assumes a relaxation in development restrictions, which allows new residential developments to locate in the formerly rural areas of Montgomery, Baltimore, Prince George’s and Howard Counties. Source: National Center for Smart Growth

Blue Planet: High fuel prices and strong government regulation stimulate investments in mass transit and renewable energy

This scenario assumes low levels of self-driving cars, but strong economic growth as advancements in clean technology overpower the economic drag of rising fossil fuel prices. High-tech clusters expand throughout the region, and investments in transit and renewable energy greatly decrease emissions, improve travel times, and lower regional congestion. Local governments accommodate growth by increasing residential capacity in inner suburbs, especially around the expanding transit network. The changes in travel behavior are forecast to be dramatic in this scenario. Though vehicle miles traveled increases, congestion is reduced as more public transit accommodates new straphangers. As a result, transportation-related emissions are greatly reduced as vehicles become electrified and personal transit shifts to public transit.

In this scenario, transit ridership increases 21 percent over the baseline; about half due to the expanded network and half due to high fuel prices. Unlike the baseline, many more transit trips originate in the cores and inner suburbs, with a substantial increase in reverse commutes to transit-accessible inner suburb locations. Source: National Center for Smart Growth

Last Call at the Oasis: As gas prices quadruple and economic growth slows, governments respond with more investment in core transit and electric vehicle infrastructure

The last scenario envisions a future defined by scarcity. Declining world oil reserves quadruples gas prices and accelerates the transition to electric vehicles, but not self-driving cars. The changing structure of the economy directs growth to the city cores of the region, and both households and jobs concentrate near transit stations in urban centers or inner suburbs. A quadrupling of gas prices would cause dramatic changes in travel behavior. Transit ridership would increase significantly, and electric vehicle sales would rise, helping slash emissions from transportation. In addition, considerably less forest and farm land would be developed in this scenario, since the jobs and housing would be concentrated more toward transit hubs in city centers or inner suburbs.

When vehicle operating costs quadruple, travel behavior, and ultimately land use, change in expected ways. Households cluster in the inner suburbs, close to employment and services, and near existing and new rail transit stations. Source: National Center for Smart Growth

Travel behavior is profoundly affected by a fourfold increase in fuel costs, the lack of autonomous vehicles, and the concentration of households in suburban corridors. As a result, congestion could fall dramatically in this scenario, along with auto-related pollution.Source: National Center for Smart Growth

How policy can help shape the Washington, DC / Baltimore region

This modeling effort demonstrates that the Washington, DC / Baltimore region could grow in vastly different ways. If we are to maximize the potential of self-driving cars and electric vehicles to reduce congestion and transportation-related emissions, smart policy will be needed to help drive the adoption of these technologies even if gas prices remain low.

Policies that offset the cost of electric vehicles incentivize the installation of public charging infrastructure, and push the generation of renewable energy are a good start – and already on the books across the country. Additional regulations to ensure autonomous vehicles are powered by renewable electricity and, to the greatest extent possible, operate as shared rides, will also likely be important as self-driving technology encourages people to take a car over public transit.

Policy will also be needed to keep housing and jobs from expanding too far into agricultural preserves and forests beyond the inner ring of suburbs. Placing affordable housing near transit hubs will likely remain key to keep people using public transit, even if congestion is somewhat lessened from a widespread adoption of self-driving cars.

Lastly, it’s important to recognize that neither self-driving cars nor electric vehicles are a panacea to transportation-related emissions and congestion. Even if we have cleaner vehicles, if there are more people in the region buying more vehicles and driving them more, then a decrease in emissions from fuel efficient or electric vehicles could be at least partially offset by the sheer volume of new drivers in the region. That’s why housing and regional planning policy must be taken into account when looking at the holistic future of this region – and hopefully this report informs regional planners and other policymakers as they look to expand the productivity and environmental stewardship of the region.

Good News for Colorado Drivers: Hickenlooper Moves to Adopt State Clean Car Standards

Streaks of light on Colorado road.

This week Governor Hickenlooper ordered his agency staff to move forward in adopting California Clean Car Standards for Colorado – a move that would prevent the harm to Colorado consumers that the anticipated federal rollback of fuel economy and emissions standards is expected to bring.   At the same time, California regulators released an analysis that sheds light on just how much damage a rollback of federal vehicle standards is likely to have if state clean car standards are not kept in place.  What’s at stake?  A lot, including billions of dollars in additional gasoline spending.  And sadly, the Auto Alliance – the trade group representing major auto companies including Ford, GM, and Toyota – has resorted to a misinformation campaign to turn Coloradans against cleaner cars.

Why does Colorado want to join California and the other 12 states that follow California’s emissions rules?

Every state in the nation is benefiting from the availability of cleaner, more efficient vehicles that have been prompted by current emissions and fuel economy standards. In fact, savings on fuel already tops $60 billion.

Current plans by the Trump Administration are to rollback federal standards which are currently aligned with CA and the other states that have adopted California rules.  It has been reported the administration’s proposal, currently under review before public release, would freeze the standards at 2020 levels. This would result in a major increase in climate emissions – UCS estimates an increase of more than ½ billion tons of climate emissions just for vehicles built from 2022 through 2025. By 2030, that would be the equivalent of pollution from 30 coal-fired power plants.  But it would also harm consumers more directly, increasing how much they spend at the pump for years to come.

For example, Coloradans have already saved $550 million in fuel costs thanks to existing standards and by 2030 are expected to save an average of $2,700 per household under current rules.  If EPA and NHTSA freeze the standards in 2020, these expected savings will be slashed.  Governor Hickenlooper understands what’s at stake and the move to have Colorado join 13 other clean car states will ensure Coloradans continue to get clean, more efficient vehicle choices in every class from small cars to big SUVs and pick-up trucks.

California analysis makes it clear – rolling back vehicle standards will hurt consumers and increase pollution

An analysis by California regulators paints a very clear picture that following the Trump Administration’s plan to stall progress on clean cars will be a costly mistake. The analysis examines the pollution and economic impact to California under two scenarios – (1) vehicle standards are frozen at 2021 levels or (2) vehicle standards kept in place through 2025 as currently planned.  The highlights (or low-lights) from their analysis (See Appendix A):

  • A rollback of vehicle standards will cost Californians a net $15 billion between 2021 and 2030. That’s because cleaner cars save consumers money, even after paying for the technology to reduce emissions. Weaker standards mean less fuel savings and more money spent on fuel.
  • Californians would also suffer from additional air pollution resulting from production and delivery of increased amounts of gasoline, adding another $1 billion in economic costs related to increased premature deaths and health-related damages between 2021 and 2030.
  • Adding in the economic value for the actual carbon emission reductions, the rollback adds an additional $1.3 to $5.5 billion in climate damages that would have been avoided with the standards between 2021 and 2030.
  • In California, the state has a law requiring a 40% reduction in global warming emissions by 2030 compared to 1990 levels. The ARB analysis shows that a rollback would add nearly 57 million metric tons of CO2 between 2021 and 2030 with about a 20% annual increase in car and truck emissions by 2030. The numbers would be even worse if standards are held at 2020 levels, as reportedly may happen, instead of 2021. Many other states, including Colorado, have set emission reduction goals and are committed to contribute to efforts to avoid the costly consequences of climate change. A rollback will make their efforts that much harder.

While the analysis is specific to California, the same conclusions hold for other states.  Clean car standards are good for consumers and reducing pollution – and freezing them is a gift to the oil industry paid for by drivers at the pump.

Figure 1. Analysis by CA regulators showing emissions from light-duty vehicles under current standards (blue line) and emissions if standards are held at vehicle model year 2021 levels (green line).

Auto Industry Response to Colorado’s support for Clean Cars? Spread misinformation

Immediately responding to Colorado’s decision to ensure its consumers get the benefits of cleaner car technology, the Auto Alliance (representing companies including Ford, GM, and Toyota) and the Colorado Chamber of Commerce rolled out a new campaign attacking clean car standards as un-Coloradan, using the same scare tactics and misinformation harkening back to the days of fighting seatbelts and air bags requirements.

Here’s some fact checking:

  • Claims of higher gas prices resulting from clean car standards are completely bogus. Clean car standards require manufacturers to make cleaner cars. These cars reduce fuel use and save consumers money at the pump. Yet the Alliance’s website claims adopting CA standards somehow means Colorado gas prices will be affected.  This is a blatant attempt to use California’s higher than average gas prices as a scare tactic to Colorado consumers and is not based on facts—Coloradans will save money on gas as a result of this action, not spend more on it.
  • Strong standards will provide Coloradans more choices, not less. The Alliance claims clean car standards are bad for Colorado consumers and would restrict vehicle choices. The opposite is true. Current standards are driving innovation and giving consumers more fuel efficient choices in every class especially in small SUVs as documented in our recent Automaker Rankings report.  As we’ve pointed out time and again, selling SUVs and trucks doesn’t make it harder to manufacturers to meet clean car standards but it remains a talking point of the Auto Alliance.
  • The Zero Emission Vehicle Program does not require automakers to sell 15 percent electric vehicles by 2025. Peddling misinformation about CA’s Zero Emission Vehicle program trying to make the case it is unreasonable is standard fare for the Auto Alliance. In fact, they know quite well that updated regulatory analysis from 2017 shows the program requires plug-in hybrid, battery electric or fuel cell vehicles to be about 7-8% of new sales by 2025 in California and slightly less in other states that have adopted CA’s program. CA is already at 5 percent new vehicle sales. Governor Hickenlooper’s announcement doesn’t include the California electric vehicle requirements, but even if it did, characterizing the requirement as 15 percent is a clear mischaracterization of what the program requires.


The Trump Administration, prompted by the automakers, has decided to throw out a well-coordinated national program for vehicle emissions and fuel efficiency —a move that is bad for consumers and moves the auto industry backward.  Initiation of lawsuits to prevent the rollback and Colorado’s recent announcement to join the clean car states clearly demonstrate that states recognize the myriad benefits to their residents from these standards.  They should not be deterred by tired auto industry arguments.



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?