The Detroit Free Press reports that a recent filing by the California Air Resources Board [Full filing in PDF format here] threatens that a rapid ramp-up to the proposed 35.5 mpg 2016 standard and a reduction in zero-emission vehicle credits are necessary “to ensure California’s continued support.” CARB spokesman Stanley Young explains that “what we wanted to do is convey the level of importance for these two issues,” and that it’s “too early” to say whether California will withdraw from its compromise with the Obama administration. Still, the threat of a California withdrawal should be enough to get some attention in Washington, as Obama adviser David Axelrod has called the emissions compromise one of the administration’s top accomplishments of 2009.
CARB’s first complaint is that, though Obama promised to harmonize national emissions standards with California for 2016, the current proposed rule allows for more leeway in the 2011-2015 model-years.
While the proposed national passenger motor vehicle greenhouse gas standards are of equal stringency to the Pavley [California] regulations in the 2016 model year, they are less stringent than the Pavley standards in the 2011 through 2015 model years. Consequently, allowing manufacturers to comply with the Pavley regulations in the 2012 through 2015 model years by demonstrating compliance with the national regulations in these model years will result in slightly less reduction in greenhouse gas reductions within California and the individual states that have adopted California’s program. However, staff believes that nationwide, greenhouse gas emission reductions from the proposed national GHG program – assuming California’s comments on the proposed rulemaking are affirmatively addressed – will be greater than if the Pavley program were implemented without the national GHG program. This occurs because although the proposed national standards are less stringent than California’s in model years 2012 through 2015, the national standards apply to more than twice as many vehicles than are subject to the Pavley regulations.
Though the CARB’s zeal is impressive, messing with the ramp-up to an agreed-upon 2016 standard is overreaching for relatively marginal gains… at a considerably higher cost to the auto manufacturers. If this were the only issue, CARB might well have stayed silent and sucked up the slower ramp-up as part of the cost of compromise. The second issue, however, is far more real.
The CARB filing notes:
EPA believes that electric vehicles (EVs), plug-in hybrid electric vehicles (PHEVs), and fuel cell vehicles (FCVs) have the potential to reduce greenhouse gases more significantly than any commercially-available technologies, and ARB fully agrees with this. EPA is, therefore, proposing that additional credits be given to these advanced technologies in the 2012 through 2016 model years, in order to encourage their development.
These advanced technology credits would take the form of multipliers in the range of 1.2 to 2.0, allowing an EV, PHEV, or FCV to count as more than one vehicle during the calculation of a manufacturer’s fleet average CO2 level to determine compliance with the applicable footprint-based standard. These multipliers would not be applied when calculating the actual footprint-based
CO2 standard to which a manufacturer must comply. (Footprint is determined by multiplying the vehicle’s wheelbase by the vehicle’s average track width. The greenhouse gas standards being proposed by EPA are expressed as mathematical functions that depend on vehicle footprint.)
In addition, EPA is proposing to assign a value of zero grams per mile of CO2 for EVs and for the electric portion of PHEV operation, when including these vehicles in a manufacturer’s average. EPA acknowledges that there are =upstream CO2 emissions from electricity generation, which are produced during EV and PHEV charging. Similarly there are upstream emissions from hydrogen production for FCVs. However, EPA feels that the significant greenhouse gas emission reductions that may be achieved from this technology outweighs the dis-benefits of ignoring these emissions within this timeframe.
Staff agrees with EPA’s goal of encouraging the early development and production of advanced technology vehicles. However, staff believes that the approach proposed by EPA could allow manufacturers to earn unreasonably high numbers of credits, thereby potentially reducing the overall GHG reductions achieved by the national program and delaying the implementation of improved greenhouse gas technologies on conventional vehicles.
Consequently, staff believes that EPA’s Final Rule must strike a better balance between advanced vehicle development and protecting greenhouse gas reductions by assigning average lifecycle emissions to these vehicles, and restricting credits to EVs and FCVs only.
Having looked into the credit multiplier loophole, we agree wholeheartedly that it’s rife for abuse, especially in respect to Flex Fuel (ethanol) Vehicle credits. On the whole, the “super credit” program incentivizes automakers to build zero- and low-emissions vehicles without regard for marketability, to make up for a fleet that could be otherwise way out of compliance. Under this system the environment and consumers lose out equally.
Still, California is walking on thin ice. Politically, the Obama administration can’t afford to see one of its few major accomplishments of the last year fall apart. But then it can’t afford to burden the auto industry it now owns a stake in with CARB-approved toughness either. Meanwhile, other states are weighing in with concerns about implementing the new GHG emissions standards. Hell, California’s own Energy Commission is asking the EPA to delay the implementation of GHG standards entirely. This is why they call politics the art of the compromise.