How One Regulatory Proposal Could Discourage EVs

Posted by: David Welch on December 23, 2010

Government regulations, when done right, are supposed to either prohibit bad behavior or encourage the right ones. I came across one proposal that may have it backwards. Right now, the Environmental Protection Agency, National Highway Traffic and Safety Administration and California Air Resources Board are mulling rules that would push the average car sold to a mandated 60 miles per gallon by 2025. The green lobby is pushing to include one new rule that could discourage some of the technologies that they want to see sold in greater numbers.

They want to assign electric vehicles a carbon dioxide emissions rating based how much of the greenhouse gas is generated by the power plants that supply the juice to the car. They call it “upstream emissions.” The government would measure how much electricity the car uses, calculate how much carbon dioxide is emitted while generating that power and assign that value to the car. There is a direct calculation that gets you from carbon dioxide emissions to fuel economy. If you live in an area that gets a lot of power from coal, a hybrid-electric car that burns gasoline could actually be counted as emitting less carbon dioxide and using less fuel than an EV like the Nissan Leaf, according to the American Council for an Energy Efficient Economy. That’s right. Even though the Leaf burns no gasoline and has no tailpipe, the feds would say that its greenhouse gas emissions are higher than the gas-burning hybrid.

Such a rule could discourage carmakers from selling more EVs. If environmentalists and regulators want to encourage the growth of a nascent electric-car market, this could give carmakers more credit for developing hybrids instead. It also gives the power utilities, whose power generation is creating the emissions, a free pass.

The green lobby has a reason for pushing for some kind of measure of EV emissions. The carmakers have a long history of exploiting loopholes in the law to sell more inefficient vehicles. In this case, the environmentalists are worried that the carmakers will use very low carbon dioxide emissions numbers assigned to their EVs to offset the emissions of gas hogs and sell more of them. If the government goes with a 60 mpg rule (which is 44 mpg in real-world fuel economy) they will be pushing the industry to get more efficient. If the regulations encourage more EVs, the industry will have a better chance of getting there.

Reader Comments

Ad van der Meer

December 24, 2010 9:28 AM

Now what if you produce your own electricity from PV's or some other form of "green" energy?


December 24, 2010 9:35 AM

If they do this, it would be inherently highly biased against EVs, for a very simple reason: gasoline cars also have a "long tailpipe."

Their emissions don't just come from the tailpipe: huge amounts of energy are used to refine gasoline. There are also large amounts of energy used to extract crude from the ground, transport it to the refinery, and transport the resulting gasoline to the customer. If you added all this up the CO2 emissions for gasoline cars would be double or more.

A recent study suggested that the electricity used just to refine a gallon of gasoline would be enough to drive a Nissan Leaf the equivalent distance.

I don't see manufacturers agreeing to including this "long tailpipe" figure for gasoline cars. It would increase their emissions by a huge amount.


December 24, 2010 11:28 AM

I don't want a hybrid !

I WANT 100% Battery Electric !

And don't try to tell me there's no demand out there for EVs, Government Motors !


December 24, 2010 6:12 PM

I don't want a hybrid !

I WANT 100% Battery Electric !

And don't try to tell me there's no demand out there for EVs, Government Motors !


December 25, 2010 1:00 PM

Electric only cars are the way to go but I wish to see them make batteries that are standardized and slide-in-out like power tools so that owners can just rent out a new battery pack at each destination to get to the next one.

Andrew Bissell

December 25, 2010 3:54 PM

If they do this (and there is some merit to it) then:
1. gas vehicles must also be made to account for the upstream emissions of hydrocarbon fuel production - current miles per gallon and CO2 emission figures for gas cars do NOT include these. Depending on the source of the oil and the route to refining these upstream emissions for gas can be very substantial - for tar-sand oil these can double the CO2 emissions (making a Prius emit over 300g CO2/mile when the well to pump emissions are combined with pump to wheels).
2. It had best be done at the level of the regional/national electric grid: your electricity can't be assigned to just your local power plants when they are on a larger grid with power flowing all over the place to meet demands - you need to uses the average CO2 per kWh of all the generators on the whole grid; equally you can't treat the whole US as one place as it doesn't have a true national grid - it has at least three major ones (West, Central and East) - so the average grid CO2 intensity has to be calculated for each grid area. So in the US this would mean three separate vehicle sticker emissions numbers for the three separate grid areas; in Europe a different CO2 emissions number for each of the 26 EU countries. Competition and single market regulators may take a dim view of this - but the alternative of pretending that there is a US-wide or EU-wide single average emissions number that is physically meaningful should be resisted.
3. In calculating the upstream emissions for the EVs, attention should be paid to the time of day that EVs are charged. In general EVs charge at night. Hour-by-hour statistics for the UK national grid indicate that carbon intensity are typically 1/3 lower at night. So let's be sure that the upstream emissions are calculated with a weighting to a fair view of when the bulk of vehicles charge.
4. Given that most regulators allow electricity companies to sell "green" electricity that is sourced from wind, solar, etc, there should be provision on any EV sticker to state "zero emissions if powered by a green tariff electricity supply (or your own zero carbon generation)."

Tom Saxton

December 26, 2010 2:05 PM

Counting upstream emissions for EVs is fine as long as we do the same for gas vehicles. It's not carbon-neutral to pull a bucket of crude out from miles below the Earth's surface, transport it to a refinery, refine it, and transport it to your local gas station. Counting the fuel, electricity and natural gas used in this process will double or quadruple the total CO2 emissions of a gas car.

Also, you can run an EV from your own solar panel or green energy from your utility, which can't be done for a gas-burner. That should also be clear on vehicle labeling.


December 28, 2010 2:34 AM

In 2009 alone USA oil refineries purchased 43,019 million Kilowatthours of
electricity! That one year alone would be enough to power two years of production of every new car in the US if they were electric.

The refineries in California are the largest user of electricity next to the State.

There also has to be an accounting of the (extra dirty) fuel burned in the Supertankers bringing oil from parts afar one tanker burns a gallon of fuel every 44 feet! Just 16 of the hundreds of tankers create the pollution of all the worlds cars:


January 18, 2011 6:50 PM

No doubt that upstream emission should be considered in both hybrid-electric and EV-like, why didn't the industry ever consider a greener source of electricity? Maybe it doesn't have to come from burning coal to get the energy we need to power the car, we still have options like the FREE SOLAR POWER or some other biofuel cell options...

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