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Singapore considers Model S EV a high carbon emission vehicle based on fuel consumption and upstream power generation

Channel NewsAsia recently reported on the case of a Tesla Model S owner in Singapore who, rather than receiving the Carbon Emissions-based Vehicle Scheme (CEVS) rebate he expected of S$15,000 (US$10,841) was hit with a CEVS surcharge of S$15,000 for having high carbon emissions.

Under Singapore’s revised Carbon Emissions-Based Vehicle Scheme (CEVS), all new cars and imported used cars registered from 1 July 2015 with low carbon emissions of less than or equal to 135g CO2/km qualify for rebates of between S$5,000 (US$3,614) and S$30,000 (US$21,681), which are offset against the vehicle’s Additional Registration Fee (ARF). Cars with high carbon emissions equal to or more than 186g CO2/km incur a registration surcharge of between S$5,000 and S$30,000.

The revised CEVS is applicable until 30 June 2017, after which it will be subject to further review.

Singapore revised CEVS bands
Band Carbon Emission(CO2 g/km) Cars Taxis Rebates/Surcharges
A1 Up to 95 $30,000 $45,000 Rebates
A2 96-105 $15,000 $22,500
A3 106-120 $10,000 $15,000
A4 121-135 $5,000 $7,500
B 136-185 $0 $0
C1 186-200 $5,000 $7,500 Surcharges
C2 201-215 $10,000 $15,000
C3 216-230 $15,000 $22,500
C4 Above 230 $30,000 $45,000

As Channel NewsAsia determined, Singapore’s Land Transport Authority (LTA), the agency responsible for planning, operating, and maintaining Singapore’s land transport infrastructure and systems, tested the Models S using United Nations Economic Commission for Europe (UNECE) R101 standards. The result was that the electric energy consumption of was 444 Wh/km. (This figure is approaching twice that of the US EPA’s estimate of 235.6 Wh/km (38 kWh/100 miles) for the Model S 90.)

Singapore applies a grid emission factor of 0.5 g CO2/Wh to all electric vehicles for CEVS analysis to account for CO2 emissions during the electricity generation process. As a result, the equivalent CO2 footprint of the Model S was 222g/km—placing it in the CEVS C3 surcharge band (216 to 230 g/km), along with, for example, the Lexus RX270 and the Maserati Ghibli.

(Using the EPA-estimated fuel consumption of 235.6 Wh/km would have resulted in a carbon footprint of 118 g CO2e/km. That would have nestled the Tesla in the CEVS A3 band (106 to 120 g/km), for a S$10,000 rebate.)

The LTA spokesperson said that the Tesla was not the first fully electric car where grid emission factor was applied. Others, however, qualified for the rebate.

In the US, the fueleconomy.gov website, the official US government online source for fuel economy information, enables users to calculate the upstream GHG emissions from power generation based on location, for use in estimating the full carbon footprint of an EV. (The calculation for “Tailpipe & upstream GHG” is found under the “Energy and Environment” tab for individual vehicles.

As an example, the same Model S with a 90 kWh pack would have a US average carbon footprint of 250 g/mile (155 g/km); 150 g/mile (96 g/km) in North County, San Diego; and 270 g/mile (167 g/km) in Henderson, KY, home to some of the most carbon-intense power generation in the US.



A few comments:

a: The rebate / surcharge curve is VERY steep (-30K-30K between 95 and 230 gms/km)

b: The figure of 0.5 Gms/Wh is a suspiciously round number.

c: Are they testing all cars using (UNECE) R101 ? I hope so.

d: Using just CO2 (rather than a more general pollution mix including NOX, HC, etc.) will skew them towards diesel and you will end up in a mess as in Europe - you need a blend of all pollution types.

e: It is nice to see a country accepting that EVs mostly run on grid electricity and you have to count the CO2 created in generating it. It is not generated by CO2 free magic (unless it comes from Hydro).

f: I would have thought the problem they have in Singapore is congestion, so all cars of a given size are equally bad. After that, urban pollution, such as NOX and particulates (not CO2) are the problem.

g: Be careful what you wish for - you might end up with a load of 3 and 4 cylinder diesels.

h: You could always add solar to reduce the grid CO2/Wh levels.


For an electric car, the Tesla's do not use energy particularly economically and are comfortably beaten by many others.

For lifetime emissions, the high embodied energy in manufacture is also critical, and that correlates highly to weight, and it takes more energy to build an electric car, mainly due to the battery.

So the heavy Tesla cars take a lot of miles to pay back the embodied energy.

The BMW i3 is one heck of a lot more efficient, and when they get more energy dense batteries in perhaps 2017 or so should have enough range to suit many.

Account Deleted

This is absurd. CO2 taxes should not be paid by the end users of energy but by the companies that make the CO2 emitting fuel. In other words, tax coal miners, oil drillers and gass drillers and any company that imports coal, oil or gas. Also the problem with cars is not the non-toxic CO2 emissions but all the other toxic emissions that BEVs do not have. That is killing people as well as unsafe cars. Model S is the safest car in the world by far and it emits zero toxic pollutants.

Davemart fuel cell cars are far less efficient than BEVs so by your own logic you really should direct all your hatred against fuel cell cars and gassers.


It's completely absurd. They consider only that part of a vehicle responsible for pollution during operation. How much pollution is generated for production of tires, for the sheet metal, for the plastics and interior décor of a vehicle? This applies to ICEs as well as EVs. These idiots classify cars in the same manner as India classifies humans in their caste system.


Henrik said:

'Davemart fuel cell cars are far less efficient than BEVs so by your own logic you really should direct all your hatred against fuel cell cars and gassers.'

I have supported BEVs and FCEVs both for over a decade, and have consistently taken a stance in their favour against ICE.

What I do dislike is the gimcrack finances and deliberately obscure accounting of Tesla, not their cars,or at least the Model S as that was properly designed, before Musk sacked the engineers who enabled that achievement and specified perfectly daft vanity projects like gull wing doors on the Model X.

All that is beside the point, which is that in the Singapore rating cycle the Tesla does not score very well.

As for the diversion enabling you to have a fling at fuel cell cars, do try to stick to the subject.

The Teslas are not very efficient in energy use for a BEV.

That is the fact.


Since FCEVs have been brought up I would point out that their emissions should be calculated on an entirely different basis to those of a BEV.

A BEV plugs in, and it running emissions are dependent on the efficiency of the grid.

An FCEV uses whatever hydrogen is specified, which varies by source and does not rely on a general grid.

In Denmark 100% of hydrogen is produced from renewables, and consequently if hydrogen were produced in a similar way in Singapore they should be eligible not for a tax, but a rebate.

OTOH if the hydrogen were produced by steam reformation of NG, then they would become liable for tax.

The differences in cost in Singapore would seem to be ample to cover the extra cost of producing the hydrogen from renewables.


It looks like a flawed incentive plan that they are blocking until they have a chance to revise it. I doubt if there will be much sympathy for the Tesla owners who don't qualify for the rebate.

With the difference between the full rebate and the calculated surcharge of S$40,000 (29,000 US), the Tesla owners could easily install adequate solar panels and storage but I imagine that isn't allowed.


So, any EV that's solar charged gets:

1 - the car surcharge dropped
2 - an equal refund for electric/CO2 generation not reguired..
3 - a many-fold refund for healthcare costs NOT inflected byelectric/CO2 generation ..



The CO2 intensity of the grid electricity changes from hour to hour as different generation modes are used, especially if you have a lot of solar or wind on it.

Thus, while it is easy to get an average level over say a year, it is time consuming to monitor it from minute to minute to calculate how much CO2 was used to actually charge a vehicle at a given time.

In a perfect world, you could have chargers programmed to charge when the grid had the lowest CO2 levels, assuming the car is plugged in overnight or at work to a suitable "smart" charger, and then record this. Using this, you could calculate the average CO2 intensity of your years driving and get a rebate / tax refund / tax demand.

At the simplest level, say it took 4 hours to charge your car, and you had 12 hours in which to charge it (say 7pm-7am) the system would pick the predicted lowest 4 hour slot (and dither the time a little).

This would scale well with increasing solar / wind penetration.

You could easily work it into a purchase tax (or permit) scheme if you wanted to.

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