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California Limits on Auto CO2 Emissions Tackle Altfuel, Hydrogen and Plug-ins Too

California’s new regulations limiting greenhouse gas emissions from new vehicles cleared the final hurdles with the state Office of Administrative Law (OAL) in September. The new rules package becomes operative 15 October 2005, and becomes effective 1 January 2006.

Positioned by opponents as an indirect fuel economy regulation (based on the correct premise that if you burn less fuel, you emit less CO2) the rules have a more complex set of measurement criteria that, as asides, open up the possibility for fuel-inefficient E85 vehicles and make it difficult for hydrogen-powered cars to conform to the regulations.

The new rules limit the amount of carbon dioxide, methane, nitrous oxide, and hydrofluorocarbons (typically used as refrigerants in air conditioning systems) that new vehicles can emit per mile beginning with model year 2009.

The limits tighten each year after that, and by 2016, greenhouse gas emissions from lighter vehicles will be cut by one-third, while greenhouse gas emissions from heavier vehicles will be cut by about one-quarter.

Manufacturers earn debits for falling short of the requirements, and have up to 5 years to earn enough credits to erase the debit, after which they will be subject to civil penalties.

The auto industry responded by challenging the regulations in federal court, a suit which has yet to be resolved. Despite the industry protests, however, the CO2-reduction targets set by the California rules are still more lenient than the voluntary target automakers set for themselves for Europe, and more lenient still than the EU’s overall target.

California Fleet Average Greenhouse Gas Requirements
MYCars, Trucks
to 3,750 lbs
3,751 to 8,500 lbs
2009 323 201 439 273
2010 301 187 420 261
2011 267 166 390 242
2012 233 145 361 224
2013 227 141 355 221
2014 222 138 350 218
2015 213 132 341 212
2016+ 205 127 332 206

The EU has set an ultimate goal of 120g CO2/km by 2010 at the latest for new cars. The European, Japanese and Korean car manufacturers’ associations committed to an interim goal of reducing CO2 emissions to 140 g/km by 2008/2009. (Earlier post.)

The California rules, however, specify 201 g/km in 2009 for passenger cars, reach 141 g/km in 2013—four to five years after the comparable voluntary target in Europe—and drop only to 127 g/km in 2016.

The basic California-rule calculation for greenhouse gas (GHG) emissions factors in CO2, CH4 and N2O plus direct and indirect air conditioning emissions allowances if the manufacturer uses a low-leak system, refrigerants such as HFC-134a and so on.

For alternative fuel vehicles, the state rules apply an upstream adjustment factor: a multiplier reflecting greater or lesser upstream greenhouse gas intensity. For natural gas, the adjustment factor is 1.03; for LPG, 0.89; for E85, 0.74.

In other words, the manufacturer of an E85 (note, not flex-fuel) vehicle gets to multiply the total CO2 emissions plus the air conditioning indirect emissions by 0.74.

This could have a significant impact on meeting the new criteria. As a quick example, let’s take a 2006 Flex-Fuel Chevrolet Avalanche, which delivers 12 mpg US combined on an E85 blend.

EPA figures project annual GHG emissions of 7.9 metric tons on 24,135 kilometers driven. That works out to 327.3 g/km of GHG. Apply the 0.74 fuel adjustment factor, and that number plummets to 242 g/km—the California target, as it happens, for a vehicle of this size for 2011.

This is a quick-and-dirty exercise that won’t match exactly the calculations California is requiring. But the power of the adjustment factor could be enormous in helping automakers meet the target. (Just as the flex fuel rule in federal CAFE helped them meet overall fleet economy targets and spurred the production of millions of low fuel-economy E85 vehicles that rarely use E85.)

Under the California regulations, flex-fuel vehicles, along with bi-fuel, dual-fuel and grid-connected hybrids (plug-ins) are evaluated based on tests when operating on gasoline. Manufacturers of plug-in hybrids have a special adjustment factor that can increase based on the capabilities of their battery systems.

For Zero Emissions Vehicles—i.e., hydrogen fuel cell, hydrogen combustion engine and all-electric vehicles (EV)—California has another set of upstream adjustments.

The ZEV upstream emissions factors are:

  • Electric ZEV: 130 g/mile

  • Hydrogen ICE: 290 g/mile

  • Hydrogen ZEV (fuel cell): 210 g/mile

In other words, hydrogen cars are already defined as not meeting the long-term (2016) criteria, absent emissions allowances for A/C that could bring them back down. (For light duty trucks, however, it is a different story.)

The hydrogen penalty derives from the CO2 associated with hydrogen production. There is a loophole that allows approval of a lower upstream emissions factor if the manufacturer demonstrates the percentage of hydrogen fuel (or electricity) produced by renewable energy resources.

EVs, however, are good to go.




This shows quite clearly that EVs really are the best solution in terms of the GHG emissions, now it's up to the industry to lower the cost of batteries and get the vehicles made.


Maybe we could pool our experience and brainpower and start a company to compete with the big boys and make good cheap batteries.


Since there are many many ways to produce hydrogen without any green house gas emissions such as thermochemical water splitting from nuclear or solar, electrolysis powered by wind, hydro, etc...and since this initiative does nothing to account for up stream costs and damage for oil...this is nothing but a political sham and the politicians involved should be criminally prosecuted. This arbitrary adjustment factor on the fuel alone rather than accounting for how the fuel is produced is shameful.


I agree with you Rob...enormous quantities of hydrogen are already produced today and used in the process of making gasoline. Some say the quantity would be sufficient to fuel 100,000,000 fuel cell vehicles. If hydrogen production is so bad...how can these law makers not account for it in the production of gasoline, but account for it when used as a raw fuel. I agree...this law is absolutely shameful.


I couldn't agree more Shandra and Rob...particularly since the 210 g / mile says nothing about the fuel efficiency of the vehicle. If the hydrogen FCV gets 20 miles per kilogram or 82 miles per kilogram like the new DaimlerChysler F 600 Hygenius...the penalty would be the same. That's laughable...the greenhouse gases (assuming there are any...i.e. H2 not produced from GHG free method) would be 4 times as great in the first case as the second case. This was clearly a case where big oil lobbyists must have pushed and won. This is truly criminal for California. Hopefully sanity will return and this won't stand.

Harvey D

Past pre-twisted or twistable government regulations have not reduced gas consumption by vehicles produced by the Big Three in the last 50 years and these new regulations will do no better.

Users will only move to more efficent vehicles when the cost for gas is driven above what they can afford. The pocket book seems to be the best and quickest way to change our attitude. That's why a progressive/variable gas tax is required to keeps the price at the necessary level or around $5/gallon.


There should be a significant adjustment factor for gasoline and diesel since they have plenty of upstream CO2 emissions that are being ignored by this method of calculating, but until hydrogen is actually being produced without CO2 emissions, I see no reason to give it a free pass, but as soon as it is being mass produced renewably, then that should be adjusted to reflect the change.


A free pass...no Schwa. A fair shake...yes. Massive amounts of H2 are already created in the up stream process just to create gasoline...and yet no upstream cost for that? It's the same darn upstream process...creating H2...but because it goes into the creation of gasoline it gets a free pass. That's criminal and sick and twisted.


Not necessarily (legal). Euro 4 requirements aren't a direct match for CARB and EPA07. The cars in question will have to be tested with the ultra-low sulfur fuels and prepped for the US market. But with the ongoing convergence of emissions requirements and the deployment of ULSD, the hurdles should be low.

Plus, if the California CO2 regulation is not overturned in court, the automakers are going to be looking for ways to reduce their new vehicle CO2 emissions--and diesel is one way to do that.

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