California ARB Staff Posts New Concept Paper for ZEV Amendments; Encouraging BEVs and PHEVs
10 November 2007
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| Among the amendments currently proposed by ARB staff is a method for calculating Equivalent All Electric Range to account for a variety of operating strategies for plug-in hybrid electric vehicles. The plot is an example of the application of the new formula. Click to enlarge. |
The California Air Resources Board has posted a new concept paper outlining proposed amendments to the zero emission vehicle (ZEV) regulation. (Earlier post.) In developing the new proposals, staff started with the range of proposed amendments heard at the 24 July 2007 workshop, and considered comments received at the workshop and in dozens of subsequent meetings with affected stakeholders.
The new concept paper presents six, more refined amendment proposals—particularly in the area of plug-in hybrid electric vehicles (PHEVs)—as a starting point for further discussions with interested stakeholders and in preparation of the Initial Statement of Reasons and proposed amendments for the ZEV regulation.
The amendments cover: the Alternative Path to the ZEV requirement; the use of battery electric vehicles (BEVs) after 2008; hybrid electric vehicles, including PHEVs; neighborhood electric vehicles (NEV); timelines for intermediate volume manufacturers; and an extension of the travel provision that allows ZEVs placed in any state with the ZEV regulation to count in California.
| Existing Alternative Path Requirements | ||
|---|---|---|
| Phase | Model Years | Total target |
| I | 2005 to 2008 | 250 |
| II | 2009 to 2011 | 2,500 |
| III | 2012 to 2014 | 25,000 |
| IV | 2015 to 2017 | 50,000 |
Alternative Path. In 2003, the Board made its most recent amendments to the ZEV program, increasing the ZEV requirement to 16% in 2018. It also defined an alternative path for automaker compliance with the ZEV regulation that was solely designed to advance the commercialization of fuel-cell vehicles. Also, the credit system was adjusted so that one fuel cell vehicle garnered the same credits as 10 battery-electric vehicles.
Under the Alt Path, automakers are required to produce their sales-weighted market share of a target number of vehicles during four multi-year implementation phases. With fuel-cell vehicle development not proceeding as expected, ARB has been grappling with whether or not to ease the requirements.
Under the proposed amendment outlined in the November concept paper, ARB would maintain the 2,500-unit target for Phase II.
For Phase III, ARB would maintain the 25,000 target; establish a floor of 10% of those vehicles which must be either hydrogen fuel cell or battery electric ZEVS; and allow the remainder of the target to be met with a new category of “silver +” vehicles. Silver + vehicles are defined as high scoring (greater than one credit per vehicle) AT PZEVs that utilize fuel that can be used in a ZEV—e.g., plug-in hybrid electric vehicles (PHEV) and hydrogen internal combustion engine vehicles.
For Phase IV, the fuel cell/BEV floor would be set at 50% of the target of 50,000 ZEVs, and silver + vehicles would be allowed to fulfill the remaining 50 percent of the target.
ARB staff views the silver + vehicles as a more significant technology bridge to ZEVs than conventional AT PZEVs.
The requirement that they make use of a ZEV fuel significantly shifts the user towards the ultimate goal of electric drive using either batteries recharged from the grid or hydrogen. This is not an easy offset option for automakers. For most automakers it means an entirely new product that has not yet been demonstrated. In this sense, the silver+ option is highly technology forcing and at the same time incrementally more valuable as a bridge to pure ZEVs than silver vehicles.
A second proposal in this amendment area combines the Alternative and Base Paths into a “New Path” for Phase III and beyond that maintains the vehicle numbers. Staff is making this proposal to simplify the regulation, which most stakeholders, including staff and Board Members, are saying has become too complicated.
The New Path would return the compliance calculation to an annual percentage requirement for ZEVs with options to comply with percentages of PZEVs, AT PZEVs and a new AT PZEV plus or “silver+” category.
Battery Electric Vehicles. Another proposed amendment adjusts the credit ratio between full-function BEVs and hydrogen fuel cell vehicles. Rather than the existing 10:1 ratio, ARB staff is proposing a 1.33:1 ratio.
Hybrids and PHEVs. ARB staff is proposing several modifications to the hybrid electric vehicle (HEV) AT PZEV requirements, mostly to address plug in HEVs (PHEVs).
When the regulators first considered plug-in hybrids, they assumed that the vehicle would run in all-electric charge-depleting mode until the battery state of charge reached the designated threshold of depletion, and that the vehicle would then transition to operation on the engine and charge-sustaining mode.
Under a blended operating strategy, however, the engine may turn on before the depletion of the battery is complete—to assist with acceleration, top speeds or peak power requirements, for example. ARB staff is proposing retaining the same 10-mile minimum all electric range (AER)—now to be called Equivalent AER, EAER) for blended mode plug-ins as in the existing regulation.
The EAER takes the miles driven by the PHEV in charge-depleting mode and then adjusts those miles by the percentage of those miles operated electrically (Equivalent Electric Range Fraction or EERF). Staff further proposes that the EAER credit allowance be adjusted by a utility factor related to miles driven by consumers that normalizes the credit allowance to a maximum of the credit earned by a city electric vehicle. The proposed equations to govern calculation of the EAER credit allowance are:
EAER = Rcd * EERF
AllowanceAER = (EAER/ 50) * [(1-UFRcd)/ (1-UF50)] * 1.45
Where:
- Rcd is the range of the PHEV in Charge Depleting mode
- EERF is the Equivalent Electric Range Fraction
- [(1-UFRcd)/ (1-UF50)] adjusts for the lower probability that the blended PHEV will be driven far enough to make use of its stored electric energy and is from the 0-100 mile 4th order curve fit from SAE’s J1711, March 1999, page 52 which plots the likelihood of a vehicle being used to travel a daily range in miles,
- (EAER/ 50) normalizes the range allowance to a 50 mile range, the same as the minimum range for a Type I or City EV, and
- 1.45 is the assigned AER credit allowance because this is what a Type I ZEV would earn [2 credits – (0.2 PZEV base) – (0.35 Advanced Componentry allowance)] ≈ 1.45 AER allowance @ 50 miles.
ARB staff is also proposing to add a new, higher-power Type F HEV category that would meet a peak power requirement of 100 kW, or alternatively, when installed on AER-type PHEVs, would demonstrate sufficient power capability to propel an HEV through the entire UDDS driving test cycle on electric power alone.
The Type F HEV category is intended to encourage the deployment of HEV drive systems interchangeable with those deployed in full function ZEVs.
Staff is also proposing the elimination proposes to eliminate the low fuel-cycle emissions (LFCE) allowance for PHEVs and to increase the credit for AER PHEVs under the advanced componentry provision by at least 0.15 credits to recognize and compensate for the LFCE benefits of electric fuel. As a result of this proposed change, now only dedicated LFCE-fueled vehicles (e.g., compressed natural gas and hydrogen, depending on the source) will be eligible for AT-PZEV LFCE allowance.
Neighborhood Electric Vehicles. Staff proposes to increase the credit for neighborhood electric vehicles to 0.30 credits per vehicle, reflecting the vehicle’s positive benefits but limited functionality compared with full function battery electric or fuel cell electric vehicles.
ARB is encouraging stakeholders to meet with them between now and 28 November 2007 to further discuss these proposed amendments. Stakeholders may also provide comments on these topics in writing.
ARB plans the public release of the staff report on 11 January 2008, followed by a Board hearing in Sacramento 28-29 February 2008.
Resources
An already incredibly complex piece of regulation is about to become even more complex. CARB has the right idea in leveling the playing field to take advantage of emerging technologies, but at some point they should close the current ZEV ledger and draft a much simpler, new one that reflects the need to balance improvements on toxic emissions with those needed to reduce well-to-wheels CO2 emissions / increase fuel economy. For example, the 4:3 skew favoring FCVs over BEVs makes no sense at all IMHO. However, this can and should wait until the lawsuit regarding the EPA waiver is resolved, but cutting red tape ought to be a top priority after that.
One good aspect here is that California is at least trying to find a formula that fairly assesses PHEVs relative to other technologies. On this one point only, I would suggest that a similar formula be developed for the well-to-wheels CO2 footprint of such vehicles so their running costs / global warming footprint can be assessed objectively. EPA may have the exclusive right to advertise MPG numbers in the showroom, but they cannot prevent the state of California from providing additional CO2 data to consumers.
Posted by: Rafael Seidl | 10 November 2007 at 06:33 AM
What on earth is California up to? I would have thought that they would have learned their lesson from the previous ZEV fiasco / failure of the EV1.
As much as they would like to think that regulations force technology, technology forces the regulations right back. That's why they're amending the current regulations -- changing their views on hydrogen, reacting to blended-mode PHEV concepts, etc. The fact that they don't recognize this tendency in both their historical record and their present moves is baffling.
Governments tend to be very bad a prescribing specific technological solutions to problems they are dealing with. They should probably get out of that business. Simpler and better strategies include increasing gas taxes, imposing an MPG-tied feebate across all new LDVs sold in state -- and don't ask what's under the hood. Set (rational) standards for tailpipe-out emissions, and let the manufacturers figure out how to get there.
Putting together a unique credit-formula for figuring out how much each blended-operation PHEV is worth towards some three-stage quota system strikes me as nothing short of mental autostimulation.
(Which is not to say that someone doesn't need to come up with a way to estimate some combined MPG + M/Kwh measurement standard for PHEVs, or a way to calculate their average tailpipe-out emissions profile. It's just probably best to leave those more practical numbers to the EPA, so the same number is applied to the same car no matter where it is sold, and leave it at that.)
Posted by: NBK-Boston | 10 November 2007 at 06:49 AM
Also, having quotas on a manufacturer-by-manufacturer basis is silly, unless the quotas are tradable -- in which case they are not really strict quotas. Porche is in the business of making fun, expensive, gas-guzzling cars. Tesla motors is in the business of making fun, expensive, electric cars. Why should it make a difference whether or not they merge or remain separate companies, when their market shares and environmental impacts are what they are?
Posted by: NBK-Boston | 10 November 2007 at 06:54 AM
How in the world can any automaker guarantee that X% of their sales will be Y-BEV, assuming such a car even exists? Even when my personal politics were much more leftward than they are now, these regulations never made any sense to me.
I'm in agreement with NBK. This is baffling. But one of the things that the California government excels at is layers and layers of red tape.
Posted by: Cervus | 10 November 2007 at 10:04 AM
NBK: I'm with you. Mandate results, not the means to get there. Don't pick design/technology winners and losers.
I once worked for a small engineering firm that designed gear boxes. We got an RFP for a particular reduction drive. The drawing that accompanied the RFP was dead simple: it depicted the outline of the envelope available for the gearbox, input shaft and output shaft location and the required gear ratio. The designer was free to solve the problem as best he saw fit, so no innovation was precluded.
Posted by: Nick | 10 November 2007 at 10:33 AM
Please help reduce my ignorance.
Without doubt governmental agencies do a disservice when they prescribe the specific technological fix rather than the desired result and allow the market to create. But cloddishness of the approach aside, what will be the likely impact of these regs on the market and on the emergence of PHEVs, RXEVs, and BEVs?
Posted by: Don | 10 November 2007 at 12:25 PM
"Also, the credit system was adjusted so that one fuel cell vehicle garnered the same credits as 10 battery-electric vehicles."
You ask: what will be the likely impact of these regs on the market and on the emergence of PHEVs, RXEVs, and BEVs?
I think it is self evident what effect these FCV credits will have on BEVs and PHEVs. Until 10 years down the road, oh sorry, FCVs still cost $100,000 apiece.
Posted by: Emphyrio | 10 November 2007 at 12:43 PM
NBK Boston, let me just ask you this then.
What makes you think that the automotive market is a competitive market with low market entry barriers, and few if any market distortions?
Second, the only reason we have the Hybrids we do now is because of a mandate for them. Both federally, and the PZEV mandate program in California.
That said of course the permits are tradable because right now hybrids count as Partial-ZEVs. Last I checked, California buys quite a few high end sports cars already.
Posted by: GreyFlcn | 10 November 2007 at 02:06 PM
Eight comments on zero pollution efforts mostly sandbagging California because economics & auto makers could be upset. Nothing is said WHY California tries to jump start zero pollution efforts.
Think you ALL have to spend more time in hospitals visiting lung, heart, & cirulatory disease patients...a morgue to see an autopsy of a lung disease patient too.
Posted by: litesong | 10 November 2007 at 03:32 PM
Litesong:
If you'll read the comments more carefully, you'll find that in general commenters do agree with the ends. It's the means that are a matter of debate.
Posted by: Cervus | 10 November 2007 at 03:45 PM
Greyflcn wrote:
Second, the only reason we have the Hybrids we do now is because of a mandate for them. Both federally, and the PZEV mandate program in California.
::::::::::::
Question. If there are mandates why haven't all car makers produced hybrids? Honda and Toyota have offered them for about five years. Strangely enough so has Ford.
You may be right. This certainly isn't a topic I follow. But I believe the mandates are about emissions not method.
Posted by: | 10 November 2007 at 04:39 PM
What mandate forced Honda to sell the Insight in the US in 1999, but didn't apply to GM until now, and still hasn't kicked in for Chrysler, BMW, Mitsubishi, Subaru, etc.?
Posted by: Lou Grinzo | 10 November 2007 at 06:04 PM
Greyflcn,
I think the American auto market does not have low barriers to entry, but I think it is highly competitive nevertheless. One indicator of competitiveness is the number of independent companies participating in the market, and the U.S. auto market is healthy in this respect. There are at least six major full-range carmakers (GM, Ford, Chrysler, Toyota, Honda, Nissan), and nearly as many smaller or niche players (Subaru, Mitsubishi, Hyundai, BMW, VW, Mercedes-Benz, Porsche and the other exotics) Tesla has demonstrated that its possible to at least try the silicon valley startup model in this industry.
I don't think the auto market is undistorted, but using an unnecessarily complex set of regulations to try to remedy either a distortion or a market failure (pollution externalities are a classic market failure) is just a recipe for more headaches.
I do not believe that there is a specific mandate on manufacturers to produce hybrid cars, but there are hybrid-specific tax credits which has made them more affordable and competitive. That sort of spending occupies a middle ground, in my mind. The government is choosing a particular technology, which is not usually a great thing, but it is only doing so to the tune of x million dollars freely spent on what is essentially a promotional campaign. It's not tying a whole industry to its ill-concieved favorite choices through the mechanism of binding regulations.
This concluding remark responds to litesong's comment as well: I fully understand why a state, particularly vulnerable to smog, would want to strictly limit air pollution. My grandmother died of lung cancer -- nasty stuff, and I see no need to further linger in cancer wards. But a state should try to achieve its results in the most simple and least restrictive way possible. That way, we are free to (and have incentives to) reach it in the most efficient way possible. Getting there less efficiently makes us all worse off, and that's just pointless.
Why should anyone be forced to spend extra money on, say, a hybrid, when he might rather keep his conventional car and walk more often if he needed to save gas? His freedom to choose is being taken away, and more importantly, so is his money.
Yet any mandate that is non-trivial will do this (a trivial mandate is one which tells us to do something we'd do anyway). Either some consumer will have to spend more out of pocket to buy something he doesn't want, or a company will be forced to sell some number of products at a loss (think fuel-cell vehicles or EV1s) to meet the mandate, and pass on those costs to every buyer of a conventional product. And why? Given flexibility, we could have found a few volunteers who would have taken the bus for a much lower marginal cost, and then spent the rest of the EV1 money (a cool billion, or so) on things we otherwise would have wanted, like side-impact air bags, cancer research, or amusing TV shows. If it turns out that nobody wants to take the bus, then some market-responsive actor (Tesla) will build an electric car at a profit. Life goes on in either case.
Posted by: NBK-Boston | 10 November 2007 at 06:42 PM
Cervus...Reread what is economy-technology babble. Not an ounce of shame for the causative factors that hurt & kill our choked brethren, sisters, & children do I hear, as your reprimand of my post also held no grief & sorrow for the past dead & unnecessary future dead. I restate, you all need some time in hospitals & morgues to straighten up your motives & inspirations why zero pollution vehicles are necessary. Ten thousand scientists, technicians & economists & 10 million consumers who allow themselves to release great heaves of compassion for the dead who could no longer breath in life, would clear this issue & pave the way clearly to proper high population zero pollution solutions. Sure the problems seem big & complicated. But all we need do is end strangling death because we're all trying to move around on the good Earth at the same time.
Posted by: litesong | 10 November 2007 at 09:23 PM
Emphyrio,
I may be dense but this is not self evident to me. The proposed regs change the bias you referenced: "Rather than the existing 10:1 ratio, ARB staff is proposing a 1.33:1 ratio." And they propose a new formula for PHEV credits.
What impact will it have? Will Phoenix get a boost? Aptera? Tesla? Zap? GM? Toyota? How much of a motivation is this?
Litesong, reiterating what has been said: a noble end is ill served by ineffective means.
Posted by: Don | 10 November 2007 at 10:00 PM
The free market solves all problems. Government is a cancer.
Posted by: Libby Tarianne | 10 November 2007 at 11:42 PM
Litesong:
It is not enough that we "do something" when that something does not give us the intended result. So far, CARB's actions have not delivered, after well over a decade there are still no readily available BEVs. Rafael and NBK have brought up some specific points. Do you have any critique?
Posted by: Cervus | 11 November 2007 at 12:05 AM
Don, that was the single most interesting point in the article for me. I never understood why hydrogen cars got 10:1 credit over electric cars to begin with. Wouldn't it be logical to set it 1:1? Or perhaps even 1:2 since battery-powered cars are more energy efficient?
This change certainly won't help Phoenix, since they've already worked hard to get their BEVs to qualify for those 10X credits. I'm guessing that's what prompted the change in rules. The rules were written to ensure that only HFCEVs would qualify for the 10X credits. When Phoenix managed to qualify their BEV anyhow, it must have been embarrassing for CARB and a threat to their pro-hydrogen agenda.
The other BEV and PHEV startups might get some minor boost from this change, only because big car makers won't get as much credit from their hydrogen cars and will therefore be more motivated to scrounge for credits from other sources.
Posted by: Tony Belding | 11 November 2007 at 05:16 AM
Greyflcn wrote:
Second, the only reason we have the Hybrids we do now is because of a mandate for them. Both federally, and the PZEV mandate program in California.
::::::::::::
Actually, we have hybrid cars as a direct result of Japanese carmaker exclusion from the USDOE Supercar Program of the 1990's. This program to design a family car that achieves 80 mpg drove Honda and Toyota to start their own parallel programs. As the Supercar program degraded to infighting and essentially a government gift of $1 billion to the "big three," Honda and Toyota continued toward established goals and released the Prius and Insight to market.
Learn more about it in the Chicago Tribune special report:
Supercar: The Death of a Dream
http://www.chicagotribune.com/news/specials/chi-scoverview-story,0,3535916.story
Posted by: | 11 November 2007 at 06:00 AM
Cervus...Not econo-tech talk, but sorrow for unnecessary death IS the first 'do something' that needs to be done by tens of thousands of 'key' people & multi millions of us all. You need to do that & everyone that reads this. At age 5 I knew tailpipe 'stuff' wasn't good & for 50 years have put less 'stuff' in the air & encouraged many others to do the same. The future shows the way to put 'no stuff' in the air. California sees the future. Instead of criticizing, despite my ailing body I got an electric bike. Severe restrictions indeed here in cold wet winter-approaching Washington State, but now my electric bike shows me personally that it is the way to the future. I pass through town with less than 1/700th the pollution of a ICE car(& none in the town) as an electric car would nearly duplicate. An added bonus: electric motors are undeniably elegant(a rich man would lust after a chauffeur who could drive so quietly & smoothly as an electric motor can perform). My 1/700th or less pollution is my critique. Stop the econo-tech talk & JUST DO IT. Encourage ALL efforts towards zero pollution. Zero pollution is possible. Zero pollution is...the sweet yell from young lungs that aren't gasping for a dying breath.
Posted by: litesong | 11 November 2007 at 09:56 AM
Funny thing: when it comes to CARB ZEV mandate, even most passionate proponents of CAFÉ and Kyoto become free marketeers…
Posted by: Andrey | 11 November 2007 at 04:43 PM
Tony,
So then Phoenix, and to some lesser degree by extension, ALTI, are somewhat hurt by this. It seems that Miles Auto Group and Zap (with their already expected to be mostly affordable Chinese imports) will be the most immediate beneficiaries. Aptera? Given that it is classified as a motorcycle, does it count? Tesla too but at their price point of less impact. GM gets a big step up if they bring the Volt out on time (and with their other lesser plug ins, even if they do not.) Toyota gets a slap down. Or am I reading the tea leaves incorrectly?
Andrey, neither Kyoto nor CAFE presume to prescribe what precise fix will work. They each merely set up a set of circumstances for the free market to work with in. They set the goals and let the market, or the individual nations in some cases, figure out how to get there. CARB ZEV instead seems to be an attempt to micromanage the solution. And politicos are poor at handicapping which technology will bear fruit best and on what timetable the fruit will ripen.
Posted by: DON | 11 November 2007 at 05:56 PM
I do agree that the regulations are complex and that setting simple targets for fuel economy would be a straight forward piece of legislation. I believe that California is trying to internalize the well-to-wheel analysis with their ratios for credits.
For example - how do you easily find the fuel economy of a plug-in hybrid? It will depend on how the electricity is generated in that section of the grid. It will depend on the user's particular habits with regard to frequency of charge and drive cycle.
These are things outside of the control of auto-maker and definitely out of California's control. By given a ratio that favors BEV's over mildly hybridized trucks (eh hem... Chevy Tahoe, I'm looking in your direction) it can potentially internalize those factors.
Not that I agree with their ratios... FCEV's are, IMHO, far from "efficient, clean, reliable" energy at the moment.
BEV's, Plug-in Hybrids (especially highly hybridized or series hybrids) have the best chance of making an environmental difference today and in the near future.
Posted by: TR | 11 November 2007 at 07:19 PM
DON:
CARB (and EPA, DOE, DARPA, NASA, and some others) are not politicos. They use expertise of thousands best scientists from academia and engineers from industry. They do know better what they are doing than any other entity.
Environment Protection does need serious governmental regulation, other vice it does not work. So far, CARB was extremely successful in their endeavors. I give them credits and wish them luck in their struggle to clean-up the air we breeze.
We can (and should) discuss and criticize particular steps they follows, but dismiss from abstract “market know better” sentiment what they are doing is just childish.
Posted by: Andrey | 12 November 2007 at 12:18 AM
California is a blue state. It elects Democrats, and they write this sort of central command and control regulation. How about something simple, like vehicles with an EAER of 10 miles get to use the "High Occupancy Vehicle (HOV)lanes" and get a $3000 incentive for purchase. Let the market do the rest.
Posted by: Van | 12 November 2007 at 05:24 AM