California ARB Details Refutation of EPA Claim that New Federal CAFE Is More Effective at GHG Reduction than AB1493
03 January 2008
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Comparison of the cumulative greenhouse gas reductions of AB1493 (Pavley Regulation) and the CAFE standards if implemented in California, using the California fleet mix. Click to enlarge. |
In public comments concerning the denial of the waiver that would have cleared the way for California and the other adopting states to enforce the AB1493 rules (Pavley Regulation) regulating greenhouse gas emissions from light duty vehicles (earlier post), EPA Administrator Stephen Johnson claimed that the new federal CAFE standards would be more effective than the California rules in reducing greenhouse gas emissions.
The California Air Resources Board’s (ARB) staff prepared and documented its own technical evaluation refuting Johnson’s claim, which was undocumented. The ARB study shows that California’s regulations on tailpipe greenhouse gas emissions are more effective than the new CAFE regulations contained in federal energy bill.
California standards regulate GHG emissions; federal CAFE standards are aimed at reducing the nation’s fuel consumption. This study makes the necessary calculations to allow the two programs to be evaluated so that the reductions in GHG gases under the California rules can be compared to those expected from implementation of the CAFE portion of the 2007 Energy Bill. The results show that the Administrator’s claim that the federal CAFE program is better than California’s program at reducing GHG emissions from motor vehicles is wrong, both in California and in those states that adopt the California standards.
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Comparison of projected fleet fuel economies resulting from application of California Pavley and federal CAFE to California and federal new fleet mixes. Click to enlarge. |
In its analysis, ARB employed both the miles per gallon metric used in the 2007 Energy Bill and the GHG emissions rates that are the basis of California’s regulation. ARB staff translated, as best as possible, miles per gallon to equivalent GHG emission rates. ARB staff then used the EMFAC on-road emissions inventory model to develop an apples-to-apples comparison of tons of greenhouse gases reduced under the federal CAFE standards to those that occur under the Pavley rules.
...by 2016, the adopted Pavley rules will have prevented a total of 58 MMT of CO2 from being emitted into the air [in California] as compared to 20 MMT if the new Federal standards were implemented. By 2020, the combination of the Pavley 1 and 2 rules will have prevented 167 MMT of CO2 emissions from being emitted as compared to 76 MMT of CO2 if only the Federal CAFE were implemented.
The EMFAC model reflects the current and projected vehicle fleet in California, based on data from the Department of Motor Vehicles, the Smog Check inspection and maintenance program, and local and regional transportation planning agencies. The emission rates in the EMFAC model are derived from testing of in-use vehicles.
ARB distributed total vehicle miles travelled (VMT) estimates among the vehicle classes using DMV population data and mileage accrual rates obtained from the Smog Check program.
The 2007 Energy Bill that enables the new CAFE standards also provides for a fuel economy credit for vehicles that are capable of operating on alternative fuels such as E85. Since manufacturers have indicated that they will produce large numbers of flex-fuel vehicles capable of operating on E85, ARB staff believes that manufacturers are likely to take full advantage of the credit between 2011 and 2019. The analysis includes this assumption in the calculation of the benefits of the new CAFE standards on GHG reductions.
The analysis also looked at GHG emission reductions achievable not only in California with the existing AB1493 (the Pavley Phase 1 rules) but also those expected when the ARB extends the existing requirements to obtain further reductions in the 2017 to 2020 timeframe (referred to as the Pavley Phase 2 rules).
The analysis shows that the California CO2 emission standards are 16% more stringent for 2016 models and 18% more stringent for 2020 models than under the new federal CAFE.
ARB calculated that for the projected mix of the California fleet, the Pavley Phase 1 rules would increase the average fuel economy to 36.6 mpg by 2016; under Federal CAFE, the CA fleet mix would show a 30.5 mpg new fleet fuel economy in 2016.
ARB projected that Pavley Phase 2 rules would increase that new fleet mpg to 43.9 mpg by 2020; federal CAFE would take the California fleet mix to 35.7 mpg by 2020.
ARB also applied the analysis to the federal fleet mix. (The Federal fleet is assumed to have 50% passenger cars/LDT1 trucks and 50% LDT2 trucks. This compares to 70% passenger cars/LDT1 trucks and 30% LDT2 trucks for the California fleet.)
For the federal fleet mix, Pavley Phase 1 resulted in 33.1 mpg by 2016, compared to 29.6 mpg for Federal CAFE. By 2020, the Pavley rules would deliver 40.4 mpg in the federal fleet, while CAFE results in the targeted 35 mpg.
California has filed suit against the EPA to overturn the denial. (Earlier post.)
Resources
Yet another analysis not worth the paper it is written on.
Two factors will completely overturn these simple minded projections: The analysis does not account for market driven changes both in (1)the fleet mix and (2)vehicle usage.
Lets consider how the Volt and similar vehicles might change the fleet mix. Very view cars get over 25 miles per charge today. Imagine the CO2 emissions from the tailpipe being zero for 2/3 of the miles driven by the owner. How valuable are the California numbers that do not account for smokestack emissions that provide those miles?
Those that advocate these "fixes" are simply extending the reach of government with empty, ill conceived, promises. Cafe is a joke and tailpipe regulation is the punch line.
Oil is nudging $100/barrel now. What will it be in 2015? What if gas is over $5.00 per gallon in 2015, how will that change the fleet mix.
Bottom line, Cafe was bad enough, and now even more tax dollars are to go up in smoke debating fictional outcomes.
Posted by: Van | 03 January 2008 at 07:56 AM
I find it deeply ironic you refuted a "fictional outcome" with the effect a fictional car (Chevrolet Volt) will have on it. Furthermore, most states which are adopting CA emissions standards have renewable electricity standards and a regulatory environment that make new coal power stations extremely difficult to site. So in the worst case scenario we are powering the cars using combined cycle natural gas, which is about 3x more efficient converted heat to usable energy than a car's engine. Oh, and the power station's emissions are more tightly controlled, frequently away from population centers, and the natural gas is cleaner and yields more energy per unit of CO2 emitted in the first place.
Posted by: Voice of Reason | 03 January 2008 at 09:08 AM
Posted by: Engineer-Poet | 03 January 2008 at 09:59 AM
Van:
The analysis is surely wrong, but I'd still prefer new laws to be based upon such analysis rather than guessing, prejudice or lobbying.
Posted by: DavidJ | 03 January 2008 at 11:13 AM
Depletion of N. American natural gas? Proved reserves increased in 2006 vs. 2005. That does not support your hypothesis. There have been predictions of natural gas depletion since the Carter era and they have all been dead wrong.
Posted by: Voice of Reason | 03 January 2008 at 11:43 AM
Yes, depletion of N. American natural gas. Some of the "proven reserves", like the Barnett shale, become uneconomical to produce past about 4 years; the Fayette shale in Arkansas is apparently not economical at all. What will it take, when the inputs required to get the energy out include energy?
If N. America has so much gas, why did the US nitrate industry largely shut down and move overseas? Why are there so many plans for LNG import terminals? Perhaps because these "reserves" are too expensive to produce? Your claim does not stand up to even cursory scrutiny, and your nick makes you look like a propaganda troll.
If we had an aggressive program to insulate buildings, add passive-solar features and use cogeneration to supply the remaining heat demand, we might be able to produce the electricity from natural gas (at least during the heating season). But as an addition to current demand? I don't think so.
Posted by: Engineer-Poet | 03 January 2008 at 01:58 PM
Van,
I love you free market guys. Where is the free market in oil? In OPEC? In the five oil companies that control94% of the retail petroleum distribution in the US? Milton Friedman, Calvin Coolidge and Adam Smith would all agree that there is no such thing as a free market in petroleum products.
Given the fluctuations in price from 1972 to 2008, why on earth would we all sit around and hope that a high oil price produces the desired GHG, energy security and efficient transportation results we desire (and desperately need?)
Just because I believe in a free market whereever possible doesn't mean I am not free to set government policy to achieve desirable goals. After all, I believe in evolution, but I'm not going to let a strep infection kill me just because that would be the natural course of events if not for penicillin.
Both CAFE standards and the ARB GHG are good policy. Let's not commit societal suicide because we believe in the tooth fairy and free oil markets.
Posted by: dollared | 03 January 2008 at 02:10 PM
Who would have thought when we went to school some of the highest positions would be so available to those whose only unusual qualification is to speed up the spin and turn a blind eye to untruths.
But these thick skinned will happily oblige in order to hold power.
Always knew it went with the territory but how can they live with no shame?
We are entitled to different opinions but reality can only be shared.
Posted by: arnold | 03 January 2008 at 07:48 PM
Drivel and nonsense.
CARB is desperately trying to find a justification of its further existance, now that the job for which it was created is coming to an end.
CARB was chartered to cleanse the Air in California and to undertake such extra measures as would accomodate the unique air inversion problems of the Greater Los Angeles basin. It was even allowed to express early tougher standards in the "emergency" of dirty air. No such situation exists like that with CO2. Its presumed effects are worldwide, and not visible for hundreds or thousands of years, even to the "true believers".
That air is not yet clean; but its well on its way. By the early teens, America will be be able to claim Victory and acknowledge that the Air in America is now as clean as the day the Pilgrims arrived in the New World.
Americans have led the world in forcing such a cleanup. We have gone farther and faster, have implemented tougher standards, and earlier than any one else. Americans of whatever political persuasion have fought the good fight, and succeeded faster than any other society. Amercans will arrive at our destination of clean air before any others. Americans ought to be Proud.
The Auto and light trucks have become so clean that the CARB is now off looking to install catalytic converters on marginal sources of polution such as lawn mowers, hedge trimmers, farm tractors, railroad engines and auxiliary power for docked ships in California ports.
With the cleasing of the air job almost done, there would be no need for CARB unless... they can find a new justification for existence,budgets and headcount.
Nothing is more immortal than a government agency. Like Vampires you have to drive a stake through the heart.
CARB has decided that they can sign onto the fight agaisnt GHGs around the world. California is too small to affect the global air, if not a gram of CO2 were emitted in all of California. But that is irrelevant, to its efforts at justifications for continued life and budgets.
Meanwhile modern 21st century Science and the UN's IPCC almost daily shrinks the presumed power of the GHGs. The war against the GHGs has been succesful too. All the GHG gases except CO2 have now come under control, and are stabilized and declining. The shrinkage in GHG warming power is down to but 10% of what was originally feared in the 1970s and 1980s, with more reductions coming. Problems that might have occurred in a 100 years now would take a 1000 years to occur with the reduced power of CO2, if they occur at all.
CARB is setting off to expand its charter to justify its continued existence by fighting GHGs, as long as we continue to care about GHGs. ARB 1493 probably will be repealed long before the Pavely Phase 2 cutover and perhaps before Pavely Phase 1 is even well launched.
Why? Because the World simply won't care about the nonexistent threat, just like the world doesn't care today about Y2K.
Posted by: Stan Peterson | 03 January 2008 at 09:44 PM
"Yes, depletion of N. American natural gas. Some of the "proven reserves", like the Barnett shale, become uneconomical to produce past about 4 years; the Fayette shale in Arkansas is apparently not economical at all. What will it take, when the inputs required to get the energy out include energy?"
They become uneconomical to produce past 4 years because petroleum engineers have gotten better at extracting gas faster in the first place. The article you linked to even says that (though TheOilDrum is a source without ethics anyways; what's their next narrative to explain the reason why global crude production is setting all time records and Saudi production has moved back above 9 million barrels a day after The Oil Drum called both a global peak and a Saudi peak?).
And of course an experimental play like the Fayetteville is not economical during the early wells (187 wells drilled during a time period where perhaps 40,000 natural gas wells were drilled in North America). You have to gather data and build infrastructure to drive the marginal cost of production down.
Industry is moving overseas and LNG import terminals are being constructed to use foreign gas that is produced at costs of less than 1.00 per mcfe. So while natural gas is more expensive in North America than in reserve-endowed nations like Qatar or Trinidad there is no evidence of depletion (a word implying exhaustion, or extraction all but impossible).
Posted by: | 03 January 2008 at 10:51 PM
@Stan:
I believe there is a large risk / near certainty that CO2 will cause problems in the near future through the warming of the climate. Therefore I have a question for you.
You state that the effects of GHG will only happen in 100s or 1000s of years. Let's take 1 example: the size of the Norh Polar ice cap. When you look at the graphs, the decline is clearly visible, and speeding up. In the satellite age, I can safely assume this information is reliable. This is happening NOW. Where does your information come from? Or did you ignore the size of the North Polar ice cap in your assessment?
Posted by: Anne | 04 January 2008 at 01:42 AM
Stan Peterson propagandizes:
The decrease in precipitation and the shift from winter snow to rain in the mountains have been apparent for years, and threaten California's water supplies in particular.So what if the effects are worldwide? California is a rather arid place compared to e.g. Ohio; it feels those effects more strongly. It is also a major source of economic activity, so it makes sense for California to push harder to solve the problem.
Another slick half-truth. California's standards already affect more than half the vehicles in the US, and the US in turn is responsible for about 25% of world CO2 emissions.I have few doubts that you are a paid propagandist, charged with moving the Overton window to make denialism more acceptable (regardless of the costs). This is despicable.
Even more despicable is the outright lying of the no-name poster:
Global crude+condensate peaked in 2005 and we have not exceeded that since. There are increases in things like natural gas liquids and biofuels, but these have much less energy/barrel than crude and the latter are typically made using plenty of oil, gas or coal and represent energy transformed rather than created.Posted by: Engineer-Poet | 04 January 2008 at 05:44 AM
Stan...What political drivel are you pumping out? Environmental Americans for decades pushed America to clean up its pollutions. & all the way, non-environmental Americans opposed the cleanup. So don't say all Americans cleaned up, by using the American flag to cover yourself.
& of course, poor children are still coming down with breathing & heart disease the closer they live to freeways(what an errorneous naming). So why do you say the pollution war is over? You got to visit some kids in hospitals with breathing problems.
Posted by: litesong | 04 January 2008 at 06:11 AM
Stan's job is to make denialism acceptable, period. His reasonable-sounding statements are only there to maintain credibility for his main talking point.
Posted by: Engineer-Poet | 04 January 2008 at 07:30 AM
Actually, the previouys monthly global oil record was 86.13 million barrels a day set in 2006. The IEA reports a new record monthly production 86.5 million barrels a day during November of 2007. I imagine you'll concoct some fallacy ridden narrative to support your position. What do you need to do to warp the data in your favor? Back out natural gas liquids (which are surprise, put in with crude oil because they are components of crude oil)? Back out biofuels (which were never in the data in the first place)? Back out tar sands production (which is crude oil nonetheless)? Are you just ignorant? Or do you enjoy spreading misinformation?
http://www.platts.com/About%20Platts/Press%20Room/2007/121107.xml
http://omrpublic.iea.org/currentissues/full.pdf
http://i-r-squared.blogspot.com/2007/11/this-week-in-petroleum-11-28-07.html#links
Posted by: Voice of Reason | 04 January 2008 at 10:05 AM
EP: Given that one of the major tenets of peak oil theory is that you cannot accurately pinpoint the actual peak until upwards of 5 years after the fact, it seams a little premature to declare peak in 2005. You run the risk of crying wolf and hurting your credibility. The existence of peak is much more important than the actual date.
P.S. I wouldn't worry about Stan too much. He's just local colour, I don't think anyone takes his diatribes all that seriously anyway.
Posted by: Neil | 04 January 2008 at 11:25 AM
FYI: You're confusing NGL's and lease condensate, which is recondensed liquids from the gas stream at oil wells. You get NGL's from fields which yield no oil, but not lease condensate. There is an increasing amount of NGL being produced as natural gas becomes an exportable commodity.
(cot'd)
A new monthly all liquids peak. That includes natural-gas plant liquids, which are things like propane, butane and isobutane. These have much less energy per barrel than crude.Posted by: Engineer-Poet | 04 January 2008 at 11:48 AM
The US counts both the diesel which cultivates corn for ethanol and the propane used to dry the grain and distill the mash as "fuel produced" along with the ethanol which eventually makes it to a pump. You can cheat even more by counting 78,000 BTU/gallon ethanol at parity with 126,000 BTU/gallon gasoline.
What kind of "reason" supports this skulduggery?
Ah, projection. I'll give you a hint: failing to count different things differently is warping the data, and NGL's are different from crude oil (they have less energy).Posted by: Engineer-Poet | 04 January 2008 at 11:49 AM
@Litesong,
Despite the co-option of the Environment issue by the left, whose only unconstrained governing experience is to make a complete cesspool of the Communist Eastbloc, your rhetoric doesn't wash.
Earth Day was bipartisan. The Republicans founded the EPA. The first clean air regulations were promulgated in a Republican administration. The first "conservationist" President was Theodore Roosevelt, a Republican.
But this is NOT a partisan issue.
I quote these Republican contributions, only to clear, and balance the record. There are plenty of Democrat contributions to the environmental movement. Both Parties have added Wilderness and Parkland to the national wilderness inventory. To the point where the land use set asides for such uses, exceeds the original area of the thirteen original states on the USA!
And not all industrialists are evil, despite leftist propaganda to the contrary. GM sponsored the R&D that led to the developemnt of the catalytic converter, that makes the automobile clean. Cummins and Mercedes have developed the T2 Bin 5 compliance technology, to make "almost clean deisels" feasible. Joint governemntal and Industry R&D has made the Li-Ion battery more than a laboratory curiosity. Ditto for the Fuel Cell going back to the Appollo Project. Compact flourescent lights, higher efficiency appliances, furnaces and Air conditioners came from hard headeds profit motivated indusrial research.
No loud mouth Green politician produced any of those advances.
Both Democrats, my old Party, and Reublicans and Independents have supported and funded the cleanups. Certainly, there has been disagreements, some about methods, some about schedules, but none really about objectives. America could not have achieved so much in so short a time, a mere thirty five years, if there was not bipartisan support for the objectives.
Posted by: Stan Peterson | 04 January 2008 at 12:10 PM
@Anne,
The Arctic polar sea cap ice has been widely reported as an environmental disaster by the media pumping AGW this summer. Yet if you look at the reports of the US government's satellite monitored ice coverage, NSIDC NASA MMIP, we find that sea ice is up 1.8 million sq kilometers in the Antarctic and down, 800,000 sq km in the Arctic. Net? Net?
Ice has GROWN by over 1 million sq km, worldwide this year. When its summer in the Arctic its winter in Antarctica. Ever wonder why nobody told you that?
http://arctic.atmos.uiuc.edu/cryosphere/IMAGES/current.area.south.jpg
http://arctic.atmos.uiuc.edu/cryosphere/IMAGES/current.area.jpg
No one seems to be reporting with the onset of winter in the Arctic, the sea ice freeze up has been the highest on record.
In short, Much Ado about Nothing.
Posted by: Stan Peterson | 04 January 2008 at 12:54 PM
Why should we care if all the "missing" ice from the Arctic is in the Antarctic? I dunno, why should we care if there's drought from Mississippi to the Carolinas if it's plenty wet in Washington and British Columbia?
Maybe because it causes damage in both places? Ice around Antarctica doesn't help the Pacific walrus, which are starving this year because there's no ice to let them forage on their feeding grounds and food supplies near shore are depleted.
Stan, thanks for proving that my previous appraisal of your character was too generous by half.
Posted by: Engineer-Poet | 04 January 2008 at 02:41 PM
There is no mention of a "liquids" category in the report. It explicitly says oil. The IEA does not count biofuels in oil production. They say so explicitly in their definition. They may show up in products, but not in oil.
"Additives
Additives are non-hydrocarbon substances added or blended with a product to modify its properties, for example, to improve its combustion characteristics e.g. alcohols and ethers (MTBE, methyl tertiary-butyl ether) and chemical alloys such as tetraethyl lead. However, ethanol is not included here, but under Gas/Liquids from Biomass."
From: http://www.iea.org/Textbase/stats/defs/sources/crude.htm
NGL's are naturally found in crude as well. In fact, 1/4 of marketed NGL's are produced in petroleum refineries from crude oil. I would wager all of them were found in crude before natural gas (propane certainly was). NGL's even includes pentane, which you also find in gasoline.
Regardless, NGL production has only increased by a negligible amount since 2005 (30,000 barrel a day increase from 2005 to 2006 in the US [where 1/3rd of all NGL in the world are produced]) according to the EIA: http://tonto.eia.doe.gov/dnav/ng/ng_enr_ngl_dcu_NUS_a.htm
Your arguments are bunk. Stop spreading disinformation.
Posted by: Voice of Reason | 04 January 2008 at 05:31 PM
A better source for NGL production: http://www.eia.doe.gov/pub/oil_gas/natural_gas/data_publications/crude_oil_natural_gas_reserves/current/pdf/ch5.pdf
Still more of the same, small year over year increases (3-4).
Addressing your non-energy equivalence argument... It is bunk because their is no distinction for any of the barrels of crude oil counted. Heavy crude oil has more energy than light, but it is cheaper nonetheless. The magic is that light hydrocarbons require less processing in order to make final products. The raw energy of an input is not the concern. It is what amount of energy that input will yield once it is made into final products.
Posted by: Voice of Reason | 04 January 2008 at 05:44 PM
@EP,
I have steadfastly refused to get into an ad hominum contest. We both have our scientific bases for our statements.
The Warming hysteria by the media was creating a false premise that all sea ice was disappearing. Well the data I supplied showed that it was not. And yes, ice melts in the summer and freezes in the winter. And it is summer in one Antipodes while its winter in the other. The net sea ice cover worldwide is a better measure of whether global melting or freezing is occurring. Is that such a big surprise?
The Arctic sea ice cover has much to do with the current Polar Oscillation. Every few decades the wind and currents reverses direction and the East Arctic gets the temperate air entering the Arctic while the west Arctic receives the freezing air that has traversed the Pole. One side of the Arctic cools, the other warms. A few decades later the Polar Oscillation reverses ands the East Arctic freezes and the West Arctic warms.
Its been going on as long as we have been taking weather measurements, for the last few hundred years and is nothing particularly new, unless you have some hysteria tot spread.
You did notice that the article spoke of changing currents and said warmer non-polar water was entering via the Bering Straits and the Chukchi Sea and exiting west of Greenland. Might that be an indication or a reference to a changing Polar Oscillation perhaps?
Posted by: Stan Peterson | 05 January 2008 at 12:18 AM
The filter has gone bonkers, so I'm going to break this into very small parts to find the problem. Sorry, but there's nothing else I can do.
Quoth the Voice of "Reason":
From your source for TWIP:
It might help if you had some familiarity with what you cite.
Posted by: Engineer-Poet | 05 January 2008 at 09:17 AM