cleaner transportation and alternative fuels

Gasoline and diesel transportation fuels represent a major share of America’s most pernicious air pollution, water-borne toxins, and climate emissions. While we presently have better technological choices for cleaner electricity production than for transportation fuels, there is still significant progress available from more fuel-efficient vehicles, hybrid technologies, and alternate fuels. There is also much future promise in hydrogen fuel-cell vehicle technologies. CEERT has been working to clean up CO2 from cars and trucks, promote smarter transportation and development planning, and help develop an alternate fuel-distribution infrastructure as near-term means to reduce the impacts of fossil-fueled transportation.

Recent Developments:

Advanced Clean Cars Program

CEERT is working with state and national NGOs to defend the 2022-2025 national passenger ve­hicle emis­sions standards, known in California as the Advanced Clean Cars regulations. (The state has also set California-only Zero-Emission Vehicle (ZEV) sales targets through model years (MY) 2022-2025).

Pursuant to the US-EPA’s April 13 Federal Register notice that it was overturning its January 2017 deter­mination (under the Obama Administration) that the Clean Cars regulations were feasible both technically and economically, the EPA and the National Highway Traffic Safety Admin­is­tration (NHTSA) are ex­pected to issue a joint Notice of Proposed Rulemaking (NPRM) on how they plan to revise the 2021-2025 vehicle emissions standards.  The NPRM is expected to be issued sometime in June and to allow stakeholders up to 60 days to comment on factors the agencies should consider in revising the standards.

Reports by the LA Times and Reuters indicate the draft NPRM’s main recommendation is that the EPA and NHTSA freeze the federal standards at 2020 levels for the balance of the program.  This is com­pletely counter to the California Air Resource Board’s (CARB’s) determination in its March 2017 Board Hearing that the vehicle regula­tions are entirely feasible and do not require any modifications for MY 2021-2025.  It would mean that California and the 12 other states and the District of Columbia that have adopted California’s regulations can pro­ceed to require, separate from any weakened future federal standards, that automakers must still build cars that meet the stricter target of reducing their fleet-wide greenhouse-gas (GHG) emissions 34% below 2016 levels by 2025.

In response to the April 13 federal determination, California, 16 other states, and the District of Columbia filed suit in the US Court of Appeals to prevent the EPA from rolling back the standards, thereby at­tempt­ing to avoid any bifurcation of the emissions regulations and preserve a single national program.  Sepa­rately, the National Coalition for Advanced Transportation (a coalition of electric utilities, EV charg­ing companies, and Tesla) and an alliance of NGOs also filed a petition in the same court challenging the EPA’s weakening of the vehicle GHG emissions standards through MY 2025.  While these and any other court cases proceed past rulemakings for vehicle emissions, regulations launched through the release of an NPRM have typically taken 11-12 months to complete.

The Trump administra­tion has at a minimum managed to create an environment of extreme uncertainty around the regulations and what the automakers will need to do to comply if the program splinters, which in the long run is to nobody’s advantage.

Electrifying Transportation

CEERT continues to monitor the CPUC’s Alternative-Fueled Vehicles rulemaking (R.13-11-007) and the IOUs’ transportation electrification plans pursuant to SB 350, all of which have been consolidated under SDG&E’s A.17-01-020 application, as sev­eral CEERT affiliates are active parties in these proceedings.

On April 19 and 24 the CPUC took opening and reply comments on its March 30 Proposed Decision (PD), which recommended approval of four transporta­tion electrification programs and one rate design with a total budget of nearly $589 million, proposed by California’s three investor-owned utilities as their Standard Re­view Projects (SRPs), which are expected to last roughly five years,.  On May 16 the CPUC held a two-hour all-party meeting at which stakeholders could discuss their perspectives and comments on the PD.

The issues raised about the PD ranged from concerns over the extent of ownership of charging infrastruc­ture being proposed by some utilities, to the number and capacity of fast-chargers needed to support ZEV ride-sharing (especially in major urban areas), to the pressing need to further electrify ports, to the need for additional support for electrification of medium- and heavy-duty transport.  After considering this input, the CPUC revised its PD to address those concerns (e.g., reducing the amount of utility ownership of charging infrastructure, and increasing funding for port and freight transport).  The revised PD, which will be considered at the CPUC’s May 31 business meeting, is now proposing that total funding for the SRPs be increased to $738 million.

Low-Carbon Fuel Standard (LCFS)

CEERT continues to participate in advocacy efforts to improve and extend the LCFS to 2030.  On April 27 the CARB Board held the first of two hearings to consider staff proposals on the revised (Phase 2) approach to the LCFS.  These revisions reflect advances in the science and technology for production of low-carbons fuels, and aim to streamline the LCFS program (changes to the pathway carbon inten­sity ap­plication and evaluation process; improvements to reporting and credit-generation processes; the integra­tion of mandatory third-party verification require­ments; and updates to lifecycle assessment mod­el­ing tools and the fuel pathway certification process).

The revisions will include new fuel (e.g., alternative jet fuel, renewable propane) and vehicle types, and innovative actions such as carbon capture and sequestration that further reduce transportation GHGs.  As CEERT has advo­cated, the revisions will allow renewable power generated off-site to be used for EV charg­­ing and hydro­gen produc­tion by electrolysis, and will recognize the benefits of shifting EV charging and electrolyzer loads to times when excess renewable electricity might otherwise be cur­tailed, and there­fore wasted.

These amendments are a first step in promoting further expansion of ZEV infra­structure through the LCFS as directed by the Governor’s executive order B-48-18, which mandates the deploy­ment of 250,000 chargers and 200 hydrogen fueling stations by 2025 in sup­port of de­ploying 5 million ZEVs by 2030.  It would help make these vehicles fully zero-emission on a lifecycle basis.

Under the LCFS the average carbon intensity (CI) of all transportation fuels used in the state during 2017 was 3.5% below the 2010 baseline.  Phase 1 of the original LCFS regulation adopted in 2009 set a CI reduction target of 10% below 2010 levels by 2020, and the Phase 2 revisions proposed by CARB staff would extend this target to 20% below 2010 levels by 2030.  CEERT supported CARB increasing this target to 22-23% below 2010 levels by 2030.

The CARB Board accepted the bulk of staff’s revisions for Phase 2 of the program, and made two addi­tions, asking staff to work with stakeholders to: 1) develop a method for hydrogen stations and direct-current fast chargers for electric vehicles to earn credits on the basis of the capacity of the ZEV infra­struc­ture; and 2) explore ways to increase the magnitude of ZEV rebates funded by sale of LCFS credits, espe­cially at the point of sale.

Staff hope to complete the overall Phase 2 revision and secure Board approval in time for the program to take effect on January 1, 2019.  To achieve this, staff will need to report during the summer how it will respond to stakeholder concerns and make the addi­tional changes requested by the Board.

Alternative and Renewable Fuel and Vehicle Technology Program

On May 11 the CEC released the final Commissioner’s version of the 2018 – 2019 Investment Plan Up­date (IPU) for the Alternative and Renewable Fuel and Vehicle Tech­nol­ogy Program.  The IPU was revised in response to the Governor’s January 26 Executive Order, which in­cluded immediate additional funding for the CEC’s ARFVTP program to support achieving the targets of placing 5 million ZEVs on California’s roads by 2030, along with 200 hydrogen fueling stations and 250,000 elec­­tric vehicle charging stations by 2025.  This raised the total funding available for the 2018-2019 In­vest­ment Plan from $97.2 million to $277.5 million.

The IPU proposes funding of $134.5 million for EV charging infrastructure and $92 million for hydrogen fueling infrastructure (both raised from previous historic levels of $20 million).  At the March 25 meet­ing, CEERT and other members of the ARFVTP Advisory Committee unanimously approved these new fund­ing levels.  The CEC will consider the final IPU during either its June or July business meetings.