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 continues to work with other NGOs to defend the 2021 – 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).

On August 24 the US-EPA and the National Highway Traffic Safety Administration (NHTSA) issued a joint Notice of Proposed Rulemaking (NPRM) for the Safer and Affordable Fuel Efficient Vehicles Rule — a proposed plan to revise the 2021-2025 vehicle emissions standards. The agencies recommended freezing the emissions targets at 2020 levels, and withdrawing California’s waiver under the federal Clean Air Act (CAA), thereby revoking the state’s authority both to regulate GHG emissions from vehicles and require that automobile manufacturers deliver ZEVs to California. In late September the agencies held hearings on the NPRM in Fresno, Dearborn, and Pittsburgh.

CEERT’s John Shears testified at the Fresno hearing, and reminded the agencies that the extensive technical and economic analyses on the regulatory program showed that auto manufacturers can meet the model year 2025 National Clean Car standards cost-effectively, largely with advanced gasoline engines and transmissions, while producing safe cars, and with minimal reliance on ZEVS. The manufacturers have been innovating and deploying fuel-efficient technologies more rapidly than predicted in the 2012 Technical Assessment, while seeing sales and profits grow by roughly 5% per year since 2010. (Indeed, some of the vehicles they have delivered already meet the 2025 standards.)

CEERT pointed out that the August 24 proposal risks making it impossible for California to meet its 2025 and 2038 goals for achieving the National Ambient Air Quality Standards, thereby putting the state in violation of the CAA. It would also remove an essential tool for many other states to clean up regions with poor and dangerous air quality, thereby increasing morbidity, mortality, medical costs, lost productivity, and wildfire risks. CEERT urged the US-EPA and NHTSA to abandon the NPRM proposals and allow implementation of the 2025 standards to proceed as originally agreed to in 2012. (We submitted similar written comments to the US-EPA). A wide diversity of stakeholders at the Fresno hearing overwhelmingly spoke in opposition to the proposals and in support of the 2012 agreement.

The NPRM justified abandoning the national emissions standards by claiming its new analysis indicated that gains in fuel economy would be too expensive, that continuing improvements would suffer from diminishing returns, and that freezing the standards at 2020 levels would prevent thousands of fatal accidents compared with the 2025 emissions standards. Studies conducted by consultants for CARB and the journal Science refuted the joint-agency analysis, with one study noting that the US-EPA/NHTSA analysis contained many inconsistencies and was fundamentally flawed, misleading, at odds with basic economic theory and empirical studies, and did not improve estimates of costs and benefits of fuel economy standards beyond those in the joint-agencies’ prior 2016 analysis.

The comment period on the NPRM closed October 26. Stakeholders now await the determination of the US-EPA and NHTSA, based on their evaluation of oral testimony and written comments and any updates to the technical and economic analysis, about which course of action they will take. Proceeding with the actions outlined in the NPRM would increase the nation’s oil consumption by hundreds of thousands of barrels per day and its climate emissions by millions of tons per day.

Low-Carbon Fuel Standard (LCFS)

On September 28 the CARB Board adopted regulations for Phase 2 of the LCFS that extended the program to 2030 and doubled the carbon intensity reduction target from 10% to 20%. CEERT broadly supported the Board adopting the new regulations (with appropriate cautions).

The program was amended to restructure the various utility vehicle rebate programs into a single uniform pool, to allow enhanced incentives for zero-emission vehicles and fuels by enabling utilities to collect LCFS credits for EV charging, and to encourage new infrastructure by authorizing credits based on the expected capacity of fast-charging and hydrogen-refueling stations. The program now allows carbon capture and sequestration (CCS) to be used to reduce the carbon intensity of fuels by requiring that qualifying projects use the most stringent CCS protocol in the country. The program expanded to include aviation fuel, and implemented a program for third-party verifiers to evaluate fuels’ carbon-intensity reductions.

Alternative and Renewable Fuel and Vehicle Technology Program

The Staff Draft of the 2019-2020 Investment Plan Update for the Alternative and Renewable Fuel and Vehicle Technology Program was released on November 2, and discussed at a November 8 ARFVTP Advisory Committee meeting. From a total budget of $100 million, the IP Update proposes investing nearly $53 million for ZEV infrastructure ($32.7 million for EV charging and $20 million for hydrogen fueling stations). Additional funds can be applied toward zero-emissions vehicles and fuels through funding for Advanced Freight and Fleet Technologies ($17.5 million) and Alternative Fuel Production and Supply ($20 million). With the increasing focus on ZEV implementation, many Advisory Committee members cautioned against ignoring other fuels such as those incentivized under the LCFS. This program’s funding has contributed to the success of some biofuels that have been critical to the LCFS.