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 2022 – 2025 federal 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).

The US-EPA and the National Highway Traffic Safety Administration (NHTSA) have yet to issue a determination on the renamed Safer and Affordable Fuel Efficient (SAFE) Vehicles Rule.  In their August 24 joint Notice of Proposed Rulemaking (NPRM) for the SAFE Vehicles Rule, EPA and NHTSA recommended freezing the emissions targets for passenger vehicles 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.

While CARB officials met with representatives from US-EPA, NHTSA and the White House through the fall to see if a compromise could be crafted, the White House withdrew the federal government from all discussions in February.  In early April CARB sued US-EPA and NHTSA because the agencies, in responding to a September 2018 Freedom of Information Act request, did not reveal all the data and research they used to justify their attempt to roll back the emissions and fuel-economy standards for 2020-2025.  CARB is hoping the courts will compel the agencies to share the rest of that information.

EPA and NHTSA have indicated they will be revising their proposal.  But if, on balance, the revisions remain close to the proposals in the August 24 NPRM, U.S. oil consumption would increase by hundreds of thousands of barrels per day and climate emissions by millions of tons per day.  Anything close to the August 24 NPRM proposals risks making it impossible for California to meet its 2025 and 2038 goals for achieving 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 air quality, increasing morbidity, mortality, medical costs, lost productivity, and wildfire risks.

CEERT’s position is that the EPA and NHTSA should abandon the proposals in the August 24 NPRM and allow implementation of the emissions standards for 2020-2025 to proceed as agreed to in 2012.

Electrifying Transportation

In December, the CPUC issued an Order Instituting Rulemaking (OIR) for R.18-12-006, its Development of Rates and Infrastructure for Vehicle Electrification (DRIVE) proceeding, to take a more systematic approach on critical issues beyond infrastructure investments, which were the focus of several one-off utility applications under R.13-11-007.  CEERT is monitoring R.18-12-006, as several of our affiliates are active parties in this proceeding.

The CPUC is examining appropriate rate structures that can enable better management of additional electric load due to ZEV charging, and realize added value from such improved management.  By developing a comprehensive Transportation Electrification Framework (TEF), the CPUC is hoping to:

  • Align internal CPUC planning processes and better coordinate with processes at other agencies
  • Identify where IOU investments can complement existing state efforts, e.g., CARB’s new Clean Miles Standard and Incentive Program
  • Collaborate on data collection, reporting, and program evaluation efforts across agencies to support the CEC’s developing Electric Vehicle Charging Infrastructure Assessment pursuant to AB 2127

The CPUC took opening and reply comments on the OIR In February and held a PHC on March 1, at which the rulemaking was determined to be quasi-legislative.  A scoping memo was issued on May 9.  The Commission also hosted a workshop on metrics and methodologies for evaluating transportation electrification programs, with goals to:

  • Finalize key questions on the IOUs’ initial SB 350 Transportation Electrification (TE) investments
  • Review and improve the effectiveness of current data collection efforts
  • Identify evaluation metrics and methodologies that can determine the most “successful” IOU TE programs ($/GHG reduction, $/incremental EV adoption, $/kWh load shift, etc.)
  • Identify data and reporting gaps and the strategies needed to fill them

In July the CPUC will host a Vehicle-to-Grid Integration (VGI) workgroup to draft a VGI Roadmap that updates the CAISO and CPUC 2014 Roadmap and builds off the lessons of the 2017 VGI Communication Protocols Working Group.  The VGI-WG will explore streamlining EVSE connections to the IOU and identify business cases and value of VGI for IOUs, automakers, EVSE providers, and EV drivers.

The OIR requires IOUs to submit a joint rate-design proposal that addresses demand charge issues and accommodates electrification of transit fleets.  The CPUC will extend its previous work on sub-metering for EVs, evaluate its applicability to distributed energy resources, and hold workshops on sub-metering and other subjects prior to an October release of a Draft TEF proposal, with the goal of finalizing the TEF during the first quarter of 2020.

Low-Carbon Fuel Standard (LCFS)

As previously reported, in September 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 new regulations (with appropriate cautions).

The program had full compliance in 2017 and 2018.  It is helping to expand a clean alternative fuels market, and since inception has helped displace the equivalent of nearly 3.3 billion gallons of diesel fuel while avoiding nearly 47.1 million metric tons of GHG emissions.  Of the 317 companies now reporting under the program, 52 generated deficits requiring them to purchase credits from suppliers of cleaner fuels.  The LCFS’s continued success and stability has encouraged other jurisdictions to adopt (e.g., British Columbia and Oregon) or consider adopting (Washington, Canada, and Brazil) similar programs.

Alternative and Renewable Fuel and Vehicle Technology Program

The Revised Staff Draft of the 2019-2020 Investment Plan Update for the Alternative and Renewable Fuel and Vehicle Technology Program was released on January 18 and discussed at a February 6 ARFVTP Advisory Committee meeting.

The proposed budget contains nearly $53 million for investment in ZEV infrastructure ($32.7 million for EV charging and $20 million for hydrogen fueling stations) and additional money for zero-emission vehicles and fuels through funding for Advanced Freight and Fleet Technologies ($17.5 million) and Alternative Fuel Production and Supply ($20 million).  The final version of the Investment Plan Update released on March 27 maintains these funding levels, but is subject to Commissioners’ approval at their June or July business meeting.  More of the ARFVTP budget is being directed toward ZEV technologies to support former Governor Brown’s goal of 5 million ZEVs being on the road by 2030.