EPA (Correctly) Affirms Vehicle Standards, Despite Automaker Misinformation

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By Dave Cooke, Union of Concerned Scientists

EPA finalized its determination today that the current light-duty vehicle global warming emissions standards for 2022-2025 are appropriate. This adjudication affirms what we have said all along—manufacturers are currently ahead of schedule on the first round of standards (2012-2016) and continue to show the many pathways to cost-effectively meeting future standards.

This is a big affirmation for both consumers and the country as a whole:

To date, our analysis shows that the standards have saved consumers more than $34 billion in fuel. By 2030, this number will grow to $450 billion, even after taking into account costs for the technology used to drive those fuel economy improvements.

At the same time, we’ve avoided over 130 million metric tons of global warming emissions. The standards are working for consumers and the environment—there’s no reason to tap the brakes on that progress.

And for all their whining about wanting to weaken the standards, the automakers themselves have provided data that shows exactly why we shouldn’t.

Automaker data shows 2012-2016 compliance was easier, cheaper than expected

As I wrote about when the proposal was released, this decision is more than four years in the making and is backed up by a tremendous amount of benchmarking, modeling, and analysis. The large body of evidence gathered continues to point to new and innovative pathways that would allow manufacturers to not just meet but exceed the standards on the books—and each new data point confirms that fact.

In fact, the automakers themselves submitted data showing just how little technology they are actually applying to their vehicles in order to meet today’s standards, with much lower penetrations of complex/expensive technologies than originally anticipated.

The 2012-2016 Final Rule (FR) on which automakers initially signed off envisioned a much higher penetration of more costly technologies would be needed (dashed red lines). However, manufacturers have shown innovative new ways to improve upon cheaper technologies as they overachieve on those standards, leaving plenty of cost-effective technologies available for deployment out to 2025 (orange bars). (Source: Comments by the Alliance for Automobile Manufacturers)

The 2012-2016 Final Rule (FR) on which automakers initially signed off envisioned a much higher penetration of more costly technologies would be needed (dashed red lines). However, manufacturers have shown innovative new ways to improve upon cheaper technologies as they overachieve on those standards (orange bars), leaving plenty of cost-effective technologies available for deployment out to 2025. (Source: Comments by the Alliance for Automobile Manufacturers, Attachment 2, pp. 40-43)

Outpacing expectations, they have been able to continue to exceed the standards with even lower cost technologies thanks to investments resulting from the need to meet strong standards. This innovation has generated numerous new technology pathways such as high-compression engines like Mazda’s SkyActiv and 48V mild hybridization—though those technologies are not yet deployed at large scale. This leaves ample room to continue reducing emissions beyond the current 2025 standards with gasoline-powered engines.

As a colleague of mine likes to say, “While automakers continue to pull the lowest hanging fruit, innovation means that the tree is constantly growing new low-hanging fruit.” This is why historically industry has continued to overstate the costs of regulation.

Automaker data shows that 2025 standards can be met through gasoline-powered vehicles

Additionally, while the auto companies claim on one hand that more electrification and other pricier technologies will be needed to comply in the future, their own analysis shows that they can comply through the broad deployment of advanced gasoline-powered vehicles.

Analysis submitted by the automakers shows that vehicles in 2025 can meet the standards through the deployment of turbocharged (TC), spark-ignited (SI) gasoline engines, complemented by advanced transmissions (HRST) and stop-start (SS). Source: Comments by the Alliance of Automobile Manufacturers

Analysis submitted by the automakers shows that vehicles in 2025 can meet the standards through the deployment of turbocharged (TC), spark-ignited (SI) gasoline engines, complemented by advanced transmissions (HRST) and stop-start (SS). Note the very low penetrations of electrification required. Source: Comments by the Alliance of Automobile Manufacturers, Attachment 1, p. 74)

These gasoline-powered vehicles will be substantially more efficient than today, incorporating advancements such as 48V mild hybridization, which allows for efficient electric boosting of smaller engines and improved efficiency of accessories; high-compression engines running on thermodynamic cycles that are more efficient; dynamic cylinder deactivation that can downsize the engine in real-time to provide the right amount of power at the right time; more efficient transmissions that keep the engine operating at its most efficient point more frequently; and reductions in road load such as improved aerodynamics and low-rolling resistance tires to help reduce the amount of energy needed to drive the vehicle in the first place.

Investments in those technologies are buoyed by the certainty of the strong standards which EPA today affirmed, as noted by automakers: “By extending the standards for many years into the future, the agencies provide manufacturers with substantial lead-time, which is of great value in compliance planning.”

Meeting 2025 standards is no problem for automakers, which is why EPA held firm

All of this is to state the obvious: the automakers themselves show that the 2025 standards are achievable, which is part of why EPA has affirmed the standards set in 2012. So in the inevitable onslaught of automaker whining that will surely follow this announcement, remember this:

  • Automakers signed on to these standards with much hullabaloo when they were finalized;
  • Automakers are currently ahead of the game, deploying efficient technologies at reduced costs compared to original estimates of compliance;
  • Automaker data submitted in the four years hence continues to show that those 2025 standards are achievable with conventional gasoline-powered vehicles (thanks to the continued investment in and deployment of fuel consumption reduction technologies); and
  • Consumers and the environment stand to benefit tremendously by leaving these cost-effective standards in place.

EPA’s decision today confirms that the data is in and crystal clear: the 2022-2025 standards put on the books in 2012 remain feasible for manufacturers and will provide significant benefits for the country and the environment.

Originally posted here.

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