California Leading the Way on Emissions ... Again: This Time its Greenhouse Gases

[Another one via Green Car Congress. Its as if I don't read anything else...]

California Limits on Auto CO2 Emissions Tackle Altfuel, Hydrogen and Plug-ins Too
13 October 2005

California’s new regulations limiting greenhouse gas emissions from new vehicles cleared the final hurdles with the state Office of Administrative Law (OAL) in September. The new rules package becomes operative 15 October 2005, and becomes effective 1 January 2006.

Positioned by opponents as an indirect fuel economy regulation (based on the correct premise that if you burn less fuel, you emit less CO2) the rules have a more complex set of measurement criteria that, as asides, open up the possibility for fuel-inefficient E85 vehicles and make it difficult for hydrogen-powered cars to conform to the regulations.

The new rules limit the amount of carbon dioxide, methane, nitrous oxide, and hydrofluorocarbons (typically used as refrigerants in air conditioning systems) that new vehicles can emit per mile beginning with model year 2009.

The limits tighten each year after that, and by 2016, greenhouse gas emissions from lighter vehicles will be cut by one-third, while greenhouse gas emissions from heavier vehicles will be cut by about one-quarter.

Manufacturers earn debits for falling short of the requirements, and have up to 5 years to earn enough credits to erase the debit, after which they will be subject to civil penalties.

The auto industry responded by challenging the regulations in federal court, a suit which has yet to be resolved. Despite the industry protests, however, the CO2-reduction targets set by the California rules are still more lenient than the voluntary target automakers set for themselves for Europe, and more lenient still than the EU’s overall target.

[See Green Car Congress Article for table of GHG emissions requirements that goes here... damn blogspot for their lack of table support...]

The EU has set an ultimate goal of 120g CO2/km by 2010 at the latest for new cars. The European, Japanese and Korean car manufacturers’ associations committed to an interim goal of reducing CO2 emissions to 140 g/km by 2008/2009. (Earlier post [on Green Car].)

The California rules, however, specify 201 g/km in 2009 for passenger cars, reach 141 g/km in 2013—four to five years after the comparable voluntary target in Europe—and drop only to 127 g/km in 2016.

The basic California-rule calculation for greenhouse gas (GHG) emissions factors in CO2, CH4 and N2O plus direct and indirect air conditioning emissions allowances if the manufacturer uses a low-leak system, refrigerants such as HFC-134a and so on.

For alternative fuel vehicles, the state rules apply an upstream adjustment factor: a multiplier reflecting greater or lesser upstream greenhouse gas intensity. For natural gas, the adjustment factor is 1.03; for LPG, 0.89; for E85, 0.74.

In other words, the manufacturer of an E85 (note, not flex-fuel) vehicle gets to multiply the total CO2 emissions plus the air conditioning indirect emissions by 0.74.

This could have a significant impact on meeting the new criteria. As a quick example, let’s take a 2006 Flex-Fuel Chevrolet Avalanche, which delivers 12 mpg US combined on an E85 blend.

EPA figures project annual GHG emissions of 7.9 metric tons on 24,135 kilometers driven. That works out to 327.3 g/km of GHG. Apply the 0.74 fuel adjustment factor, and that number plummets to 242 g/km—the California target, as it happens, for a vehicle of this size for 2011.

This is a quick-and-dirty exercise that won’t match exactly the calculations California is requiring. But the power of the adjustment factor could be enormous in helping automakers meet the target. (Just as the flex fuel rule in federal CAFE helped them meet overall fleet economy targets and spurred the production of millions of low fuel-economy E85 vehicles that rarely use E85.)

Under the California regulations, flex-fuel vehicles, along with bi-fuel, dual-fuel and grid-connected hybrids (plug-ins) are evaluated based on tests when operating on gasoline. Manufacturers of plug-in hybrids have a special adjustment factor that can increase based on the capabilities of their battery systems.

For Zero Emissions Vehicles—i.e., hydrogen fuel cell, hydrogen combustion engine and all-electric vehicles (EV)—California has another set of upstream adjustments.

The ZEV upstream emissions factors are:

Electric ZEV: 130 g/mile

Hydrogen ICE: 290 g/mile

Hydrogen ZEV (fuel cell): 210 g/mile

In other words, hydrogen cars are already defined as not meeting the long-term (2016) criteria, absent emissions allowances for A/C that could bring them back down. (For light duty trucks, however, it is a different story.)

The hydrogen penalty derives from the CO2 associated with hydrogen production. There is a loophole that allows approval of a lower upstream emissions factor if the manufacturer demonstrates the percentage of hydrogen fuel (or electricity) produced by renewable energy resources.

EVs, however, are good to go.

Resources:

Final Regulation Order


Once again, California seems to be the only state willing to push forward with reduction of emissions, in this case, green house gas emissions (GHGs). I think this is a very laudible effort and will likely have a substantial effect on manufacturers, particularly US manufacturers (who incidentally have already taken CA to court over this law!); there are a lot of cars sold in CA. (European and Asian manufacturers have already had to deal with similar standards from Kyoto signatories and the EU)

However, as some of the comments over at Green Car Congress pointed out, there is no adjustment for ZEVs to take into account the relative efficiency of the vehicles and this is a shame. Upstream GHG emissions are factored in based simply on the number of miles driven. This provides no incentive to develop a more efficient fuel cell/battery/engine/car etc. An upstream factor based on kilograms or liters of hydrogen consumed (for a hydrogen fuel cell of ICE vehicle) or kilowatt-hours of electricity (for an EV) would make much more sense.

I'd be curious to see just how they calculated each of those adjustment factors for each alternative fuel also. It seems to me, especially considering some of the worst-case outlooks like those by Pimentel et. al., that a factor of .74 for E85 is a bit much. I've seen more like a 15% decrease in GHGs for E100 (over gasoline) so I'm a bit skeptical as to E85 giving a 24% reduction.

I am also curious how CA plans to take into account any changes in production for any of these fuels. Ethanol and hydrogen in particular can be produced in a number of different ways and each has different associated upstream GHG levels.

Finally, when compared to European Union targets, CA's targets are relatively lax. Its great to see them doing something, but (probaby as always) they could have done more.

In the end, this seems to be a laudible effort by CA and its great to see some forward-looking legislation with regards to GHG emissions from transportation. I hope that this ends up being a positive step in the right direction and that oversimplifications in their GHG accounting methods, unintentional or not (I'm sure the ethanol and oil lobbies had their grubby paws in this one), dont end up hamstringing the development of cleaner/more efficient alternative transport options.