EPA’s 2017-2025 Light Duty Vehicle Rule Discourages Alternative Fuel Use
by Jim Lane (Biofuels Digest/BIO) …While there are a number of obstacles impeding further growth in alternative energy, few are as critical as the joint EPA/NHTSA proposed rules establishing light-duty vehicle GHG and fuel economy standards. The proposed rule eliminates a statutory incentive designed to increase alternative fuel usage, reduce dependence on foreign oil, and strengthen U.S. energy security. This contradiction affects a wide range of alternatives, including biofuels and natural gas, and puts the rule in direct conflict with national priorities such as the Renewable Fuel Standard (RFS) and the Energy Independence and Security Act (EISA). If left uncorrected, the proposed rule will threaten already struggling rural economies, depress overall land prices, and harm public health and the environment.
…Consumers cannot purchase alternative fuels if reasonably-priced AFVs are not offered in the marketplace.
Therefore, incentives must be provided to auto manufacturers—the decisionmakers who control new engine technology—if the nation is to move in the direction of clean alternatives to oil. In direct contradiction to national priorities expressed in the RFS and EISA, the proposed EPA/NHTSA rule actually disincentivizes the production of AFVs…
The crux of the problem is that the proposed rule prescribes fundamentally incompatible CO2 and fuel economy regimes. Carbon dioxide emissions and fuel economy are direct corollaries—the difference is entirely semantic. For every gallon of gasoline combusted in an engine, a fixed amount of CO2 is emitted. As a result, the only way to reduce vehicle CO2 emissions is to get more miles out of each gallon of gasoline. The proposed rule therefore prescribes the same standard in two ways: a CO2 emissions limit (expressed in grams/mile) and a fuel economy minimum (expressed in miles/gallon). Yet while the 0.15 multiplier mandated by EISA is included in the fuel economy calculation, it is omitted from the directly related CO2 calculation.
This omission entirely eliminates any benefit associated with the multiplier for alternative fuels, and as such, the proposed rule benefits and entrenches petroleum.
… The loss of this credit ensures that vehicle manufacturers have no real world incentive to manufacture AFVs.
…In order to remedy this contradiction, the final rule should include a 0.15 multiplier for GHG calculations from AFVs that functions in parallel to the 0.15 divisor for mpg calculations, in order to preserve the incentive mandated under EISA. READ MORE