Comparing pollutants generated by EVs and gasoline-powered cars over the life cycle also leads to ambiguous results. Of course, EVs produce zero pollution but they do use electricity, and electricity production causes pollution. How does the EPA take account of this? It doesn’t. Go to page 203 of the EPA’s 728-page proposal for its new regulation and you will see this statement:
EPA is proposing to make the current treatment of PEVs [plug-in electric vehicles] and FCEVs [fuel cell electric vehicles] through MY [model year] 2026 permanent. EPA proposes to include only emissions measured directly from the vehicle in the vehicle GHG [greenhouse gases] program for MYs 2027 and later (or until EPA changes the regulations through future rulemaking) consistent with the treatment of all other vehicles. Electric vehicle operation would therefore continue to be counted as 0 g/mile, based on tailpipe emissions only.
In short, the EPA assumes something it knows to be false, namely that emissions from producing electricity to power EVs are zero. I’m tempted to call this the EPA’s “non-smoking gun.”
How could the EPA justify such an extreme assumption? On the same page, it attempts to do so, writing, “The program has now been in place for a decade, since MY 2012, with no upstream accounting and has functioned as intended, encouraging the continued development and introduction of electric vehicle technology.”
Did you catch that? The EPA justifies its explicit bias against gasoline-powered vehicles and in favor of EVs by arguing that doing so will encourage the continued development of EVs. Well, yes, just as ignoring the cost of anything will justify more of that thing. Call it the EPA’s new frontier in cost/benefit analysis. Or maybe call it the Bart Simpson justification: “I only lied because it was the easiest way to get what I wanted.”
The above is from David R. Henderson, “EV Mandates Are Taking Californians for a Ride,” Defining Ideas, May 4, 2023.
The original title I gave the piece (the editor chose a different title) is “Assume a Tesla.” You’ll see why if you read the first few paragraphs of the piece.
At the end, I give what I think are substantial grounds for hope, based in part on thoughts from a deep expert on regulation, Peter Van Doren.
Read the whole thing.
UPDATE: Charley Hooper sent me this link. The article examines the whole cycle, including production.
READER COMMENTS
Stephen
May 4 2023 at 10:25am
Thanks for consolidating the list of lifecycle costs of EVs in one place. IMHO the pollution comparisons need more analysis. Even if overall greenhouse gas levels are lower with EVs (and we buy into the argument how that will benefit “the planet”), what about the cost of spreading toxic chemicals in the environment? Remember how we had to throw out our incandescent bulbs in favor of CFLs? After the legislation was passed, we found that the mercury in CFLs required us to spend hours cleaning up if one of them broke.
“Assume a Tesla” reminds me of a Steve Martin routine from 1978:
You.. can be a millionaire.. and never pay taxes! You can be a millionaire.. and never pay taxes! You say.. “Steve.. how can I be a millionaire.. and never pay taxes?” First.. get a million dollars. Now.. you say, “Steve.. what do I say to the tax man when he comes to my door and says, ‘You.. have never paid taxes’?” Two simple words. Two simple words in the English language: “I forgot!”
Manfred
May 4 2023 at 10:43am
“Of course, EVs produce zero pollution but they do use electricity, and electricity production causes pollution.”
Yes.
Now, what about the production of EVs? I have no scientific citation, but I heard somewhere that EVs use more plastics than gasoline powered cars. Plastics are made of natural gas/methane, which is why the plastics industry is so in favor of EVs.
And then of course is the question – what happens to the batteries at the end of their lifecycle, where are they thrown away? And what about the plastics of EVs when the EV is no longer able to be driven? Do the plastics end up in a landfill? [Same question with wind turbines, by the way.]
Does the EPA take all of this into consideration? Doesn’t the EPA employ economists?
nobody.really
May 4 2023 at 12:01pm
A broader question: What if they do?
Various people have proposed costly methods to capture and sequester greenhouse gasses. I can think of a cheap one: Make more plastic! True, the stuff doesn’t biodegrade–but on the plus side, THE STUFF DOESN’T BIODEGRADE! It keeps greenhouse gasses out of the atmosphere. What’s not to like?
rob
May 4 2023 at 5:39pm
Bloomberg thinks so… https://www.bloomberg.com/news/features/2020-02-05/wind-turbine-blades-can-t-be-recycled-so-they-re-piling-up-in-landfills?leadSource=uverify%20wall
Liface
May 4 2023 at 11:42pm
Landfills are really not that big of a deal. We have tons of space on earth that’s unused. https://medium.com/@robertwiblin/what-you-think-about-landfill-and-recycling-is-probably-totally-wrong-3a6cf57049ce
steve
May 4 2023 at 11:15am
The pollution involved in extracting, refining and transporting fossil fuels is also often ignored when making comparisons, just focusing on what is generated in use. We should have all of the info if we are going to make comparisons. That said, its also useful to know each component especially if the numbers are changing. The mix of sources for electricity is changing and the cost of fracking is higher. A big cost that often gets ignored is the need to expand and modernize the grid. Probably need to do that anyway but EVs will make it more costly.
TESLA just released Plan 3 (sounds like something Boris and Natasha would do) outlining its ideas on removing fossil fuels. It posits a lot of storage, some hydrogen generation and overbuilding on renewables. It keeps nuclear at current levels. Personally, I think they should incorporate at least tripling nuclear. Illinois (SB76) and I think a few other states are looking at repealing moratoriums on nuclear plants so there is hope in that direction.
https://www.tesla.com/ns_videos/Tesla-Master-Plan-Part-3.pdf
Steve
David Henderson
May 4 2023 at 5:22pm
See the Update that I added to the original post.
nobody.really
May 4 2023 at 11:52am
I love that!
In fairness, the EPA states that it analyzes vehicles based on tailpipe emissions “consistent with the treatment of all other vehicles.” To call this statement false, I’d need evidence that the EPA analyzes other vehicles on some other basis.
Now, perhaps you mean to say the statement tends to mislead. Fair enough. Yet this reflects a standard challenge of cost-benefit analysis: Drawing the appropriate boundary around the phenomenon being studied. Maybe it takes more labor to make an EV than an vehicle with an internal combustion engine. Humans generate expense and greenhouse gases. Should we incorporate those factors into the analysis? Or should we assume that the existence of those humans—and thus, their costs and greenhouse gas emissions—would not change regardless of the amount of EVs generated?
If we wanted to consider the emissions from electric generation, we’d need to consider the time of day that vehicles charge. Typically they charge at night—when the grid gets no benefit from solar generation, but also when generators with the highest greenhouse gas emissions (“peaker plants”) operate at their lowest levels. The US Energy Information Agency has some graphs. Completing this analysis would pose a non-trivial challenge, but seems doable.
In contrast, we’d need to consider the cost of gasoline. Historically the US got its oil from the Persian Gulf. Obviously we’d need to consider the direct cost (in $ and emissions) of the imports. But arguably we would also want to consider the indirect costs. Arguably the US has lavished attention—including military invasion and occupation—to secure access to oil, so we’d want to consider all of those costs (in $ and emissions) as part of the cost of gasoline. This analysis poses REALLY non-trivial challenges.
However, today the US produces most of its own oil, and most of its imports come from Canada. (The US both imports and exports oil because different oils have different qualities.) Imports from the Persian Gulf have fallen to almost nothing. So even if past calculations of oil costs would pose great obstacles, maybe prospective analyses should ignore Person Gulf costs?
ALL THAT SAID, battery technology gallops along. Utilities have started installing iron-air batteries (harnessing the power of rust!)–and the US has a ready supply of both iron and air. If these or other technologies become sufficiently cheap and reliable, then I could expect all electricity to come from sources with the lowest long-run incremental cost—e.g., hydro, solar, and wind–because these sources would effectively become “dispatchable.” This would seem to go a long way in resolving Henderson’s concerns on this point.
In sum, I acknowledge Henderson’s gripe. But before I would condemn the EPA’s analysis, I would want to consider what analysis I’d propose in its place. I suspect any analysis would prove incomplete, relying on some arbitrary boundaries and on assumptions, especially assumptions about the pace of progress in battery technology.
steve
May 4 2023 at 1:03pm
Read page 46. They explicitly state, if I am reading this correctly, that pollutants from EGUs (electrical generating units ie power plants) are expected to increase and factor that into their calculations. It looks like page 203 is focused on how you specifically handle Fuel cell cars and plug in hybrids.
All of the numbers on every aspect of EV vs ICE are pretty easily found and EPA appears to be aware of them. That is not saying that the numbers are all agreed upon. Every engineer and physicist/chemist thinks their numbers are correct and everyone else wrong. Still, the numbers exist and they are used. However, sometimes you just look at the pieces and not the entirety of the data which looks like what was done on 203.
Also, continue reading to page 204. While they are mostly focused here on trying to figure out how to account for fuel cells, they say that there are other parts of the EPA that look at stationary sources (power plants) and for their purposes of measuring they are leaving off upstream pollutants for all cars, including ICE cars. So they are openly explaining what they are doing and why they are doing it while noting that there are separate assessments of peer plant effects.
Steve
Mark Barbieri
May 4 2023 at 4:57pm
Why do you say that the US “got its oil from the Persian Gulf”? I think that we get about 10% to 20% of the oil we use from the Persian Gulf. It was as high as about 1/3 of our oil consumption back in the 70s, especially after Nixon imposed sanctions on the US oil industry, but I don’t think it was ever a majority of our oil consumed.
Mark Barbieri
May 4 2023 at 5:02pm
I wonder if they would classify the gigantic BelAZ 75710 dump truck as a zero emission vehicle. It has two huge diesel engines, but they work as a powerplant to generate electricity. The motors that power the truck are electric.
Maybe they wouldn’t count it because the generating engines are part of the dump truck. Maybe they could redesign it to tow the engines instead.
Jose Pablo
May 5 2023 at 7:56am
Maybe the EPA do this because measuring emission from a tailpipe is one of the few things we know how to do. Unlikely CO2 emissions “as a whole”
https://e360.yale.edu/features/paris-conundrum-how-to-know-how-much-carbon-is-being-emitted
David Henderson
May 5 2023 at 10:43am
Ah. Akin to “look for your keys under the lamppost because that’s where the light is.”
Jose Pablo
May 5 2023 at 12:12pm
Rigth!
Thomas L Hutcheson
May 5 2023 at 11:13am
Perhaps this is a sort of approximation of encouraging decisions that would be make IF we had an optimal Pigou tax on the emissions of CO2 and removal of regulatoryu barriers to nuclear, wind solar geothermal generation. 🙂
CM Spurgeon
May 5 2023 at 11:56am
The link is gone. But their is a new one. Not sure if anything has changed.
https://www.govinfo.gov/content/pkg/FR-2023-05-05/pdf/2023-07974.pdf
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