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.