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On the Heels of Rollback, Auto Makers Seek Another Hand Out

, senior vehicles analyst | May 13, 2020, 10:03 am EDT
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While the administration just finalized its reduction in vehicle efficiency from 5 percent per year to no better than a measly 1.5 percent per year (despite their own evidence showing how bad it is for the country), that hasn’t stopped the auto industry from seeking even further reductions. In a new proposed change to how passenger cars and trucks are tested, the Trump administration is trying to give automakers a carve-out that would further increase global warming emissions from new cars by 1.6 percent.

Admittedly, this change is a little wonky so let me lay it out as best as I can. But the bottom line is that automakers are seeking even further, permanent reductions in the stringency of global warming emissions standards, right on the heels of a massive rollback of emissions standards.

Vehicles aren’t tested on regular ol’ gasoline

In the lab tests required for determining tailpipe emissions and fuel economy, most vehicles are certified using indolene. Unlike the fuel available at your gas station, indolene contains no additives and is one of the purest, clean-burning formulations of gasoline out there. It also has never been widely available for consumer purchase and hasn’t been a good representation of commercially available fuel for decades.

Back in 2014, the EPA finalized it’s “Tier 3” motor vehicle standards, which reduced evaporative and tailpipe emissions from automobiles and reduced sulfur and other pollutants in gasoline in order to improve air quality. As part of this rule, they also promised to phase in a rule that would require “Tier 3” gasoline be used for certification of automobiles—emissions of cars and trucks would now be measured using the same fuel available to consumers.

Automakers trying to game the new rules

After an extensive testing program, EPA is finally getting around to finalize the switch to Tier 3 gasoline as required. But it turns out that the fuel switch changes the emissions and fuel use of the vehicles, so now EPA must correct for the fuel switch. Automakers are seizing this formula correction as an opportunity to permanently erode global warming emissions standards.

It turns out that if the same vehicle is tested using Tier 2 and Tier 3 fuel, on average the certification results will show 1.6 percent fewer global warming emissions from the test on Tier 3 fuel. This means that, without adjustment, every new vehicle would appear to be 1.6 percent better just by switching how the test is conducted. That’s like comparing 100-yd dash times when one runner only had to run 98.4 yards! That’s hardly fair.

Unprecedented giveaway

EPA is appropriately proposing to correct its global warming emissions test to account for this change in fuel, just as they are required to do for the CAFE fuel economy test. However, automakers have asked the administration not to make the correction—and EPA is requesting comment on this proposal.

On the one hand, you almost have to be impressed with the chutzpah of the auto industry in such a brazen request—even children understand that you can’t change the rules after the fact. And to make this request after the administration has already nearly eliminated fuel economy and emissions requirements from 2020-2026? WOW.

On the other hand, what makes this ask particularly pernicious is not just that there is no legitimate reason for this ask (there isn’t)—it’s that the auto companies are trying to establish this precedent to permanently weaken EPA’s global warming emissions program and test procedures, regardless of the levels set under future standards.

This request goes against science and common sense

Importantly, EPA’s proposal does not adopt this ridiculous automaker request—their technical support documentation makes quite clear that the appropriate change is to make the correction. However, by requesting comment on this, EPA opens the door to finalizing this absurd ask.

With a 90-day comment period, we will be working over the next three months to push back as loudly as possible against the automakers for supporting this 1.6 percent weakening and the EPA for even considering granting a proposal that goes so clearly against scientific evidence and good governance.

The administration has already done enough damage to the environment by increasing automotive emissions—we don’t need them listening to automakers to do even MORE harm.

Eilis Garvey/Unsplash

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  • Steve_VG

    Mr. Cook,

    You clearly don’t understand what this 1.66% multiplier by EPA represents. In EPA’s testing, E10 tested roughly 1.7% less carbon per mile and now we have EPA taking that away because some how they feel they not only have to regulated volumetric efficiency based on this mystery 1975 fuel, but also the carbon per mile of this 1975 fuel. This 1.66% penalty is just another example that EPA hates ethanol. They rather push for EV’s in the future and ignore cleaner fuels for today’s vehicles.

    You need to either research this subject better or talk to someone who knows this issue because it is complicated. Heck, the two drive cycles EPA uses are not even real world. You can say CAFE mpg of 54 but in real world, that is the low 40’s.

    • David Cooke

      The stringency of the greenhouse gas and fuel economy standards for which these test procedures are used are based on the use of Tier 2 cert. fuel (indolene). There are two choices faced by the agency to reflect the use of a fuel different than that on which the standards are based–they (and NHTSA) could adjust the stringency of the regulations to reflect this shift, or they can adjust the test result. Since EPA is required to adjust the CAFE fuel economy certification to reflect the fuel used, they are proposing appropriately to adjust the greenhouse gas test result as well.

      The automakers, however, have requested EPA ignore that adjustment, which would grant them a free 1.66% reduction in emissions towards meeting the GHG standards, without any change to the vehicles or their real-world emissions. This obviously would reduce the stringency of the rule by that factor.

      This is all spelled out in the proposed rule quite clearly. If you’d like further education, feel free to continue following my blog!

      • Steve_VG

        I know this study by EPA very well and if you want to see a presentation by EPA showing how Tier 3 E10 had less CO2 per mile than Tier 2 E0, please email me at [email protected] and I will be happy to share with you.

        If you read the rule, you will also find the issue of this R-factor. EPA uses Tier 2 E0 as a comparison but with an R-factor of 0.6 that dates back to this 1975 reference fuel. So technically, this all goes back to this 1975 fuel, not Tier 2 E0. EPA’s testing shows E10 was 1.66% less carbon per mile (weighted) than E0. This 1.66% multiplier is to erase the carbon value of E10 so that EPA can say they are maintaining the stringency of this 1975 fuel.

        Isn’t the goal to promote lower carbon fuels? Fuels through either efficiency or less carbon per Btu? Then why is EPA applying this. The core problem here is that no one pays attention to the test fuels. Here is a link to my latest study. Time to tell EPA to deal in the real world.

        https://www.ncbi.nlm.nih.gov/pubmed/32315258

      • David Cooke

        The point is not that switching fuels results in lower CO2 per mile – it does. The point is that the standards were set predicated on the ability for manufacturers to meet them with Tier 2 cert fuel. EPA spells this out in their proposal. Not adjusting the rule simply results in a net increase in CO2 for everyone, because whether or not the administration makes this adjustment, there will be literally ZERO impact on the fuel available to consumers, but now you’ve reduced the stringency of the standards which manufacturers will meet by 1.66%.

        As for promoting lower carbon fuels — that’s what the RFS is for. Not making this adjustment has zero impact on lower carbon fuel development and instead would harm consumers and the environment. Not sure why anyone outside the car companies would want to die on that hill.

      • Steve_VG

        The GHG calculation is not and should not hinge on the baseline of Tier 2 E0. EPA doesn’t do this with CNG or electric so why penalize ethanol. Just because E10 in this one EPA study tested to have both lower carbon per Btu and slightly better mpg per Btu, why add an additional 1.66% CO2 to the results of just Tier 3 E10. Why did EPA remove the Acura that has less favorable results. EPA says that removing the Acura was due to this vehicle being sensitive to octane but neither the FPT or Highway drive cycle test octane.

        There are two calculations in this proposed rule being the R-factor for the CAFE calculation and this 1.66% multiplier for the GHG calculation. EPA has less the R-factor at .81 because the Tier 3 E10 tested to be more efficient per Btu than both the Tier 2 E0 and the baseline 1975 E0 that EPA wants to refer to.

        Why are we calling this GHG calculation a GHG calculation if EPA wants to erase the GHG benefit of Tier 3 E10. You bringing up the RFS has nothing to do with this. You need to learn the game EPA is play here with test fuels. More than happy to go through the presentation I gave on this just a few weeks ago if you want to understand what is going on.