Comment Log Display

While fully supporting the spirit of the proposed LEV III
Regulation, it doesn’t appear that the impacts of a significant
shift to “ZEV” technology such as electric vehicles (EV) have been
fully considered.

According to a National Academies report (National Academies,
"Hidden Costs of Energy: Unpriced Consequences of Energy Production
and Use.")...


"...Electric vehicles and grid-dependent (plug-in) hybrid vehicles
showed somewhat higher nonclimate damages than many other
technologies for both 2005 and 2030.  Operating these vehicles
produces few or no emissions, but producing the electricity to
power them currently relies heavily on fossil fuels; also, energy
used in creating the battery and electric motor adds up to 20
percent to the manufacturing part of life-cycle damages...."


This is supported by the latest version of Argonne National
Laboratory’s GREET model (GREET1_2011 - http://greet.es.anl.gov/)
which shows that WTW emissions of particulate matter (PM) in
California are higher for EV technology than current "clean diesel"
technology.  Based on the default "mid-sized" vehicle assumed in
GREET for the year 2020...


WTW PM10 (diesel) = 0.004 (Feedstock) + 0.009 (Fuel) + 0.030
(Vehicle Operation) = 0.043 g/mi
WTW PM10 (EV) =  0.060 (Feedstock) + 0.006 (Fuel) + 0.021 (Vehicle
Operations) = 0.087 g/mi

WTW PM2.5 (diesel) = 0.003 (Feedstock) + 0.005 (Fuel) + 0.016
(Vehicle Operations) = 0.024 g/mi
WTW PM2.5 (EV) = 0.015 (Feedstock) + 0.004 (Fuel) + 0.007 (Vehicle
Operations) = 0.026 g/mi

All of these values are based on the California electric generation
mix assumed in GREET in 2020.  

Exhaust PM from the diesel vehicle assumed in GREET = 0.009 g/mi
(PM10); 0.0084 g/mi (PM2.5).

Furthermore, based on certified emissions of the 2003 VW Jetta TDI
(example of an "old tech" diesel vehicle), exhaust PM emissions =
0.05 g/mi
(http://www.arb.ca.gov/msprog/onroad/cert/pcldtmdv/2003/volkswagen_pc_a0070228_1d9_1_diesel.pdf).

0.05 - 0.009 = 0.041 g/mi more exhaust PM for the "old tech" diesel
than that assumed for "clean diesel" in GREET.

0.043 g/mi + 0.041 g/mi = 0.084 g/mi WTW PM10 for the "old tech"
diesel car, actually less than the 0.087 g/mi WTW PM10 calculated
by GREET for EV in California for 2020.

"Old tech" diesel vehicles have been effectively banned for many
years under LEV II regulations, to the Air Resources Board's
credit, yet mandates are being proposed for vehicle technology
(e.g., EV) which may actually increase PM emissions from a WTW
perspective above "old tech" diesel engine technology.  EPA
acknowledges in the Draft RIA for the Proposed Rule to Extend the
National Program to Reduce Greenhouse Gases and Improve Fuel
Economy for Cars and Trucks - Docket ID No. EPA-HQ-OAR-2010-0799,
that all PM2.5 is treated as equally potent in causing premature
mortality regardless of source (page 6-35 of the Draft RIA), even
specifically mentioning PM2.5 from diesel engine sources.  So there
appears to be no valid reason from a public health perspective to
displace the reduction in PM2.5 emissions from diesel engines with
increased PM2.5 emissions from power plants to support EV/PHEV
technology.  The regulatory push for these "advanced technologies"
defies logic from an emissions perspective.

A massive shift to EV/PHEV technology would potentially offset
gains made from diesel PM emission reduction mandates.  It appears
superfluous to propose significant reductions in PM emissions from
gasoline/diesel vehicles under LEV III to trivial levels (which I
support) yet essentially mandate technology which not only doesn’t
decrease WTW PM emissions from current technology, it increases WTW
PM emissions with respect to pre-2004 (Tier 1) diesel vehicles.

I would like to state unequivocally that I support EV/PHEV
technology for certain niches (e.g., urban commuter travel), but
upstream emissions of this technology really need to be taken into
account.

As a disclaimer, I am in no way associated with the auto industry
or any support industries to the auto industry, including diesel
engine manufacturers.

Thank you for your consideration of these comments.


Respectfully submitted,

Loren Carl Marz, Certified Consulting Meteorologist (#591)