Minority Report: California's ZEV White Paper

By Bill Moore

Posted: 22 Jan 2010

The staff of California's Air Resources Board asked for an independent scientific review of its White Paper entitled, Summary of Staff’s Preliminary Assessment of the Need for Revisions to the Zero Emission Vehicle Regulation, along with a trio of supplemental attachments [listed here]. They invited four subject matter experts to offer their perspectives: those experts included Dr. Menahem Anderman, Dr. David Green, Dr. Joan Ogden and Dr. Giorgio Rizzoni, whom I had the pleasure to meeting last week in Columbus, Ohio.

The catalyst for ARB's review is to review the current status of the state's long-debated Zero Emission Vehicle regulation, which was first promulgated in 1991 and almost immediately came under severe scrutiny and attack. As a result, the regulation evolved over time to incorporate a host of vehicle technologies from PZEVs to ZEVs: partial zero emission vehicles to zero emission vehicles, the latter originally envisioned as battery electric cars, but subsequently modified to include fuel cell vehicles.

With the evolution of both technology and the definition of what constitutes harmful air emissions, which now includes carbon dioxide and related green house gases associated with global climate change, ARB decided in 2009 that its current ZEV policy needed updating and, if necessary, revision; hence the aforementioned White Paper.

Since the introduction of the ZEV mandate, which sought to reduce levels of ozone-forming gases that create harmful smog, the ban of most California communities, both the technology and policy landscape have changed. No longer is smog the primary driving factor. Now oil dependency and climate change have been legislated into the mix and both are now manifest in the State's legal responsibility to reduce its CO2 emissions by 80% by 2050, with much of the burden being placed on the transportation sector, which ARB's staff envisions being completely zero emission by 2050 with a vehicle fleet that is entirely powered by either batteries or fuel cells as depicted in the 2054 Lexus featured in the 2002 Tom Cruise scifi flick, Minority Report, pictured above.

Reproduced below are some of the comments from two of ARB's expert reviewers: Menahem Anderman and Giorgi Rizzoni. The other two reviewers' reports were a bit more clinical, but certainly worth looking at. While each of the four found both areas to praise and criticize, I found two serious flaws in both the White Paper and subsequent reviews that I think need equal attention, which you'll find below Anderman's and Rizzoni's testimony.

Menahem Anderman:

At fuel pricing below $4 per gallon in the US, the total cost of owning and operating advanced vehicles will clearly exceed that of conventional vehicles. With gasoline at about $4-5 per gallon, hybrid-electric vehicles become cost competitive. PHEV vehicles will only become cost-competitive when the price of gasoline exceeds $7 per gallon – even if we assume batteries with an 8-year life (which is far from being proven) and battery pricing below $500/kWh (late in the decade). Electric Vehicles will reach that point at similar or even higher gasoline price levels, depending on battery size (and thus vehicle range). These numbers include the assumption that Li-Ion PHEV and EV batteries will prove safe, reliable, and durable, and that price reduction efforts are successful. We do not have good estimates for FC vehicles but their economics in the next 20 years are likely to be even more problematic than that of PHEVs and EVs with a100-mile range.

We maintain that it is very unlikely that either FC vehicles or battery electric vehicles could be competitive in the mass market before 2020, or probably even 2025. To reduce CO2 emissions from vehicles, starting in 2015, it is clear that CARB will have to promulgate and enforce some severe restrictions, and increase them annually to meet the desired goal.


1. CARB to increase the requirements for new-vehicle fuel efficiency by about 4% per year, starting at the earliest feasible date and continuing indefinitely,

2. CARB to initiate a drive to increase gasoline taxes nationally, in collaboration with interested political and environmental lobbying groups,

3. CARB to enact policies to accelerate the “greening” of California’s electrical transmission grids, and

4. CARB to provide some incentives for the early introduction of EVs and FC vehicles provided they are matched with measurable progress in drastically reducing the carbon footprint of the energy source (electricity or hydrogen).


Giorgio Rizzoni

A growing fleet of EV/PHEV represents a growing load on the electric grid; any increasing load must be met with an equal 'green' capacity if a constant rate of retirement of coal power plants is to be achieved.

Electricity is the only potential energy source for transportation that addresses the simultaneous need for fuel diversity, energy security, reductions in greenhouse gas emissions, and improvements in air quality that is widely available and produced domestically. Electric utilities must understand the paradigm shift that will occur with an inevitable transition of transportation energy from petroleum to electricity—as well as their new role as a fuel provider for vehicles. The aggressive projections made in the white paper will simply not materialize unless the electric power sector can successfully reduce its CO2 emissions to an extent that exceeds current projections.


Two Key Missing Components

While I must admit that I didn't read both the accompanying White Paper with as close an attention to detail as the four expert reviewers, two key elements stood out in all five. While the White Paper mentions that part of the reason for shifting to a low carbon fuel standard is to reduce dependence on petroleum, it doesn't explain why that is important. The vaunted and now endangered California life style has been based for the last ninety years on the availability of cheap and abundant petroleum, much of it originally produced in downtown LA in the early 1900s. California's oil fields, long past their peak, still produce a modest amount of oil, but nowhere near enough for what the state consumes. And even if it still did, the environmental costs would continue to be horrific.

What the White Paper and subsequent reviews pay little attention to is the future impact of peak oil, not just in California, but globally. Yes, I know there's lot of debate about the "theory," but few people question the fact that petroleum is a finite resource with a lot more people on the planet wanting more of it: China and India being two prime examples. Additionally, if you've been paying any attention, most of the non-OPEC oil producing countries have peaked or are about to in the next few years, certainly by 2020, but that increasingly the petroleum that is being produced, even in the oil rich dominions, is heavier and dirty. Peak oil skeptics point to the gigantic reserves of heavy crude in Venezuela, for example, that dwarfs even Saudi reserves, failing to point out that it is extremely difficult to transport and refine. Worse are the tar sands of Alberta that produce some 15-40 percent more CO2 than conventional crude oil. And then there's the seemingly inevitable growth of coal-to-liquid (CTL) fuel processing that produces synthetic gasoline and diesel from coal, but at twice the CO2 level of petroleum. As conventional petroleum becomes dearer, other, even dirtier fuels will inevitably bid for increasing shares of the market, even in California, although its low-carbon fuel initiative might help stem the tide somewhat, though its recent stance on E85 ethanol had riled corn growers, especially here in Nebraska.

While I am sure ARB's staff is aware of the reality of peak oil, they seem to give it little if any attention in their deliberations or policy recommendations. Clearly it's important that they not only pay it more than just lip service, but that they factor it into their projections, just as my friends at Toyota have done. The pace at which demand outstrips supply will have a profound impact on the state's transportation policies, as it will on the rest of nation and world. So will the production of lithium and other rare earth elements essential to electric drive vehicles and renewable energy technologies.

Instead, it seems staff is narrowly focused on a business as usual scenario where all that happens is people change how their cars are fueled, shifting from petroleum to electricity. I found no reference at all to the need to rethink this basic assumption, or to consider the alternative: better public transit, the second missing component.

Once upon a time, southern California had one of the nation's best public transit systems, which by design and by guile was supplanted by the private motor vehicle and the creation of a vast network of freeways; all predicated on the assumption of cheap energy. Affordable motor cars, abundant gasoline, much of it produced and refined locally and lots and lots of surrounding farm land and orange groves -- supplied by purloined water from hundreds of miles away -- led to the sprawl that is the "Greater Los Angeles." Now the car is a prerequisite for life in the Southland, as well as equally sprawling San Francisco Bay area, though at least BART helps mitigate the problem somewhat.

From my perspective, ARB's staff needs to give far more attention to moving more people more efficiently than its seemingly myopic focus on cleaner cars, which as desirable as they are, don't solve the state's traffic problems. Just as we EV advocates like to point out that it's easier to control the emissions from a few hundred power plants than a few hundred million motor vehicles; it's also more efficient to move millions of people and goods in a few hundred rapid transit trains, and similar modes of public transit. [See: Instead of E-Cars, How About Building Streetcars?].

So, if ARB had asked my opinion of its White Paper, this is what it would included: the timing and impact of peak oil, and the economic (and environmental) impact of improved public transit in achieving the state's CO2 emission reduction goals.

Time to go back to the drawing board, California?

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