You'll be shocked who is quoted in the EPA determination notice!

Discussion in 'General' started by WadeTyhon, Apr 4, 2018.

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  1. WadeTyhon

    WadeTyhon Well-Known Member

    ...okay, not really. You won't be shocked at all.

    "Various comments raised questions about how to predict the impacts of the standards on vehicle sales. The Alliance and NADA argued that EPA has not yet conducted an “appropriate analysis” of the sales impacts of the standards, and NADA asks the agencies to “fully understand” consumer vehicle purchase decisions. The Alliance referenced work by Ford suggesting that the standards would reduce sales volumes by four percent using cost estimates from the draft TAR. Other commenters provided that neither EPA nor NHTSA has found vehicle demand modeling methods robust enough to predict sales impacts; and EDF stated EPA and NHTSA could consider using a static forecast (that is, assuming market shares to be unaffected by the standards)."

    "Toyota provided comment that “compliance with the current requirements through the 2025 MY require gasoline hybrid electric vehicles or more sophisticated forms of vehicle electrification at sales volumes significantly higher than the agencies’ estimates and at levels the market is unable or unwilling to support absent significant changes in market signals.” Toyota further provided that they continue to disagree with EPA’s past assessment that lighter, more aerodynamic vehicles powered by less expensive conventional gasoline powertrains will be sufficient to comply with the standards."

    "Toyota’s information stated that “[n]ot yet implemented technologies, such as advanced cylinder deactivation and 48V mild hybrid systems, can play a role in improving efficiency and reducing CO2 emissions moving forward; however, we do not project these technologies as sufficient to meet the 2025 MY requirements.”

    Fiat Chrysler Automobiles (FCA) similarly indicated, “FCA continues to provide data that shows more technology is necessary than the agencies have assumed for 2022-2025MY compliance. The advanced technologies needed, including higher levels of electrification will negatively affect affordability, lowering sales, and ultimately impacting jobs.”

    "Mercedes Benz estimated that it will need more than 25 percent battery electric vehicles (BEVs) and around 5 percent PHEVs in its fleet to meet the standards in MY 2025, noting that these estimates are significantly higher than the 7 percent BEV and 3 percent PHEV shares projected by EPA for the overall fleet."

    "Mitsubishi expressed concern that it would have to add electrification to already efficient low-priced vehicles and the increased price could drive buyers to less efficient used vehicles."
    Last edited: Apr 4, 2018
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  3. WadeTyhon

    WadeTyhon Well-Known Member

    GM, BMW and Nissan are not quoted, but the report frequently makes references to "other commenters" that mostly seem to think the standards are achievable. I imagine this is GM, BMW, and Nissan since they are the only manufacturers that have embraced electric vehicles.

    The report specifically mentions when they are referring to non-industry commenters such as The union of concerned scientists, CARB, and other organizations and states. They all support the standards generally. Automotive suppliers came out in full support of the standards and increased electrification.

    Nissan is only quoted on the desire to preserve the current harmonized standards. One thing that all automakers agree on is they like the current national standards. And ultimately it will all come down to this, I think. No major changes are likely to occur unless CARB agrees to them.

    "Many stakeholders commented on the importance of maintaining a National Program for GHG emissions and CAFE standards, and stakeholders urged EPA and NHTSA to continue coordinating with the California Air Resources Board. For example, Global Automakers commented, “Harmonization between the federal and California programs must be maintained. EPA, NHTSA and California need to work together to maintain the One National Program as all parties committed to at its inception.” Toyota commented that its ultimate objective “remains a true, single national standard governing fuel economy and greenhouse gas emissions in the future.” Nissan and Mitsubishi similarly commented that harmonization between federal and California programs must be maintained, urging California, EPA and NHTSA to work together."

    "Automotive suppliers also commented on the importance of maintaining the National Program. For example, the MEMA stated “[t]he One National Program provides industry stakeholders with economies of scale and increases domestic investment in emissions-reducing and fuel-efficiency technologies and jobs. Anything that falls short of a National Program will fail to provide the long-term planning certainty the industry needs to make the long-term business and technology investment decisions to meet MYs 2022-2025 standards and beyond.” The International Union, United Automobile, Aerospace and Agricultural Implement Workers of America (UAW) commented that all stakeholders should work towards a single National Program and that “California and non-governmental organizations must have a seat at the table along with manufacturers and workers.”

    "The UAW, while not objecting to a reevaluation of the standards, stated that EPA should ensure that the regulations recognize the long-term importance of manufacturing a diverse fleet of motor vehicles in the United States by American workers and radically weakening the standards will adversely impact investments in key technologies and put domestic manufacturers behind in making fuel-saving technologies being used to meet the standards. Some commenters stated they believe there would be positive effects on employment from the standards through their effects on investments."

    Interesting how Ford and Fiat in particular claim the standards will impact jobs... but UAW and Automotive suppliers think it will have positive impacts on employment.

    "EPA and NHTSA have been communicating with stakeholders, including CARB and automobile manufacturers, to try and ensure that a national harmonized program remains intact to minimize unnecessary cost and burdens in the development of the notice and comment rule-making."
    Last edited: Apr 4, 2018
  4. Pushmi-Pullyu

    Pushmi-Pullyu Well-Known Member

    Legacy auto makers pining for legacy environmental standards to be used in regulating pollution emitted by their cars.

    Kinda reminds me of the warning about generals always preparing to fight the last war, rather than the next one.
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  5. Cypress

    Cypress Active Member

    Argh. So frustrating that we have such short sited people in high positions of leadership.
    WadeTyhon likes this.
  6. 101101

    101101 Well-Known Member

    They are called criminals.
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  8. WadeTyhon

    WadeTyhon Well-Known Member

    Is it any wonder that the automakers whining loudest to the government about not being able to meet compliance are the ones that barely have any electric vehicles on the market? :rolleyes: You mean Mercedes, who sells nothing but the Smart ED and a few sub-par hybrids isn't prepared to meet emission standards? No waaaaay.

    Of course most of the automakers they're asking for minor tweaks not sweeping changes. But the danger is, they're asking freaking Pruitt who would probably disband the EPA if he could! He's a stooge for the oil industry. Not the auto industry.

    Yep, there would be no issue if we didn't have a despicable person like Scott Pruitt leading the EPA. He is no friend to the car industry, environmentalists or consumers. If Pruitt ignores what the industry itself wants, it will be 100% due to the oil industry influence.

    Again, I don't think any major changes are going to happen. But only because the automakers know that if the EPA seriously lowers or removes the standards they will end up in worse shape than they're in right now. They'll be at the whim of any future CARB demands. Or years of lawsuits and bad PR.

    In the absence of a federal standard agreed to by both CAFE and CARB (like we have currently) most automakers will distance themselves from the administration. They will build their vehicles to meet CARB standards. And Scott Pruitt would love this because he succeeded in his mission to cripple the agency.
  9. scottydoesntknow

    scottydoesntknow New Member

    I see you've read the MTE, at least enough to quote parts of it. I read it all, and don't agree with the prevailing assessment of it at all.

    OEMs / industry are supposedly "innovating faster than EPA anticipated". The argument is that the regs must be too lenient. But the MTE says that OEMs tell the EPA they are over-complying early while it is easier to earn credits so they can survive on them later when it's way harder.

    Let's assume that the "OEMs have it too easy already" assertion is correct.

    How can it then also be true that "the only MY 2017 vehicles that could comply with the MY 2025 standard ... make up less than 5 percent of the total market share [today]."?

    Toyota says only HEVs, PHEVs, and BEVs are compliant in MY25. Not even mHEVs will be enough on their own. Were 95% of MY17 light vehicles sold somehow dirty? If we force HEV technology and its high cost where there is less demonstrated market desire than effectively called for by regulation, will the same number of people buy New? Will those people instead buy Used? If New contracts, will automotive jobs ebb? If we don't sell enough New today, will we have enough Used for tomorrow? If we don't, will the EPA's 2012 projections--predicated on a certain fleet replacement rate--still happen? Will the overall vehicle fleet in the United States be overall less efficient, and therefore emit more CO2?

    Do you really think that Toyota, who pioneered mass-market HEVs 20 years ago, is sandbagging?

    Could it be that, perhaps, the regs maybe really are too stringent?

    These are just some of the questions that the MTE allows more time to consider instead of jamming through a Final Determination and skipping stakeholder commentary a week before your Administration goes out the door. Last week's reversal isn't rulemaking on its own.

    Look, I'm a big EV fan and proponent. I have a BEV on order coming in a few weeks, even though some here would call it a compliance car (it's not). I'm no shill or FUDster. But the hysterics like today's "deep dive" from this and every other EV site about as-yet-to-be-determined rulemaking is embarrassing. It made me register to write and post this counterpoint. I probably couldn't even post this on GreenCarReports, so kudos to IEVs at a minimum.

    EVs will break through starting in 2020 or 2021. That isn't that long from now. We enthusiasts have this tendency to want it to happen yesterday, and blame some strawman for why it hasn't: Big Oil, Big Auto, President Trump, Scott Pruitt, whoever.

    In reality, people have to choose to buy HEVs, PHEVs, and BEVs and they have undeniably not, so far. Individuals always have choice in what they want to buy, subject to individual preferences, needs, and wants. These vary widely in our pluralistic society. Yes, an option must be presented to be chosen. But right now range and charging aren't attainable for most people's comfort, even though it covers 95% of their needs. The problem is they way it to cover that last 5% of their needs (note the 95/5 theme).

    The bigger problem is that outgoing 1.0 or even 1.5 BEVs aren't cost-feasible. Larger is even worse unless you are charging luxury prices. That means that we don't have any volume segment coverage of larger vehicles, which are now 60-70+% of the light vehicle market. Once these things are alleviated--starting in 2020--the TCO advantage of BEV will make ICE outdated with market forces.
    Last edited: Apr 16, 2018
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  10. Cypress

    Cypress Active Member


    Interesting idea. But honestly, they have had many years to invest in the technologies they need to meet the 2025 requirements and development time to get the costs down to offer compelling products. GM seems to have a roadmap to meet China’s tougher standards, so I’m sure they could do so here in the US if required.

    The automakers could choose not to meet the standard and pay the fines (and pass the costs to buyers, which raises the costs of non-compliant ICE vehicles) which don’t even begin to cover the externalities.

    An proper interim review was done, and this re-review is purely politically motivated by administration hostile to clean energy and transportation.
  11. WadeTyhon

    WadeTyhon Well-Known Member

    "Do you really think that Toyota, who pioneered mass-market HEVs 20 years ago, is sandbagging?"

    I think Toyota said it themselves. They're worried about their own "stranded investment" because they have invested so heavily in hybrids.

    I have not only read the MTE but also the comments presented by Ford, Fiat, Nissan, Toyota and Mercedes. As well as additional supplementary information from GM, BMW, and the automotive lobbies.

    "EVs will break through starting in 2020 or 2021. That isn't that long from now. We enthusiasts have this tendency to want it to happen yesterday, and blame some strawman for why it hasn't: Big Oil, Big Auto, President Trump, Scott Pruitt, whoever."

    I'm glad you see a future in EVs, and I agree. I think mid-next decade is when the numbers will take off the way we are all hoping. Some automakers agree with you and me. Nissan as well as recent comments and statements by BMW and GM see a future in EVs and are looking for more incentives to promote EV production and spur adoption in the short term.

    Ford, Fiat, Toyota and Mercedes are particularly hostile towards the entire concept of EVs. The crux of their argument is primarily that that buyers do not want EVs in the first place because they feel that they're inferior to the gas engine. Not that EVs will become cheaper to make around 2020-2021.

    They're saying that by adoption EVs, vehicle fleets will somehow be less efficient, because less new cars will be made and people will buy older cars. They're saying it will cost American's their jobs. They stand out in contrast to automakers that have already accepted EVs as the future.

    I do feel that some of the broader regulatory changes suggested by automakers are reasonable and can/will be changed with the support of CARB. I will have a second article up shortly that discusses some of these suggested changes that will make the standards easier to manage as prices drop over the next few years. All automakers are asking for these more minor changes, including those with a history of supporting the technology.

    Also, I fully encourage people to buy the right plug-in that suits them, even from automakers that don't want to sell them. :)

    I drove a Spark EV and that was in fact a "compliance car". It was also a great car and I loved it! I like to think that by people like myself adopting the Spark and Volt early on, it encouraged GM to take a larger plunge into electric vehicles that we are just now beginning to see.

    I have attached 4 of the comments to the EPA from the most recent comment period. You'll probably find that Nissan stands out among them. I attempted to add Ford's comment as well, but it seems to be too large for the forum.

    @Domenick what is the max file size for images/pdfs/documents? I can try to remove some of the unnecessary pages from the ford document and upload it.

    Attached Files:

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  13. For files other than photos, 5 MB is the limit. Photos are just automatically resized.
  14. WadeTyhon

    WadeTyhon Well-Known Member

    Thank you! I will probably break it up in two and post them as separate files then.
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  15. WadeTyhon

    WadeTyhon Well-Known Member

    Uploaded the Ford document in 2 parts.

    Here is also the second article I mentioned.
    There are several changes that I think are more than reasonable and were actually requested well before the election of Trump. So I have also included a response from the NHTSA in December of 2016 to the proposed changes by automakers from June 2016.

    Attached Files:

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