Saturday, November 22, 2008

Economics of electric vehicles

While the electrically powered Tesla Roadster is a toy for the rich, at over $100,000, the Chevrolet and Toyota gasoline-electricity hybrids expected in 2010 aim at bigger U.S. markets for electric vehicles. Like the Tesla, they will initially appeal to enthusiasts drawn by personal attitudes. To reach substantial volumes they must compete on conventional grounds, including economics. With few performance measurements and little 21st-century sales experience for electric vehicles, one can only estimate.

We can compare forthcoming electrically powered vehicles with efficient gasoline-powered vehicles from popular makes, including the conventional Honda Civic, Toyota Corolla and Chevrolet Aveo. EPA average efficiency ratings for the 2009 models of these vehicles are 29-31 mpg.[1] The 2009 Tesla Roadster has EPA ratings of 3.0 mi/kWh highway and 3.1 mi/kWh urban.[2]

Energy costs depend on prices. U.S. residential electricity prices vary widely by geographic region but do not vary as much over time.[3] In recent years residential retail electricity rates per kWh have been as low as $.08 in some mountain states but have reached over $.20 in some northeastern states. For 12,000 miles, electric vehicle efficiency of 3.1 mi/kWh, and a range of prices per kWh, annual energy costs for electricity are:

/kWh /yr
0.08 $310
0.12 $465
0.16 $619
0.20 $774

U.S. gasoline prices do not vary as much by region but have seen large price changes over time.[4] During the past five years average U.S. regional prices per gallon regular ranged from $1.40 to $4.60. For 12,000 miles, gasoline vehicle efficiency of 30 mpg, and a range of prices per gallon, annual energy costs for gasoline are:

/gal /yr
1.50 .$600
2.50 $1000
3.50 $1400
4.50 $1800

Whether or not one saves on energy costs with an electric vehicle, and how much, depends on location, on trends in petroleum prices and, for gasoline-electricity hybrids, on what fraction of use is powered by externally generated electricity. In an unfavorable case, with electricity above $.15 per kWh and gasoline at $1.50 per gallon, electricity is more expensive. In a mid-range case, with electricity as $.11 per kWh and gasoline at $2.20 per gallon, for 12,000 miles per year an electrically powered vehicle operating at 3.1 mi/kWh will save about $450 per year over a gasoline powered vehicle operating at 30 mpg. At those energy prices, the highly efficient Toyota Prius gasoline hybrid, with current EPA ratings of 45 to 48 mpg,[1] saves about $570 per year as compared to popular, conventional vehicles.

The balances can change when comparing external electricity costs and gasoline costs in a high-efficiency, gasoline-electricity hybrid. Owners of such vehicles will be able to select the lower-cost source of energy. If such a vehicle achieves an electrical efficiency of 3.1 mi/kWh and gasoline efficiency of 45 mpg, then electricity at $0.11 per kWh will be cost-equivalent to gasoline at $1.60 per gallon.

How much extra will a cost-aware customer pay for an electric vehicle? The announced Chevrolet gasoline-electric hybrid is projected to sell for about $37,000,[5] as compared to efficient gasoline-powered vehicles from popular makes at $12,000 to $15,000.[6] In comparison, the Toyota Prius was introduced in 2000 at about $20,000 [7] and now sells at under $22,000.[6] Where the Toyota Prius has a price premium of about $7,00o to $10,000 over efficient gasoline-powered vehicles from popular makes, the projected Chevrolet vehicle price premium would be from about $22,000 to $25,000.

Depending on circumstances, ten years differences in energy costs, using an electric vehicle, might save from nothing to several thousand dollars. That will be offset by service costs to replace batteries, estimated in the thousands of dollars and with unknown service intervals. Projected pricing of the Chevrolet gasoline-electricity hybrid vehicle is out of line with pricing patterns of gasoline hybrid vehicles and appears unsustainable. After a starting surge of enthusiast buyers, it looks unwise for makers of electric vehicles to expect large-market premiums of more than several thousand dollars per vehicle.

[1] U.S. Environmental Protection Agency, Fuel Economy Guide, 2009, at

[2] Don Sherman, New York Times, Nov. 13, 2008, at, ratings converted from published units of kWh per 100 miles.

[3] U.S. Energy Information Administration, Average Retail price of Electricity, at and, omitting Alaska and Hawaii.

[4] U.S. Energy Information Administration, U.S Retail Gasoline Prices, at, omitting Alaska and Hawaii

[5] Micheline Maynard, New York Times, Nov. 22, 2008, at

[6] Edmunds New Car Prices, at

[7] Internet Autoguide, 2001 Toyota Prius Lineup, at

Some hybrid and electric vehicles use regenerative braking. The gasoline-powered 2009 Prius hybrid achieves EPA ratings of 45 mpg highway and 48 mpg urban.[1] The usual inefficiencies of urban driving are reversed, providing about a 7 percent in-town advantage, primarily because of regenerative braking. The 2009 Tesla Roadster has EPA ratings of 3.0 mi/kWh highway and 3.1 mi/kWh urban.[2] This electric vehicle also achieves an in-town advantage, but only about 3 percent. It appears to have room for some improvement.

Saturday, November 15, 2008

Emissions from using electric vehicles

The U.S. Environmental Protection Agency is currently constructing "miles per gallon" ratings for electric vehicles, in what has become a political rather than a scientific exercise. While we cannot evaluate electric-powered and hybrid-electric vehicle efficiencies and gasoline-powered vehicle efficiencies on exactly the same basis, we can compare carbon dioxide emissions caused in powering them.

The hucksters for electric vehicles encourage people to think of them powered by low-polluting sources. Decades from now they might be. But today, at any given time, the U.S. electrical grid rarely has spare capacity from nuclear, hydro or renewable power. Added demands for electricity, demands that might have been met with some other form of energy, will usually cause coal-fired generators to come on line and run harder. Vehicles that might have been powered by burning gasoline will instead be powered by burning more coal.

The 2009 Tesla Roadster is rated as consuming 28 kWh of external electrical energy to travel 100 miles [1] on an EPA combined-cycle test. The 2010 Chevrolet Volt was measured to consume 8 kWh of internal electrical energy to travel 40 miles [2] under unstated conditions, or 20 kWh per 100 miles. We do not know the added amount of external energy consumed by charging and battery losses.

The U.S. government most recently rated average carbon dioxide emissions for coal-fired power [3] at 2.1 lb/kWh. This yields carbon dioxide emission estimates for the Tesla and for the Volt, when battery powered, as follows:

Tesla 2.1 * 28 / 100 = 0.59 lb/mi carbon dioxide
Volt 2.1 * 20 / 100 = 0.42 lb/mi carbon dioxide, plus losses

The Honda Civic is a popular, efficient, gasoline-powered vehicle. Carbon dioxide emissions have been measured for the 2009 Hybrid model at 109 g/km [4] and for the 2009 conventional Civic at 159 g/km [5] or, in U.S. units:

Civic 1.609 * 159 / 453.6 = 0.56 lb/mi carbon dioxide
Hybrid 1.609 * 109 / 453.6 = 0.39 lb/mi carbon dioxide

Thus, when powered by the U.S. electrical grid, those electric vehicles, while avoiding use of gasoline, result in more carbon dioxide emissions than efficient gasoline-powered vehicles.

[1] Tesla Motors, 2008, at

[2] General Motors, 2008, at

[3] U.S. Office of Energy Efficiency and Renewable Energy, Carbon Dioxide Emissions from the Generation of Electric Power, 1999 (Table 1), at

[4] ZerCustoms, 2008, at Also rated by GreenConsumerGuide, 116 g/km, 2008, at

[5] WhatGreenCar, 2008, at

There's much wonkery around, strong on philosophy. What comes out the smokestacks pays no heed. As demands come to the grid, interconnects respond. Renewables are maxed out by regulation, Nuclear and hydro are almost always saturated, priced for base load. In a few areas combined cycle sometimes has capacity but depends on imported gas. Almost always the low-bid reserve is coal, so what comes out the stacks is more coal smoke. Build millions of windmills, and at some point we see nuclear shutins and wind reserve, maybe in 50 years. The promise of electric vehicles that can be operated now is not to improve the environment but to replace imported fuels.

Thursday, August 21, 2008

Beginning a solar power industry

Spurred by California's renewable energy law, on August 14, 2008, Pacific Gas and Electric announced the launch of major photovoltaic facilities.[1] It is contracting with OptiSolar of Hayward, CA, to purchase the power produced by a 550 peak MW thin film, fixed mount photovoltaic plant and with SunPower of San Jose, CA, to purchase the power produced by a 250 peak MW crystalline, single-axis moving mount photovoltaic plant.

Both facilities are planned for sites in San Luis Obispo County, CA. OptiSolar filed a permit application[2] on July 18, 2008, for a Topaz Solar Farms project, describing a 6,200-acre site north of CA 58 (Carrisa Rd.) and spanning Bitterwater Rd. SunPower announced plans for a California Solar Ranch project to be built on a 2240 acre site south of CA 58 and east of Soda Lake Rd.

In 2007 Ausra of Palo Alto, CA, announced plans[3] for a 177 peak MW solar thermal plant to be built for PG&E on 640 acres in San Luis Obispo County, CA, near CA 58 and east of Bitterwater Rd. PG&E also has previous contracts to purchase power from 800 peak MW of solar thermal plants located in California's Mojave desert,[3] while Southern California Edison is building a 500 peak MW solar thermal planT there.[4]

Sites of the San Luis Obispo County facilities are planned in the northern and central Carrizo (or Cariso or Carrisa) Plain, a valley between the Tremblor Range to the northeast and Coast Ranges to the southwest. The southern part of the Carrizo Plain and adjacent parts of the Tremblor and Caliente Ranges are protected as the Carrizo Plain National Monument.[5] Located just north of the unincorporated town of California Valley, CA, the sites are about 150 air miles northwest of Los Angeles.

Carrizo Plain is about 40 miles long and up to 7 miles wide. Land is used mainly for dryland farming; much of the land is unused. Located in the rain shadow of the Coast Ranges, Carrizo Plain often has cloud cover from November through February but is usually sunny in warmer months. It receives on average about 8 inches of annual rainfall. It has experienced major earthquakes. The announced solar facilities will occupy a little over 10 percent of Carrizo Plain.

NASA records for average insolation around the Carrizo Plain solar facility sites are 5.1 KWh/sqm-day,[6] comparable to Scottsdale, AZ, and better than major European facility sites at Serpa, Portugal, and Brandis, Germany. OptiSolar estimates a 23% annual capacity factor for Topaz Solar Farm. SunPower estimates a 25% annual capacity factor for California Valley Solar Ranch. Compared to insolation and performance for the largest current photovoltaic plant at Brandis, the OptiSolar and SunPower estimates appear optimistic by about 15 percent, possibly justified by sparser layouts.

These projects have created a solar power industry in California, in which solar technology companies are constructing and in some cases WILL operatE industrial scale facilities.

[1] David Sneed, PG&E to buy power from 2 solar farms, San Luis Obispo Tribune, August 15, 2008, at Matt Nauman, PG&E, SunPower announce major solar deal, San Jose Mercury News, August 15, 2008, at

[2] Optisolar, Topaz Solar Farm Application Submittal, July 18, 2008, at

[3] Michael Kanellos, PG&E links with Ausra for 177 megawatts of solar thermal power, CNet News, November 5, 2007, at

[4] Michael Kanellos, Ausra goes for a gigawatt, CNet News, September 27, 2007, at

[5] U.S. Geological Survey, Carrizo Plain National Monument, 2004, at

[6] U.S. National Aeronautics and Space Administration, Surface meteorology and solar energy database, at

Monday, July 14, 2008

Climate of discontent

Enthusiasts for action on climate change may have put the cart so far before the horse that there are no longer any reins and other horse tack connecting them. Worldwide solutions to projected problems carry enormous potential costs, tens to hundreds of trillions of dollars, or years to decades of the total economic output of the United States. Before there can be any sustained commitment approaching such scales, there will have to be general agreement and near total certainty as to benefits and costs. Today there is only limited agreement and great uncertainty. Areas of agreement are recent trends of rising temperatures, rising sea levels and rising concentrations of trace gases in the atmosphere. Uncertainties include distinguishing causes from effects, assessing relative strengths of causes and predicting future effects from human efforts directed at causes.

Key knowledge and projections of climate change are coming from a few hundred people worldwide, who rarely if ever expose details of their work candidly to public view. Most reports rest on hackneyed assumptions, stated or not, that have never been conclusively proven. Only insiders at the private clubs get meaningful access. However, mavericks among them have explained that no model achieves much accuracy in predicting many decades of observations based solely on the profile of the Earth and on physics, chemistry and scalable, validated engineering. Models are tweaked with arbitrary adjustments, parameters determined by statistical inference rather than from physical principles, so that they get the right answers to match observations[1]. Who has the crystal ball to tweak them correctly for future years? An article evaluating several thousand models showed that only 15 years into the future, global temperature projections varied up to nearly 15 degrees Farenheit[2].

That situation does not reflect some kind of "junk science" [3] but rather an endeavor of great complexity, comparable perhaps to understanding the causes of and cures for cancer, and similar in that about 50 years of science has produced partial knowledge and limited success, leaving vast territories yet to be covered. Atmosphere and ocean circulations are dynamic, chaotic and dissipative, with many interacting factors and much potential for novel and unpredictable behavior. After 50 years of science, we are able to predict weather fairly accurately for about two days, but at about two weeks all our supercomputing and automatic monitoring does not improve much over what we can predict from typical weather for a time of year.

Climate, of course, is weather, averaged over years, decades and centuries. On a historic time scale, let alone a geologic scale, our records are spotty and shallow. We have a handful of temperature series extending back a few hundred years, some measurements of atmospheric gases for about a century and a half, and direct if controversial measurements of solar output since 1979. The past thirty years have seen major improvements in the density and sophistication of measurements, but such an amount of time is at best marginal as a baseline for estimating climate. Solar output, a critical factor in climate, can be estimated from longer records of sunspot activity, but the correlations are noisy and imprecise.

Historical records tell about sizable shifts in climate before the Industrial Age, such as the Medieval Warm Period, a shift in annual temperatures up to 2 degrees Farenheit found in Europe from about 800 to 1,300 CE. We have little to explain some such events except unmeasured changes in solar output. Modern measurements of the geologic record over the last several million years tell about more dramatic episodes of warming and cooling, shifting annual temperatures by more than 20 degrees Farenheit, with some substantial changes taking place in less than 100 years. Persistence of some patterns over centuries and millenia, recurrences at intervals around 40,000 and 100,000 years, and abrupt spikes and dips make explanations appear unlikely other than orbital patterns and solar output changes, stimulating changes in atmosphere and ocean circulation. In some warming episodes, atmospheric carbon dioxide concentrations lag rather than lead temperatures, thus appearing as effects rather than causes.

Many current climate models fail to consider records older than about 100 years, but useful records extend to three times that age. Among other things, they indicate warming trends since the early 1700s, while large effects of the Industrial Age on atmospheric gases emerge in the mid-1800s. Adjustment factors of current climate models may be tuning them to correlations between temperatures and atmospheric gases that would not be found in records over longer periods. Atmospheric emissions from power plants, motor vehicles and agriculture exploded since the 1940s, yet although it has been shown that the average exchange time for carbon dioxide between atmosphere and ocean is about ten years, records of temperatures and sea levels do not show closely correlated accelerations of most trends.

Experts at climate modeling seem increasingly focused on inside pursuits, such as cross-comparisons and increased areal and time densities. However, development of the science shows greatest improvements from understanding new factors, such as cloud cover, aerosols and particulates. Trustworthy knowledge is more likely to emerge from thorough understanding of systematics and interactions than from refinements of calculations. Unless we can obtain robust, accurate models grounded on principles of physics, chemistry and engineering, few people will trust the models with their lives and fortunes. Critical issues are whether, how much and how rapidly climate change could now be affected by human efforts and what levels of efforts may be required. If it were to turn out that rises in sea levels had become practically unstoppable and irreversible, then we might better spend resources reinforcing or relocating coastal communities rather than rushing to build photovoltaic panels.

[1] A. Arakawa and W.H. Schubert, Interaction of a cumulus cloud ensemble with the large-scale environment, part 1, Journal of the Atmospheric Sciences 31(4):674-701, 1974. A.H. Van Tuyl, Physical initialization with the Arakawa-Schubert scheme in the Navy's operational global forecast model, Meteorology and Atmospheric Physics 60(1):47-55, 1996. T.M. Wagner and H-F. Graf, A spectral convection parameterisation with a dynamical Arakawa-Schubert quasi-equilibrium closure, Geophysical Research Abstracts 10, EGU2008-A-12443, 2008.

[2] D.A. Stainforth, et al., Uncertainty in predictions of the climate response to rising levels of greenhouse gases, Nature 433(1):403-406, January, 2005.

[3] Steven Milloy, ed., Martin Durkin, dir., “The Great Global Warming Swindle,” British television film, March 8, 2007, revised edition available as DVD. Lars Mortensen, dir., "Doomsday Called Off," Danish television film, 2004, first shown in Canada, November 27, 2005. Hilary Lawson, dir., "The Greenhouse Conspiracy," British television film, August 12, 1990.

Saturday, July 12, 2008

A game of regulation with jokers in the deck

When courts call, the EPA folds. Most recently the call was for the U.S. Environmental Protection Agency, representing the Administration in office from 2001 to 2009, to justify its Clean Air Interstate Rule, which was under development from 2001 through 2003. The EPA lost everything. Its entire rulemaking action was canned, and the agency was told to start over, in a decision from the Third Circuit Court of Appeals, North Carolina v. Environmental Protection Agency, No. 05-1244, July 11, 2008.

From its beginnings, CAIR, the Clean Air Interstate Rule, was a scam purporting to regulate stringently the air pollution emitted by power-plants that flows from state to state, while actually offering power-plant operators a low cost, if not a free, ride. Emissions were to be regulated only on a regional basis, using a trading system through which power-plant operators could buy the rights to pollute. Pollution limits, on the other hand, were to be regulated on a local basis, requiring potentially draconian measures by cities and counties found out of compliance, but giving them no powers to stop emissions coming from somewhere else. Enforcement of local limits was scheduled for 2010, one convenient year after the Administration responsible for the system had left office, dumping inevitable problems onto its successor.

The tip-off to a scam was the EPA focus in CAIR on “highly cost-effective” emission controls. The agency was set up to regulate pollution, not industrial finance. It is charged by law to insure that power-plants use the "Best Available Control Technology" to reduce emissions when new plants are built or old ones are significantly renovated. As the Court of Appeals stated, "Because EPA evaluated whether its proposed emissions reductions were 'highly cost effective' at the regionwide level, assuming a trading program, it never measured the 'significant contribution' from sources within an individual state to downwind nonattainment areas." The EPA did not document the amounts of air pollution travelling from power-plants to local areas and had no plans to monitor them.

The power industry is now crying wolf and apparently influenced the New York Times to howl along. In an article published July 12, 2008, power industry representatives were quoted condemning the court decision, one spokesman saying, "one of the things we crave is certainty, and this goes in the other direction." The EPA Administrator during development of CAIR was a former governor who, according to the Times, had been criticized "in the name of attracting businesses" for having "compromised water pollution protections and cut spending for state offices that prosecute environmental abuses by industry." That was hardly enough, and the agency was routinely told what to do and sometimes how to do it. Evidence for its continuing manipulation can be read in an EPA proposal of July 11, 2008, to investigate regulating carbon dioxide, as the agency was instructed to do by a Supreme Court decision in Massachusetts v. Environmental Protection Agency, 549 U.S. 497, April 2, 2007. The recent announcement starts by exhibiting a letter to the current EPA Administrator from an appointee responsible for Regulatory Affairs in the President's Office of Management and Budget, saying what to do and how to do it.

But now the hands have been played, the game is almost over, and the jokers are leaving. The problems that CAIR would supposedly address are still with us, of course. Were we to take care in regulating pollution rather than CAIR, we would account not only for emissions but also for power flowing from state to state. Southern California, for example, is notorious for drawing heavily on coal-fired power-plants in the Southwest, thus enjoying "clean" power while sending most of the pollution somewhere else. One possible approach, in somewhat the spirit of the discredited CAIR, is to charge Southern California electricity consumers directly and explicitly for pollution emitted by their practices.

Tangle of air pollution regulations affecting energy

Federal court decisions from 2005 through 2008, unlike some from earlier years, indicate that without persuasive evidence attempts to weaken, subvert or avoid environmental regulations affecting energy production will be overturned and indicate that enforcement of regulations will be upheld.

Four Court of Appeals decisions and two Supreme Court decisions changed the landscape. An Administration seeking to obstruct regulations had resorted to wordsmithing and legalisms. A southern, coal-fired power-plant operator seeking to avoid regulations had persuaded southern courts to do the same.

The power-plant operator's case was sent back for enforcement. The Environmental Protection Agency was instructed to investigate regulating carbon dioxide. The attempts to weaken or subvert air pollution regulations were rejected, striking out seven actions of the U.S. Environmental Protection Agency from 2002 through 2005 and restoring earlier regulations.

New York, et al., v. Environmental Protection Agency
Court of Appeals for the District of Columbia [3rd] Circuit
No. 02-1387, June 24, 2005, 413 F.3d 3
"In 1977, Congress amended the Clean Air Act (CAA or 'the Act') to strengthen the safeguards"
"major stationary sources undertaking modifications...process known as “New Source Review” (NSR)"
"petitioners now challenge this 2002 [NSR] rule, which departs sharply from prior rules"
"EPA erred in promulgating the Clean Unit applicability test, which measures emissions increases by looking to whether 'emissions limitations' have changed"
"Congress directed the agency to measure emissions increases in terms of changes in actual emissions"
"EPA also erred in exempting from NSR certain Pollution Control Projects (PCPs) that decrease emissions of some pollutants but cause collateral increases of other"
"we vacate the provisions...regarding the Clean Unit applicability test and Pollution Control Projects"

New York, et al. v. Environmental Protection Agency
Court of Appeals for the District of Columbia [3rd] Circuit
No. 03-1380, March 17, 2006, 443 F.3d 880
"Equipment Replacement Provision (“ERP”)...amends the Routine Maintenance, Repair, and Replacement Exclusion (“RMRR”) from NSR requirements"
"Under section 111(a)(4) of the Clean Air Act, sources that undergo 'any physical change' that increases emissions are required to undergo the NSR permitting process."
"ERP would allow sources to avoid NSR when replacing equipment notwithstanding a resulting increase in emissions"
"because it violates the Act, we vacate the ERP"

Massachusetts v. Environmental Protection Agency
Supreme Court of the United States
No. 05–1120, April 2, 2007, 549 U.S. 497
"organizations petitioned the Environmental Protection Agency (EPA) to begin regulating...carbon dioxide"
"EPA ultimately denied the petition, reasoning that (1) the Act does not authorize it"
"Court of Appeals...judges agreed that the EPA Administrator properly exercised his discretion"
"EPA has offered no reasoned explanation...Its action was therefore 'arbitrary, capricious"
"The judgment of the Court of Appeals is reversed"

Environmental Defense, et al., v. Duke Energy Corp., et al.
Supreme Court of the United States
No. 05-848, April 2, 2007, 549 U.S. 561
"Duke Energy Corporation replaced or redesigned...coal-fired electric generating units"
"the United States filed this enforcement action"
"the District Court entered summary judgment for Duke on all PSD claims...The Fourth Circuit affirmed"
"The Fourth Circuit’s reading of the PSD regulations amounted to the invalidation of the PSD regulations"
"The judgment of the Court of Appeals is vacated"

New Jersey, et al. v. Environmental Protection Agency
Court of Appeals for the District of Columbia [3rd] Circuit
No. 05-1097, February 8, 2008
"petitions for review of...rules regarding the emission...from electric...generating units (EGUs)"
"first rule [Delisting rule] removes coal- and oil-fired EGUs from the...sources...regulated under section 112 of the Clean Air Act"
"second rule [CAMR] establishes total mercury emissions limits for States and certain tribal areas"
"Clean Air Mercury Rule [CAMR]"
"Petitioners contend that the Delisting Rule is contrary to the plain text and structure of section 112"
"in section 112(c)(9)...Congress limit[ed] EPA’s discretion to remove sources...from the section 112(c)(1)"
"EPA can point to no persuasive evidence suggesting that section 112(c)(9)’s plain text is ambiguous"
"Because coal-fired EGUs are listed sources under section 112, regulation of existing coalfired EGUs’ mercury emissions under section 111 is prohibited"
"the court grants the petitions and vacates both rules"

North Carolina v. Environmental Protection Agency
Court of Appeals for the District of Columbia [3rd] Circuit
No. 05-1244, July 11, 2008
"Petitioner North Carolina challenges CAIR’s programs for pollution-trading"
"Clean Air Interstate Rule [CAIR]"
"North Carolina contests the lack of reasonable measures in CAIR to assure that upwind states will abate their unlawful emissions."
"EPA...never measured the 'significant contribution' downwind nonattainment areas."
"No amount of tinkering...will transform CAIR, as written, into an acceptable rule"
"we vacate CAIR and its associated FIP [federal implementation plan]"

(7) [added Aug. 23, 2008]
Sierra Club v. Environmental Protection Agency
Court of Appeals for the District of Columbia [3rd] Circuit
No. 04-1243, August 19, 2008
"Clean Air Act emission limits...are scattered throughout rules promulgated by states or EPA"
"1990 Amendments...created a national permit program"
"Title V gives EPA...the duty to identify its 'minimum elements'"
"in 1997...the agency took the position that...permitting authorities could supplement...requirements"
"In 2002, EPA proposed a regulation codifying this view of §70.6(c)(1)"
"an industry group challenged the...rule...Util. Air Regulatory Group v. EPA, No. 02-1290
"the agency settled the litigation by agreeing to...a...rule that would prohibit...supplementing"
"Several environmental groups challenge the 2006 rule...arguing that they violate the Clean Air Act"
"We hold...that Title V of the Act unambiguously precludes EPA’s interpretation in the 2006 rule"
"Accordingly, we vacate the 2006 rule"

Wednesday, January 2, 2008

When is a hybrid not?

When it's a Chevy. Here are specifications for the 2008 Chevrolet Malibu and its main competition, the 2008 Toyota Camry, both vehicles available in conventional as well as hybrid versions:

Body Typesedansedansedansedan
Engine Size, l2.
Auto. Transmission4-speed4-speed5-speed5-speed
Weight, lb3,4363,5373,2853,637
Power, hp169164155147
Torque, ft-lb160159161192
MSR Price, US$$19,345$22,140$21,075$25,200
EPA Urban mpg22242133
EPA Highway mpg30323134
EPA Combined mpg25272534
Gasoline, US$/yr$1,800$1,667$1,800$1,324
Hybrid mpg Gain 8% 36%
Payback, years 21 9

The single-mode technology of the Malibu Hybrid provides just a marginal improvement in efficiency. At $3 per gallon for gasoline, driving 15,000 miles per year, payback of the cost difference over the conventional base model takes more than 20 years. Chevrolet is trying to compete with Toyota on car prices, offering inferior technology. The last twenty years of automotive history indicates that the strategy will fail. Toyota shows how to get almost a real 35 mpg vehicle, not by 2020 but this year, at a reasonable price and without giving up comfort and performance.