To say that the EPA’s most ambitious plan to date to cut greenhouse gas (GHG) emissions from passenger vehicles has been met with skepticism is an understatement. The overriding reason is that the plan isn’t realistic. The truth is clear, according to a variety of sources, for multiple reasons.
The plan
On April 12, 2023, the EPA announced new proposed federal vehicle emissions standards for light-, medium-, and heavy-duty vehicles for model year (MY) 2027 and beyond that are expected to accelerate the ongoing transition to a clean vehicles future and tackle the climate crisis.
On the same day, the EPA also announced new proposed standards for heavy-duty trucks.
Together, the proposed rules are projected to “avoid nearly 10 billion tons of [carbon dioxide (CO2)] emissions, equivalent to more than twice the total U.S. CO2 emissions in 2022, while saving thousands of dollars over the lives of the vehicles meeting these new standards and reduce America’s reliance on approximately 20 billion barrels of oil imports,” says an Agency press release.
The proposed standards are performance-based, allowing each automaker to choose what set of emissions control technologies is best suited for its vehicle fleet to meet the standards.
According to the EPA, one potential pathway for manufacturers to meet the limits is by achieving 67% of new vehicle sales in the electric vehicle (EV) category by 2032. Many in the auto industry have said this goal is unrealistic.
“Even if the industry boosts EV sales to the level the EPA recommends, any reduction in pollution could prove more modest than the agency expects,” the Associated Press says. “The Associated Press has estimated that nearly 80% of vehicles being driven in the U.S. — more than 200 million — would still run on gasoline or diesel fuel.”
Scientific data and the Paris Agreement
The Paris Agreement on climate change calls for limiting global warming to 1.5 degrees Celsius, or 2.7 degrees Fahrenheit.
“Peter Slowik, a senior EV researcher with the nonprofit International Council on Clean Transportation, has calculated that to cut emissions enough to reach Paris Agreement goals, the proportion of new electric and plug-in hybrid vehicles sold would have to reach 67% by 2030,” the Associate Press continues. “The EPA has projected 60% by then.”
“The EPA proposal is a really great start to putting us on a Paris-compatible path,” said Slowik, whose group provides research and analysis to environmental regulators, according to the Associate Press. “But no, it isn’t enough to comply with the Paris accord.”
“The council has calculated that carbon dioxide pollution from passenger vehicles would have to drop to 57 grams per mile by 2030 to reach the Paris goals,” adds the Associated Press. “The EPA’s preferred regulation would cut those emissions to 102 grams per mile by 2030 and to 82 by 2032.”
Additionally, new gasoline vehicle carbon emissions would also have to keep dropping 3.5% each year from 2027 to 2032, according to Slowik.
The transportation sector accounts for 28% of GHG emissions from 2021 data, the “largest share of [GHG] emissions,” according to the EPA GHG Sources website. This sector includes cars, trucks, trains, ships, airplanes, and other vehicles. Passenger cars account for more than half of the emissions from this sector.
Automotive industry concerns
The Alliance for Automotive Innovation, a trade group representing several auto manufacturers, classifies the proposed emissions standards as unreasonable and identifies the following concerns:
- The EPA’s proposed rule is “neither reasonable nor achievable in the timeframe provided.” The standards call for 67% of all new vehicle sales in 2032 to be battery-electric vehicles (BEVs). Sales of BEVs in 2022 accounted for only 6% of all light-duty vehicles. The EPA’s standards can’t be met without substantially increasing the cost of all vehicles, reducing consumer choice, and disadvantaging major portions of the U.S. population and territory.
- The EPA’s proposed rule is a “de facto battery electric vehicle mandate.” Taken together, the proposed GHG and criteria pollutant standards are “so stringent” as to set a “de facto battery electric vehicle mandate” for the United States.
- The EPA “leapfrogs” the Biden administration’s own 50% light-duty electrification Executive Order from 2021. The EPA’s proposed standards increase faster than at any time in history. By assuming BEVs alone will make up 60% of the new vehicles sold in 2030 (and 67% of new vehicles just 2 years later), “the proposed requirements leapfrog even President Biden’s ambitious target of 50 percent which included BEVs, fuel cell electric vehicles (FCEVs) and plug-in hybrid electric vehicles (PHEVs) by 2030.”
- The EPA underestimates battery costs and makes unrealistic BEV sales assumptions. The EPA’s rule assumes that in 2029, the combination of cost reductions from installing larger batteries in BEVs and incentives from the Inflation Reduction Act (Sections 30D, 45W, and 45X) results in consumer incentives and battery production tax credits that substantially exceed the battery cost. In other words, the model assumes that batteries will cost automakers nothing. If cost reductions and incentives eliminate the entire cost of EV batteries, it’s no surprise the EPA (outlier) model suggests a massive increase in sales of long-range BEVs. These assumptions aren’t realistic.
- The EPA makes no concurrent requirements to support required EVs or the drivers who must buy them. The EPA’s proposal focuses solely on the sale of BEVs. The agency proposes NO requirements to ensure charging and refueling infrastructure will be available at homes, businesses, public event venues, highway corridors, transportation hubs, or other public locations. Similarly, the EPA doesn’t address the need for battery-critical minerals to power light-, medium-, and heavy-duty vehicles; energy storage systems; lawn and garden equipment; laptops; cellphones; forklifts; and airport services—not just in the United States but also around the world.
Mining for battery materials
Weighing in at about half a ton, EV batteries contain approximately 190 pounds (lb) of graphite, 130 lb of nickel, 90 lb of copper, 60 lb of cobalt ore, 30 lb of lithium, and 400 lb of aluminum, steel, and plastics.
“Mark P. Mills of the Manhattan Institute has done the attendant arithmetic on the amount of mining needed to produce these quantities for a single EV battery,” according to The Hill. “By his estimate, each battery requires the extraction of 20,000 pounds of lithium brines, 60,000 pounds of cobalt ore, 10,000 pounds of nickel ore, 2,000 pounds of graphite ore and 12,000 pounds of copper ore.
“This tally excludes three to seven tons of what is known as the ‘overburden’ for each ton of ore — that is, ‘the materials first dug up to get to the ore.’ It also excludes the environmental burden involved in extracting and refining materials to produce the steel, aluminum and other less uncommon materials that go into EV batteries.”
The minerals needed to produce batteries aren’t without limits. And, as demand increases for a limited supply, costs for those minerals will increase.
“Proponents of a massive shift toward EVs have attempted to avert attention from this central reality of mineral needs. This does not bode well for policymaking. EVs are expensive — on average about $20,000 more than their conventional counterparts — and will become more so,” The Hill continues. “Direct purchase subsidies in the U.S. are subject to several conditions; far from reducing costs, they merely shift them onto taxpayers. The indirect subsidies take the form of higher prices on conventional vehicles, the inexorable implication of the mandated market shares for EVs. And EVs’ operating costs do not differ by much from those of conventional vehicles, once depreciation is included in the cost comparison.
“The very fact that massive subsidies are needed to make EVs even marginally competitive suggests that the lack of enthusiasm on the part of consumers is no accident. EVs cannot satisfy a wide range of consumer needs, and they also create their own set of environmental problems.”
Charging power
“Using sales projections from the EPA and industry analysts from 2022 through model year 2032, the AP calculated that Americans will likely buy roughly 60 million EVs,” the Associated Press says. “With 284 million passenger vehicles on U.S. roads today, at that pace only about 22% of them would be electric in nine years. Two million are already in use, and vehicles now stay on the road for an average of 12.5 years.
“Dave Cooke, a senior vehicles analyst for the Union of Concerned Scientists, said that even with slow vehicle turnover, studies show the EPA’s proposal would be an important step toward a zero-carbon transportation system by 2050,” continues the Associated Press. “In addition, power plants that fuel EVs, he noted, will be converted to renewable energy such as wind and solar.”
“We know that EVs provide a compounding benefit as we dramatically cut [electric power] grid emissions,” said Cooke, whose group is calling for more stringent emissions standards than the EPA is currently proposing.
Understanding home charging station power
Another glaring problem for consumers in adopting BEVs is the power to charge the vehicles at home. There are two types of home charging stations:
- Level 1: plugs into any standard 120-volt (V) wall outlet. These types of chargers generally take 20 hours for the ability to travel 124 miles.
- Level 2: requires 240-V outlets and allows for faster charging.
Older homes typically only have 100 amps of service, and Level 2 charging stations require 200 amps of service. According to Forbes, installing a new power panel is costly—$5,000 or more, which is a price that’s likely out of reach for low-income households.
However, it may be possible for many to convert to BEVs without installing a Level 2 charging system.
“How can you get away from it? The answer is that while it’s nice to have enough power to recharge a car from zero to full in one night, you don’t actually need nearly that much,” Forbes says. “The average car is driven only 40 miles/day. … [Level 1 chargers] deliver 40 miles in an 8-hour overnight charging session. … On the days you drive more, you won’t recharge fully, but as long as you don’t keep doing long days several days in a row, you will eventually make it back. (How quickly depends on whether you must limit charging only to off-peak electrical times.)”
People with longer commutes will have to have 200-amp service, which is standard in newer homes and will only require the addition of a new circuit for the 240-V Level 2 charger.
Conclusion
“The reality, however, is that the proposed rule has little to do with ‘pollutants,’” according to The Hill. “Instead, it is an attempt by the administration to force an economy-wide transformation away from conventional cars and trucks in favor of EVs. This is a complex policy nostrum, poorly thought through and replete with adverse consequences that proponents are determined to ignore. The harsh realities of EVs are the reason regulatory agencies have tried so hard to force ever more such vehicles upon the market in ways insulated from democratic accountability.”
Politics aside, there are many contradictory statements about transitioning to EVs, such as:
- Charging EVs will/won’t collapse the power grid.
- EVs will/won’t lead to massive unemployment for autoworkers.
- Mining for battery minerals and battery disposal will/won’t create more pollution than it eliminates.
“Transitioning to electric vehicles and renewable energy to combat climate change are valid goals in themselves,” says IEEE Spectrum. “Drastically reducing our fossil-fuel use is key to realizing those goals. However, attempting to make such transitions at scale in such a short period is fraught with problems, risks, and unanticipated consequences that need honest and open recognition so they can be actively and realistically addressed. Going to scale means not only manufacturing millions of EVs per year but supporting them from recharging to repair. A massive effort will be needed to make this happen.”