To make significant money, we all know that we have to get a job. But if we just need a small bit of money (say to tip the paperboy), we might meet our goal by looking under the sofa cushions for a bit of loose change.
It turns out that the same is true for the EPA’s 2025 challenge of reaching 54.5 mpg for personal vehicles. Mostly car companies will need to do the hard work of improving the efficiencies of engines and transmissions, lightweighting the vehicles, adding hybrid technologies, adding some diesels engines to the mix, etc. But in the equivalent of loose change under the sofa cushions, the EPA has created something called “off-cycle” credits.
The EPA recognizes that not everything that improves efficiency shows up in their standard “2-cycle” fuel efficiency test used for CAFE. So they have created these special “off-cycle” credits for car companies to encourage these valuable efficiency improvements that are not adequately represented in the test.
Before getting into the credits, there is a big of jargon to get through. It turns out that the EPA doesn’t develop its rules in terms of mpg, but it uses grams of CO2 emitted per mile. The goal is to get vehicles to emit much fewer grams of CO2 per mile by 2025. The specific target depends on both the size of the vehicle (so-called footprint) and whether the vehicle is a car or a truck. The lowest target is for small cars (think Honda Fit) which must achieve 144 grams of CO2 per mile. Compared to the goal of 144 gCO2/mile, the off-cycle credits are small, say 1 or 2 gCO2/mile, but every little bit helps when trying to reach a goal.
The final rules are contained in document 2012-21972.pdf which is a massive 578 pages. There is some additional insight into this process in a document called AllianceCommentson2017NPRMFINAL2.pdf where the Alliance of Automobile Manufacturers are commenting on proposed EPA regulations.
The list of “off-cycle” credits includes.
A/C Improvements: A/C can be made more efficient by reducing blower speeds and evaporator temperature and this can significantly improve gas-mileage in a way not reflected in the 2-cycle testing. These credits can be up to 5.0 gCO2/mile for cars and 7.2 gCO2/mile for trucks.
High Efficiency Exterior Lighting: Energy can be saved in vehicles by switching from incandescent bulbs to LED technology. If the manufacturer can reduce electricity consumption from the bulbs by 100 watts, they will be rewarded with a credit of 1.0 gCO2/mile. These lights include the high and low beams as well as the parking/position, tail, and license plate lights.
Waste Heat Recovery: Most, perhaps more than 65%, of the energy in gasoline is converted to waste heat rather than useful work. If that heat energy could be recovered using either a thermoelectric technology or rankine cycle technique, the overall efficiency of the vehicle would improve. As of yet, no commercial systems have been developed. But if a system could be developed that recovered 100 watts of power, the vehicles manufacturer would be rewarded with at 0.7 gCO2/mile credit. A 200 watt system would produce twice the credit.
Solar Panels: OK, so we all know that it is impractical to try to run an EV off of vehicle mounted solar panels, because they are too small. But that is not to say that they don’t have some value. The EPA figures a 75 watt solar panel is worth 3.3 gCO2/mile when used to charge the battery and 2.6 gCO2/mile when combined with cabin ventilation.
Active Aerodynamic Improvements: These are technologies like active grille shutters and active air dams. If the technology can reduce Cd by 3% in cars, a 0.6 gCO2/mile credit will be awarded or a 1.0 gCO2/mile credit on trucks. If, by some miracle, the technology can provide 20% improvement, up to 7 gCO/mile in trucks will be given.
Engine Start/Stop: Vehicle manufacturers have long complained that the value of Start/Stop technology is not adequately reflected in the EPA mpg Window Sticker, and that is likely to continue to be the case. But at least the technology will be given some credit in the CAFE calculations. That credit will be 2.5 gCO2/mile for cars and 4.4 gCO2/mile for trucks when start/stop is combined with an electrically driven pump that can keep heat flowing to the passenger compartment with the engine stopped. If no pump exists, the credit is worth 1.5 gCO2/mile for cars and 1.9 gCO2/mile for trucks.
Active Transmission Warm-up: Cold oil in a transmission, differential or transfer case significantly reduces vehicle efficiency, particularly on short trips. Technologies exist to transfer waste engine heat to these driveline components to accelerate their warm up and allow them to operate more efficiently. Credits of 1.5 gCO2/mile for a car or 3.2 gCO2/mile for trucks are available.
Active Engine Warm-up: Other technologies can be used to actively warm the engine up more quickly and get credits of 1.5 gCO2/mile for cars and 3.2 gCO2/mile for trucks.
Thermal Control Technology: Additional credits are available to keep passengers comfortable in ways that reduce air conditioning loads: improving window glazing up to 2.9 g/mile, active seat ventilation 1.0 g/mile, solar reflective paint 0.4 g/mile, passive cabin ventilation 1.7 g/mile, and active cabin ventilation 2.1 g/mile for cars. Truck credits are 3.9, 1.3, 0.5, 2.3, and 2.8 respectively.
All these credits together are not allowed to exceed 10 gCO2/mile, which for a 144 gCO2/mile small footprint car would represent about 7%.
So these off-cycle credits will never be a huge factor in meeting the CAFE goals. But just like a little change from the sofa cushions can help you out on occasion, these off-cycle credits might be just what the car companies need to meet some of their CAFE goals.
Postscript: There are some additional interesting programs listed where the EPA deviates from a “merit” based argument to a more pragmatic argument. The EPA clearly sees some technologies as winners despite their frequent claims to be technology neutral.
One of the more interesting programs is called “Advanced Technology Incentives for
Full-Size Pickup Trucks” where the EPA wants to encourage hybridization of “full-size” pickups early on in the 2017-2025 program. They see early deployment of this technology as key to its development and introduction to the marketplace. The EPA lists hybridization of trucks as a “game changing” technology.
If truck manufacturers implement “mild hybrids” in at least 20% of their full-size pickup trucks starting in 2017, they will be rewarded with a 10 gCO2/mile credit. For “strong hybrid” implemented in at least 10% of their full-size pickups starting in 2017, there is a 20 gCO2/mile credit.
Call me skeptical, but if Ford, Dodge, or GM was planning on using this incentive requiring 10% or 20% or full size pickups to be hybrids in 2017 (3 short years away), I would expect to see some “concept” vehicles showing up at auto shows with hybrid technology. In July, Ford claimed that they would produce a hybrid F-150 by 2020, only one year before the credit expires. So I suspect this offer will be left on the table by the truck makers.
One other interesting policy is that vehicles that are EVs/PHEV/FCV/CNGV get credit for more than one vehicle with an “Advanced Technology Volume Multiplier”. EVs and FCV get 2 credits starting in 2017 phasing down to 1.5 in 2021. PHEV and CNGV get a multiplier of 1.6 in 2017 phasing down to 1.3 in 2021.
EPA claims to be “technology neutral” in their pursuit of better fuel economy and lower GHG emissions. That seems to be true of much of their policy making, but there are some glaring examples of “technology preference.”
1) EVs don’t need to account for upstream GHG emissions (ICE don’t either, but their upstream CO2 emissions are much lower than for EVs powered by a mix of grid electricity).
1) EVs don’t need to account for upstream GHG emissions (ICE don’t either, but their upstream CO2 emissions are much lower than for EVs powered by a mix of grid electricity).
2) Full size pickups can get special credits for hybridizing their vehicles.
3) EVs get counted twice which is especially biased because they are counted a 0 gCO2/mile vehicles.
Personally, I tend to agree with these EPA rules that encourage technology that I believe is the key to increased energy security and lower emissions. However, I don’t see how the EPA can make the case that these programs are technology neutral.
But with the EPA allowing each EV sold to count as two 0 gCO2/mile vehicles, there would seem to be a significant incentive for the car companies to produce EVs.
