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One of the persistent challenges of deploying plug-in vehicles has always been metrics: how to evaluate, regulate, incentivize and talk about them to the general public. It's complicated enough transitioning consumers from thinking about miles per gallon to miles per kilowatt hour, particularly for vehicles that refuel via both plug and pump. And within this new language, regulating automakers requires a different dialect than marketing or consumer education, to say nothing of different agency priorities: curbing emissions, reducing petroleum use, protecting public health and so on.

Given the inherent complexity, the impulse to pick one definition or metric for these vehicles and apply it broadly is understandably appealing. But actually doing so creates unintended consequences akin to Maslow's summation that, "if the only tool you have is a hammer, every problem begins to resemble a nail". Such is the case with California's SB 535, which passed earlier this month and will allow plug-in hybrids (PHEVs) and extended-range electric vehicles (EREVs) to have High Occupancy Vehicle (HOV) lane access beginning on January 1, 2012. On its face, it's a win – but it's a very nuanced win, and one we ought not get too excited about.

HOV lane access is the single most effective perk we've had for electric vehicles; because the earliest adopters are less price sensitive than mainstream buyers (and have incomes high enough to exclude them from many tax credits usually applied to these technologies), they tend to be moved more by incentives that offer convenience and privilege than by any financial benefits. So, as has been done with both hybrids and battery electric vehicles, it not only makes sense but has been a foregone conclusion that PHEVs would enjoy single-occupant HOV lane access for a few years to encourage early uptake. SB 535 was originally constructed as a more robust version of a similar policy used for hybrids, essentially raising minimum miles per gallon ratings from 45 to 65 and adding the requirement of grid rechargability. However, the proposed regulation was pared back in June to reflect only an emissions-based metric: the California Air Resources Board's "enhanced-ATPZEV" designation. The irony is that in focusing solely on emissions, the bill unintentionally promotes the use of gasoline. (This post continues after the jump.)

2010 Plug-in Prius Prototypes – Click above for high-res image gallery

To be clear, this is not the fault of CARB (I know, I know – it is a rare moment when those words leave these fingers). The agency's purview is to regulate tailpipe emissions and it's metrics and requirements are framed around that alone. And, given California's prioritization on air quality, it's appropriate that an emissions cap would be built into SB 535. However, the true priority of each program or incentive must also be considered and implemented – and the defining feature of these new vehicles is the plug, not the tailpipe. Therefore, it's a problem that a policy meant to encourage electrification now has no meaningful electrification standard. And the real-world illustration of that problem is the fact that the 2012 Toyota Prius PHV, which cannot operate at what most people consider true highway speeds without burning gasoline (and so, under these conditions, the plug-in Prius is not meaningfully different than the standard Prius) will have access. Meanwhile, the 2011 Chevrolet Volt – which for most people will never use gasoline during the standard commute conducted on those very same HOV lanes – will not.

That General Motors sponsored the bill can only be salt in their wound, but this is not truly about the Volt, since the first generation won't get e-ATPZEV status anyway (GM says it was too difficult). Nor is it about the PHEV Prius, whose drivers will likely still use what electric vehicle capabilities it has, given traffic in much of California. The real issue is using the right metric for the mission at hand. In this case, an emissions requirement should have been the backstop, not the primary goal. Given that HOV access is a freeway-based incentive, SB 535 should have emphasized vehicles that can operate at freeway speeds without using gas, preferably for the length of a standard commute. And as a perk that is meant to move consumer behavior, so much the better that its language that would make sense to consumers in a way that e-ATPZEV never will.

Personally, I'm sorry to see SB 535 pass. Roughly half the number of stickers will be available in this category as there were available to hybrids, and many will go to the least electrified plug-in due out in the next few years. Worse, in its current form, SB 535 leaves our sector ripe for gaming and the media and public backlashes that go with it. Given that it won't take effect for another year and a half, there is little excuse for not having taken the time to reconsider and do it right. I suspect we'll wish we had soon enough. But the only questions now are whether we take that time to revise the policy into something useful, and whether we can help other states learn from California's example. It may be true that all ZEV miles are generally good miles, but that's not the same as all plug-ins being equal, nor that they should be credited and incentivized equally or using the same metric in every case. While it's tempting to go for any political win, it can't be at the expense of the right one. A comprehensive, credible policy framework will be crucial to the successful roll-out of plug-in vehicles, and it will take a lot more than a hammer to build it.

***

Chelsea began working in the auto industry before she was old enough to vote; her work on General Motors' EV1 program was featured in the Sony Pictures Classics film, Who Killed the Electric Car? She led the creation of the Automotive X PRIZE, co-founded Plug In America, and currently runs the Lightning Rod Foundation, through which she conspires with various stakeholders to get plug-in cars back on the road and educate consumers about them. Chelsea is also a consulting producer on Chris Paine's next film, Revenge of the Electric Car.


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    • 1 Second Ago
  • 16 Comments
      • 4 Years Ago
      Normally, I'd suggest that basing regulations on design, rather than performance, is short-sighted and, in the long run, a bad idea.

      This regulation seems to have been written in such a way as to encourage a long-term performance benefit, rather than promote a particular design (technology, as it were) that "might" prove to be soon-obsolete or, at least, not the most effective path to a particular means. Naturally, I should be applauding it.

      However, when it comes to encouraging a nascent change in behavior, I think it's okay to include a particular design/technical component to regulation. In this case, why not include a transitionary (since this law and it's ilk are only temporary, meant to encourage or ease a transition, anyway) rider that encourages a vehicle that travels on the highway on electric power rather than requires internal combustion power to travel at highway speeds (even if it doesn't quite meet the emissions requirement).

      I agree that GM should probably have considered a low-emissions range-extender in place of the engine they plugged in (excuse the pun); In reality, that's exactly what's been "on the table" all along, with interchangeablility of range-extenders part of what was originally referred to as "E-flex" and now goes by the name "Voltec".

      Finally, as an aside, I've worked my whole career for transplant OEMs but I have no problem whatsoever with a domestic OEM gaining an advantage through something like this law. I know, first-hand, that it is absolutely natural (or, frankly, un-natural, given the extent to which governments in other countries will support domestic industry) for a company to have an advantage on the "home-field" of it's domestic market; To not would be a shock and, in fact, would be a dis-advantage of epic proportions. Toyota & Hyundai enjoy such a strong "home-field" advantage that they were able to build profitability at home while building volume here, with little worry about their home market. The true powerhouses in the industry are those that have one cash-machine market to rely upon, nearly without fail, while expanding into other markets. Not all Japanese have that (though it should be noted that Mitsubishi nearly did back in the 1980s and Suzuki nearly does now in Kei-jidooshas, explaining how it can survive here).

      So, no, I figure it's part of the level playing field for a law like this to provide an advantage (and, frankly, inducement) to a domestic like GM (or Ford) in producing a vehicle like a Volt (or PHEV Fusion?)... I encourage it, in fact, despite the fact that I'm "on the other side".
        • 4 Years Ago
        I'm actually very much in favor of performance metrics in this case- just don't think that emissions alone is the right metric in this case. The gas hybrid version of this policy had both emissions and efficiency standards, but we lost the latter in this case.

        In other cases, design standards make a lot of sense- I was a really early proponent of using kWh on board a vehicle as an incentive basis, as was eventually adopted in the federal tax incentive for plug-ins. I like it specifically because it creates a level playing field between serial, parallel and BEV configurations and doesn't place a value judgement on vehicle size- so lets the OEMs make their technological gamble on what they think will sell while still encouraging more electrification across the board. And certainly, kWh could have been used here in place of mpg or EV range- but the main issue isn't that we picked the wrong choice of these, but that none at all got included.

        We have to strike a balance- it's important to allow for the "big tent" in terms of what's available to consumers, and "lightly electrified" vehicles that will likely be cheaper than those with higher range are important to that effort. But we should still preserve limited incentive resources for the better examples of any given technology, and that's the piece that's missing here.
      • 4 Years Ago
      The idea that a Volt would get access even when running on gas is strange to me. But giving it to a Prius or Prius PHEV doesn't make sense either, because they are always running on gas.

      It'll be interesting to see how e-ATPZEV does. Having to put a 15-year warranty on a battery pack may be financially difficult for automakers.
      • 4 Years Ago
      As long as it uses gasoline, I'm a happy camper!
      • 4 Years Ago
      Chels - great article and insight. Thank you!

      For those of you who seem to be missing the point of the article, please re-read this paragraph:
      ++++++++++++++++++++++++++++++++++++++
      And the real-world illustration of that problem is the fact that the 2012 Toyota Prius PHV, which cannot operate at what most people consider true highway speeds without burning gasoline (and so, under these conditions, the plug-in Prius is not meaningfully different than the standard Prius) will have access.
      ++++++++++++++++++++++++++++++++++++++

      How many of you live in CA, specifically Southern CA? I make this distinction because there is a major difference in the way HOV lanes operate in NoCal and SoCal. And how many of you actually commute using the freeways every day? In SoCal, HOV access is a 24-7 proposition, not a part time convenience (or inconvenience depending on your perspective) as in NoCal. Does this make sense? That's a debate for another thread.

      As Chelsea stated above, granting HOV access to single driver is a major incentive in our clogged freeway system. Based on summary of SB 535 above, the incentive doesn't fit the "accomplishment" of a vehicle such as the PHV Prius and penalizes EREVs such as the Chevy Volt, which is leading the way for other EREVs. FYI, I lived w/ 100% electric MINI Cooper (MINI E) for 3 months and 2,500 miles in 2009.

      Did GM take shortcuts with Volt's current generator? Probably. Should GM be rewarded for being in the forefront of the EREVs? ABSOLUTELY.

      A clean sheet designed generator that uses diesel fuel for source of power would have been a better solution, efficiency wise. But here's the kicker - the Volt will hopefully be the vehicle that bridges the gap between ICE vehicles and pure EVs. And as a "bridge" vehicle, gasoline is still more convenient choice for most American drivers. Having owned a 2009 Jetta TDI for 22k miles (and real world 38MPG average), I can tell you unequivocally that I've yet to encounter a female driver fueling a diesel vehicle. And why the discrepancy? As much as diesel powered vehicles have improved, handling the fuel is still messier than gasoline. I’m not being sexist – just stating my observation based on my fueling experience in LA and Orange Counties for the past 14 months.

      It's a shame we don't have 60 MPG diesel powered MINI Coopers, Volvos, Fiats, etc. in the US, but again that’s a topic for another thread...
      • 4 Years Ago
      I think it is hightime we looked at our priorities and clearly define them.

      My suggestion would be to make HOVs - purely for emission-free vehicles that operate below 25 mph. This would mean NEVs, bikes & electric bikes. They are the best vehicles in terms of resources used - and are completely barred from using our highway system.

      Let us see how "green" the Californians really are ;-)

        • 4 Years Ago
        Would you really want to ride your bike on the highway? With the ability to lane split, but a maximum practical speed of 15-20mph, I just don't see that there would be much benefit to that compared to riding on surface streets.
      • 4 Years Ago
      I'm glad GM failed in this.....that'll teach 'em for trying to manipulate the legislative process. POWER TO THE PEOPLE!
        • 4 Years Ago
        @GoodCheer
        Adding a large battery pack to a fuel cell would not greatly increase the price, as they already have one.
        Fuel cells can't rapidly turn out more power, and so need a large battery pack to provide extra oomph.
        • 4 Years Ago
        I hardly think this is 'power to the people', I see this as one more twist of the (increasingly dull) knife that CARB has been using to force fuel cells onto the market rather than EVs.

        At every possible turn they have promoted regulations that make the path smoother for fuel cells, and this is just another of those: Adding a battery pack to a FCHEV that is big enough to get any benefit from plugging in would just add another $5-10,000 to an already prohibitively high price.
      • 4 Years Ago
      Agree or Disagree, I appreciate Chelsea's clear explanation of a complex issue. Without her, I don't think I would have even understood this.
      • 4 Years Ago
      I agree that legislation should always spell out the goals clearly; and basing this on ONLY emissions is a bummer.

      But I don't think the law is really that awful. If I understand correctly, the argument is that a Volt goes farther on electricity than a plug-in Prius, so it's a shame that the Prius will get HOV access but the Volt won't. Right? (Let me know if there's more to it than that).

      First, if the law doesn't take effect for another year and a half, the Volt could be certified by then.

      Second, while the Volt will probably generally burn less gas, it might not always be so, especially with freeway commutes which, as you note, are the issue. Of course it depends on what mpg the Volt gets after the 50 miles is gone, but one recent unofficial report said 32mpg. If three neighbors have a regular Prius, a plug-in Prius, and a Volt and they all commute on the highway to the same job 50 miles away, and can't plug in at work, then at the end of the day the Prius will have used 2 gallons of gas, the plug-in Prius 1.75, and the Volt 1.875. Conclusion: why don't they carpool?

      I'm not arguing the exact Volt mpg numbers (I don't have them, but I hope to see them soon!), nor am I arguing that's a typical case and/or that the Prius is better than the Volt. I'm just arguing that plug-in Prius getting HOV access but not the Volt is not necessarily a horrible thing that's going to burn a lot of extra gas. It all depends on who's driving, when they charge, how far they go...overall I suspect the difference will be small.

      I still agree that there is still time to make the legislation better, and I would like to see that happen.
      • 4 Years Ago
      Smells of green-whining.

      I'm perfectly fine with PHEV's getting HOV access along with electric cars. They are prefectly valid low-emissions solutions, especially for apartment owners. It sounds like GM needs to get the Volt e-ATPZEV approved, not that CARB needs to write laws to carve out a hole for GM.

      To me this sounds like someone who wants to buy a Volt taking out their frustrations on CARB for GM not certifying it to e-ATPZEV. Go talk to GM if you have a problem with their refusal to spend the money to certify it to e-ATPZEV (or if the Volt just can't pass that certification).

      Does anyone actually know of a car that WOULD qualify for this program that really shouldn't. As opposed to this sort of kindergarten-style "my green car is better than your green car" argument?
        • 4 Years Ago
        paulwesterberg:
        Teslas get carpool lane access.
        • 4 Years Ago
        I agree, the volts range extending engine is too large and inefficient at only 35ish mpg to meet e-ATPZEV standards. GM cut corners on the range extender and chose to reuse an existing vehicle engine rather than designing a smaller more efficient power-plant specifically to meet the needs of the volt.

        If carb carved out an exemption for this type of vehicle then fiskers ferrari and porsche would all sell HOV approved vehicles with V6 or V8 range extenders that use their serial hybrid drive-train to provide just 25-30mpg.

        Where is the outrage over tesla roadsters without HOV access? Wheres the love for the raceway capable electric vehicle made in kahleefonyah?
        • 4 Years Ago
        "green-whining"

        No kidding. GM lawyers wrote and promoted legislation to carve out a hole for their hybrid for HOV use because it did not qualify as an EV under the law (EV's have HOV access). Then because GM lobbyists didn't talk to GM engineers (they probably assumed the car would match Prius emissions) the car doesn't qualify for the special incentive they spent untold dollars lobbying to have carved out for it. People should be mad at GM for being so incompetent rather than getting upset with the government of California for passing legislation sponsored by GM.
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