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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