First Name | Loren |
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Last Name | Marz |
Email Address | lmarz@charter.net |
Affiliation | |
Subject | Comments on LEV III Proposed Regulation |
Comment | While fully supporting the spirit of the proposed LEV III Regulation, it doesn’t appear that the impacts of a significant shift to “ZEV” technology such as electric vehicles (EV) have been fully considered. According to a National Academies report (National Academies, "Hidden Costs of Energy: Unpriced Consequences of Energy Production and Use.")... "...Electric vehicles and grid-dependent (plug-in) hybrid vehicles showed somewhat higher nonclimate damages than many other technologies for both 2005 and 2030. Operating these vehicles produces few or no emissions, but producing the electricity to power them currently relies heavily on fossil fuels; also, energy used in creating the battery and electric motor adds up to 20 percent to the manufacturing part of life-cycle damages...." This is supported by the latest version of Argonne National Laboratory’s GREET model (GREET1_2011 - http://greet.es.anl.gov/) which shows that WTW emissions of particulate matter (PM) in California are higher for EV technology than current "clean diesel" technology. Based on the default "mid-sized" vehicle assumed in GREET for the year 2020... WTW PM10 (diesel) = 0.004 (Feedstock) + 0.009 (Fuel) + 0.030 (Vehicle Operation) = 0.043 g/mi WTW PM10 (EV) = 0.060 (Feedstock) + 0.006 (Fuel) + 0.021 (Vehicle Operations) = 0.087 g/mi WTW PM2.5 (diesel) = 0.003 (Feedstock) + 0.005 (Fuel) + 0.016 (Vehicle Operations) = 0.024 g/mi WTW PM2.5 (EV) = 0.015 (Feedstock) + 0.004 (Fuel) + 0.007 (Vehicle Operations) = 0.026 g/mi All of these values are based on the California electric generation mix assumed in GREET in 2020. Exhaust PM from the diesel vehicle assumed in GREET = 0.009 g/mi (PM10); 0.0084 g/mi (PM2.5). Furthermore, based on certified emissions of the 2003 VW Jetta TDI (example of an "old tech" diesel vehicle), exhaust PM emissions = 0.05 g/mi (http://www.arb.ca.gov/msprog/onroad/cert/pcldtmdv/2003/volkswagen_pc_a0070228_1d9_1_diesel.pdf). 0.05 - 0.009 = 0.041 g/mi more exhaust PM for the "old tech" diesel than that assumed for "clean diesel" in GREET. 0.043 g/mi + 0.041 g/mi = 0.084 g/mi WTW PM10 for the "old tech" diesel car, actually less than the 0.087 g/mi WTW PM10 calculated by GREET for EV in California for 2020. "Old tech" diesel vehicles have been effectively banned for many years under LEV II regulations, to the Air Resources Board's credit, yet mandates are being proposed for vehicle technology (e.g., EV) which may actually increase PM emissions from a WTW perspective above "old tech" diesel engine technology. EPA acknowledges in the Draft RIA for the Proposed Rule to Extend the National Program to Reduce Greenhouse Gases and Improve Fuel Economy for Cars and Trucks - Docket ID No. EPA-HQ-OAR-2010-0799, that all PM2.5 is treated as equally potent in causing premature mortality regardless of source (page 6-35 of the Draft RIA), even specifically mentioning PM2.5 from diesel engine sources. So there appears to be no valid reason from a public health perspective to displace the reduction in PM2.5 emissions from diesel engines with increased PM2.5 emissions from power plants to support EV/PHEV technology. The regulatory push for these "advanced technologies" defies logic from an emissions perspective. A massive shift to EV/PHEV technology would potentially offset gains made from diesel PM emission reduction mandates. It appears superfluous to propose significant reductions in PM emissions from gasoline/diesel vehicles under LEV III to trivial levels (which I support) yet essentially mandate technology which not only doesn’t decrease WTW PM emissions from current technology, it increases WTW PM emissions with respect to pre-2004 (Tier 1) diesel vehicles. I would like to state unequivocally that I support EV/PHEV technology for certain niches (e.g., urban commuter travel), but upstream emissions of this technology really need to be taken into account. As a disclaimer, I am in no way associated with the auto industry or any support industries to the auto industry, including diesel engine manufacturers. Thank you for your consideration of these comments. Respectfully submitted, Loren Carl Marz, Certified Consulting Meteorologist (#591) |
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Date and Time Comment Was Submitted | 2012-01-23 11:01:37 |
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