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Regulate the Results, Not the Technology

Posted in Environment by erichard on the May 30th, 2007

by Eric Richard

One of the threads we’ve seen a couple of times recently has been the notion that regulators should focus on setting specific performance targets through regulations rather than regulating specific implementations.

For example a few months ago, we heard of plans for various governments to ban the sale of incandescent light bulbs, and then only weeks later the incandescent lightbulb manufacturers announced plans to produce super-efficient lightbulbs that would be better than existing CFLs.

If this really is the case, there is no reason to ban incandescents. The ban should really be based around the performance of the bulbs. Ban any bulb that takes requires more than a certain number of watts to produce a certain number of lumens. Then, let the innovators figure out which technologies make the most sense.

Anyway, I saw an interesting article recently that made me think of this debate again.

Specifically, the article deals with the types of cars that are allowed to use HOV lanes.

As you probably know, high occupancy vehicle (HOV) lanes (more commonly known as carpool lanes) are generally set up to encourage people to behave in ways that reduce traffic by carpooling.

It turns out that in 2005, Congress modified this definition slightly when they passed the “Safe, Accountable, Flexible, Efficient Transportation Equity Act: A Legacy for Users Act.”

(Note the acronym: SAFETEA. I really wonder how long they spend coming up with cute acronyms like this!)

In this act, they recognized that reductions in pollution could also be encouraged through the HOV lane and, to that end, they added exemptions to HOV lane usage for hybrid vehicles.

This was designed as a “perk” to encourage drivers to consider purchasing hybrid vehicles.

If you look at most of the press coverage of this proposed change, it tends to focus on making the regulations stricter to ensure that only truly fuel efficient cars could use the HOV lanes:

“For the driver of a hybrid to qualify for HOV lanes during peak time, hybrid vehicles would need to achieve 25 percent higher combined fuel efficiency for city and highway driving compared with similar gasoline-fueled vehicles.”

At first blush, this seemed totally reasonable and would close a previously existing loophole. Specifically, just because a car is a hybrid doesn’t necessarily mean that it meets the fuel efficiency standards that would justify the use of the HOV lane.

For example, according to the article above, “Some of the vehicles that would not qualify include the luxury Lexus GS450h Hybrid, DaimlerChrysler AG’s Dodge Ram Hybrid and General Motors Corp.’s Saturn Vue Greenline Hybrid.”

This seemed perfectly reasonable to me. You shouldn’t just get a free pass just because you have a hybrid; you should have to have reasonable fuel efficiency.

But, then, as I looked deeper, I saw something a little silly.

According to the EPA’s regulatory annoucement about the new proposal, in order for cars to qualify they would need to “meet the specifications for both low emission and energy-efficient”. Ok, that seems reasonable. But, what do each of those things mean?

Again, according to the EPA, to be considered “low emission”, a vehicle would “have to be certified to either the federal Tier 2 bin 5 (or cleaner) or California LEV II emission”. Fine. That seems totally reasonable.

And do be considered “energy efficient” a vehicle would have to be:

  • “A dedicated alternative fuel vehicle, or
  • A hybrid vehicle achieving 50 percent or better in-city fuel economy or 25 percent or better in combined city/highway fuel economy compared to a similar gasoline fueled vehicle.”

Here’s where I think they went wrong.

Energy efficient is energy efficient, regardless of how you achieve it. Why stipulate that the vehicle has to be a hybrid or other alternative fuel vehicle?

There are several 100% gasoline fueled cars that get close to 40 mpg today. Small cars like the Honda Civic, Mini Cooper, Kia Rio, and Hyundai Accent all get around 40 mpg on the highway. And you have new cars like the smart fortwo that is expected to get over 40 mpg when it is available in the U.S.

So, why limit this to hybrids and other alternative fuel cars? It seems like the performance standard in the regulation is perfectly fine. In fact, the way the regulation is currently stated, as the overall efficiency of cars goes up, the bar will get higher and higher for cars that meet this threshold which seems like just what you’d want.

But, that one little glitch about specifying the technology seems like its going down the wrong road. As much as I love my hybrid, there’s nothing inherently good about a hybrid. If a non-hybrid can produce the same emissions and the same fuel efficiency, good for it!

Seems like they were so close to getting this right, but took one wrong turn at the end.

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An Inconvenient Book

Posted in Environment by erichard on the May 24th, 2007

By Eric Richard

Last week, Al Gore published a new book called The Assault on Reason.

I have not read the book yet, but I have read a few excerpts and I have to say that purely speaking as an environmentalist, I am a bit sad about this book.

One of the things that Gore has been able to do over the past few years has been to really help bring the entire global warming movement to the mainstream. He helped take this from being a liberal Democrat issue to an issue for everyone. I think the most recent statistics I’ve seen have shown that something like 70% of Americans now believe that global warming is real, that it is man-made, and that we have to do something about it.

While I don’t know the numbers, my suspicion is that there has really been a large shift in those numbers over the past couple of years and I would put quite a lot of the responsibility squarely at his feet.

Now, part of why Gore has been able to succeed is because he has largely transcended partisan politics. He stopped being the former Democratic Senator from Tennessee or the former Democratic VP and started becoming the man the first President Bush called “Ozone Man”.

Clearly during the peak of the fever surrounding An Inconvenient Truth, lots of people tried not to let Gore escape politics and ascribed political motivations to him like, “This is just so he can run for President again.”

I think it actually helped the credibility of Ozone Man when Gore repeatedly denied over and over and over again that he was not going to run for president.

With all of that in mind, I think that Gore, the champion of the environmental movement, has really done a disservice to that side of his personality through this book. I think it brings him smack dab into the middle of partisan politics and will allow people to dismiss all of his arguments as being all about liberal issues.

Just to be clear, I am not saying that these things don’t need to be said. But, I think that this was a real missed opportunity for Gore and the environmental movement.  I think it would have been better if someone else said these things and if Gore kept out of the fray on issues like Iraq or national security.

I would have been much happier if this book was a follow on to An Inconvenient Truth taking all of the star power he’d gained and continuing to focus that on the environmental issue.

Hopefully I will be proven wrong, but I worry that Gore has just brought himself back to the land of the mortals with this book and, in that process, may undo some of the great work he’s done around bringing environmentalism to the mainstream consciousness.

Has anyone else read this book yet?  Are my fears warranted?

Debunking Another Misleading Site

Posted in Environment by erichard on the May 16th, 2007

by Eric Richard

A few days ago, one of the mailing lists I am on sent out the following URL and asked if people had seen it or had comments on it:

http://www.geocraft.com/WVFossils/GlobWarmTest/start.html

If you go to it, you can see that it challenges you to “test your knowledge and common sense” with a 10 question “Global Warming Test”. And, from the get go, they warn you that this is a “No Spin Zone” with the following note: “This section contains sound science, not media hype, and may therefore contain material not suitable for young people trying to get a good grade in political correctness.”

The quiz then walks the user through a set of 10 questions about global warming and lets them know whether they got each answer right or wrong with a detailed explanation of each including numerous citations to support their argument.

I have to admit that the author of the quiz knew what they were doing. I don’t think they ever outright lied. They certainly mislead and obscured and misrepresented. But never did they outright lie. It is what Al Franken would call “weasel-words”.

Anyway, one of the other readers on the mailing list went through the quiz question by question to debunk each of the questions and explain how they are misleading. I figured it would be useful to get this analysis up in case anyone was interested in understanding the tactics used by the opposition or in case you are ever forced to explain why this site is hooey.

Oh, in case you were wondering, the website is hosted by Monte Heib, Chief Engineer, West Virginia Office of Miners Health, Safety and Training. He is not a climate scientist, but a mining engineer in ‘coal country’. Big coal rears its ugly head again.

Anyway, feel free to take the quiz and follow along with the question-by-question debunking below. Special thanks to Lisa Alexander, chair of the Watertown Environment and Energy Efficiency Committee, for this great analysis.


I took the test. I will say it is very carefully worded and quite subtly deceptive and well designed to mislead the naive minded. I answered all the questions correctly except one (which, actually, I could have answered “the skeptic” way, but when got “wrong” answer, got lot of charts and graphs and explanations about why I was “wrong”)… The “scientists” quoted include Richard Lindzen (known skeptic) and Pat Michaels (twice - so probably this was produced by American Coal - I think he’s their guy - can easily find out on www.heatisonline.org.)Here’s my comments on the questions:

#1 about the “increasing” temps since 18000 years ago, conveniently leaves out last ice age (ended 12000 years ago) and the “mini” ice age (which it later notes) which started around 1300 AD when the St. Lawrence ice dam broke and a lot of water rushed into upper Atlantic (think about Gore movie) and Gulf Stream slowed down. It has NOT warmed continuously since 18000 years ago. And yes, sea level is higher now that all the ice is melted, but there was a mile or two of ice on top of northern US in the ice age. All very deceptive with the use of strategically selected facts.

#2 GH effect (atmosphere) makes earth liveable, else would be too cold (like Mars), yes, that is true, but too much of a good thing (CO2) is still too much. 30,000 people plus died in Europe a couple summers ago due to all that heat, and more in India. I’m sure it was only “a few degrees” above normal - esp. if you calculate in centigrade.

#3 this was the one I got wrong - but they talk about natural cycles and variations… about sunspots, etc., but we have sunspots about every 11 years (solar cycle as I recall from astronomy classes), and they again left out ice age 12000 years ago and mini-ice-age etc.

#4 water vapor as most abundant greenhouse gas - yes, true, but warmer atmosphere makes it possible to hold more humidity thank you very much Dr. Michaels (who they quote here). He then goes onto say that “wetlands” produce more global warming gases - well, yes, they do - but it’s because of METHANE in wetlands, not WATER vapor - and methane being stronger warming potential.

#5 They talk about the less than 1 degree centigrade rise…well yes, but 1 degree F is even smaller and all it takes is ONE to go from ice to water if you’re already at 32 degrees F. That’s another deceptive argument, trying to minimize reality. I thought it was interesting that he said we’re at the same temps as in the 1930s - great - does that mean we can expect another dust bowl and decimation of crop lands?

#6 El Nino - yes, that not “caused” by global warming, but it is certainly EXACERBATED by global warming as it is caused by variations in ocean temps. And the warmer it is, worse it is, worse the hurricanes are.

#7 No, CO2 from anything, coal, etc., does not “damage” plants in forests - but acid rain certainly does, and mercury fallout makes fish unsuitable to eat hundreds of miles from the source of the coal burning… additionally, while more CO2 does make a “bigger” plant, the nutritional value of that plant is so poor that bugs living right on them and eating them have been shown to STARVE to death. Bigger is not always better.

#8 Chart question here is interesting (graph of middle age warming and mini ice age) because the multiple choice answers only leave you one that can be answered right - but that answer misses the fact that, again, that “cooling” c. 1300 AD was totally disruptive, was result of melting of ice dam from Great Lakes through St. Lawrence seaway that “shut down” Gulf Stream… lot of people died during those years and there was lot of disruption to society caused by famine for many years.

#9 Ah yes, the usual suspects getting quoted again - Lindzen, Michaels, Van Doren, Wallop and Santer - all getting nice payments of $10,000 per paper probably from Exxon/Mobil for their “research”… well, even Rupert Murdoch is finally conceding that we need to do something now so I wonder how much longer these clowns will have much say. Again, www.heatisonline.org is great source to find out more about them.

#10 Another quote by Pat Michaels. I forget the question now, but two quotes from him, and a few questions about coal - pretty likely that this was produced by some American Coal Lobby or whatever.


Prius vs. Hummer Analysis Debunked

Posted in Environment by erichard on the May 12th, 2007

by Eric Richard

Many people have seen or heard about the articles going around that say that “owning a Hummer is better for the environment than owning a Prius.” This all stems from the report called “Dust to Dust” and a follow on commentary called “Hidden Cost of Driving a Prius” by CNW Research. This report then seems to have gotten legs when a column was run in The Recorder, the paper for the Central Connecticut State University.

I think for most of us, our initial reaction was, “Hmmm… That sounds odd. I wonder how they came to that conclusion?”

For those who dug a little deeper, you found that, one of the most controversial aspects of this report is that it assumes as lifespan of 100,000 miles for the Prius and a lifespan of 300,000 miles for the Hummer. This winds up having immense implications on the rest of the analysis since it basically means that you need to buy 3 Priuses to travel the same distance as 1 Hummer. So, the real analysis says that “owning a Hummer is better for the environment than owning three Priuses.”

Since this is the most glaring issue that gets raised by this report, the folks at CNW Research have put out a paper called “Why 100,000 Miles for Prius?” that explains the rationale for this figure.

Reading this document is quite fascinating and I think points to the ludicrousness of the Prius vs. Hummer analysis.

If you read through their document, they basically make the point that Priuses have a shorter lifespan (in miles driven, not time) for the following reason: People who drive Priuses (especially people who drive first generation Priuses) drive less than people who drive other cars.

Yup! That’s the real problem. Confused? Read on.

The key point here is that this is a factor of the people’s driving habits and not of the car itself. This basically says that if you were already inclined to drive small amounts, then you are inclined to buy a Prius. If you were inclined to drive large amounts, then you wouldn’t be inclined to drive a Prius.

This is all probably completely true. But, how does that affect the analysis?

Well, if you start with the assumption that Prius owners only drive ~7,000 miles per year, then you can do the math and figure out that it will take about 15 years for that driver to get to 100,000 miles on the car.

And then you ask the question, “Is someone likely to keep the car for more than 15 years?”. Since the answer is no, you thus put the “effective” lifespan of the car at 100,000 miles. Not because the car couldn’t go further, but because the person didn’t drive it more.

Let me just restate that to be clear. The report is not saying that Priuses can only drive 100,000 miles. In fact, the report makes absolutely no statement on how far Priuses could be driven. What the report says is that Prius drivers tend to drive so little that by the time they’ve driven 100,000 miles, they are likely to get rid of their car.

Just to drive this point home, if that same car owner traded in their Prius for a Hummer, you’d make the exact same argument about the Hummer; you’d say that it had a life expectancy of 100,000 miles.

Or, looked at from the other perspective, the report says:

If the Prius were driven the American average of 13,000 miles per year, it would hit the 100,000 mile mark in 7.6 years, well within its attractive (financially and technologically) useful life span. In 10 years, again about the maximum for ground-breaking technology, it would have registered 130,000 miles. Mechanically, there is no logical reason for the Prius not to last 130,000 miles or more.

In fact, the report goes on to say that, “The latest data shows Prius owners are driving more than early Prius owners and the use of the vehicle is becoming a primary means of transportation in a household rather than a novelty,” although it does say that “the average annual mileage, outside of certain southern-tier states, remains barely above 7,000 per year.”

As more and more people drive Priuses and use them for mainstream driving, this entire analysis is going to go to the wind. As an example, my Prius is about 3 years old and I am about to hit 60,000 miles. If I drive my Prius for another 3-5 years, I will blow through their numbers.

The report also points out that much of the reason that the Prius fairs poorly compared to the Hummer is that “much of the design, development and manufacturing energy costs [for the Hummer] are spread across more than just this single model. … The platform, power train and other mechanical components are shared with a variety of other GM products and have a significantly longer post-disposal life in the replacement market.”

Again, this was true for the early Prius models. For example, the first generation Prius had special “fuel efficient” tires. But, in the second generation, they replaced these tires with “normal” tires because people wanted better road handling at the cost of fuel efficiency.

In addition, as Toyota installs the hybrid synergy drive in more of their models, the Prius will start to get the same efficiencies as the Hummer.

More than likely, you could make this same claim about the cost of producing any new car or car with new technology. For some period of time, you are experimenting and, thus, the costs are high. But, then once they go mainstream, the costs decrease.

So, looking at this full report, the take away messages are that “Cars based on new technology are more expensive initially than cars based on mature technology” and “When a car has a niche market of environmentally conscious consumers, they aren’t likely to drive a lot.”

That’s pretty much all you can take away from this analysis.

And while the result of this analysis is that first generation Priuses fit into both of these categories, the key point is that both of these arguments are based on a point in time and are changing and neither of these arguments have anything to do with the technology or design of Prius in particular (except to the extent that its design attracted people who don’t drive a lot in the first place).

You could put any car in this same analysis and get the same results if it was based on new technology and people didn’t drive it much.

As people drive Priuses more and as the technology under Priuses become more and more mainstream, the entire underpinnings for this report are going to evaporate and you will ultimately get to the steady state analysis where you can accurately compare the environmental footprint of the Prius to other cars.

Thus, I think it is fair to say that this report is really just a load of hooey and shouldn’t be given any real merit. (Of course, I don’t think any of you were giving it merit, but now you at least know why. =)

P.S., I am happy to see that the folks at CNW Research published this document in response to a “bloggers’ frenzy” over this issue. Of course, that makes it sound like this was all an imaginary issue in the blogosphere, completely discounting the impact of the “Hidden Cost of Driving a Prius” document that they themselves wrote.

Ways to Increase Fuel Effeciency

Posted in Environment by erichard on the May 11th, 2007

by Eric Richard

In the past few days, I have seen articles coming out of the research side of the world talking about technologies that can possibly be applied to the fuel effeciency/emissions problem.

One of the articles talks about redesigning some of the fundamental aspects of how the combustion engine works and another talks about how “intelligent cars” can improve fuel efficiency.

I have no idea if either of these ideas will pan out or how long it would take for these ideas to get to market, but I think that this is exactly the sort of research that the auto manufacturers need to be looking at and the sort of thing that increasing the CAFE standards will motivate.

I thought it was kind of ironic that the second article positioned the debate a “intelligent cars vs. hybrids” as if there was a competition here and our goal is to prove that hybrids are a “bad” solution. When I read the article, my first reaction was, “so, what improvements would you get from having an intelligent hybrid vehicle?”.

While hybrids clearly have received the majority of the glory over the past years, there is no reason to think that they are the end solution. In fact, I think you could make a very strong argument that the real evolution will come with a totally different type of hybrids — hybrids that run on pure battery power for the majority of the driving but have a combustion engine as a “backup” for longer driving. This is the basic idea behind the Chevy Volt.

Anyway, the really exciting and interesting thing will be to watch to see how increased CAFE standards wind up affecting innovation in this sort of area.

Hopefully we’ll see all sorts of hair brained ideas being floated and some of them actually making their way to market.

It’s Time for a Change Redux

Posted in Environment by erichard on the May 9th, 2007

by Eric Richard

One of the common themes on this blog has been a discussion of the Corporate Average Fleet Efficiency (CAFE) Standards. The first post on this was “20 Years Later, It’s Time for a Change” and was followed by “The Dirty Little Secret about Flex-Fuel Cars“.

The common theme throughout these posts was that the CAFE standards were woefully out-of-date and had loopholes that you could drive a Hummer through allowing companies to produce gas guzzlers without having to bear the costs of this against their fleet averages.

It looks like the Senate just made a huge step in the right direction toward fixing this.

Yesterday, the Senate Committee on Commerce, Science, and Transportation voted to pass Senate bill 357, the Feinstein-Snowe “Ten-in-Ten Fuel Economy Act“.

Reading through this bill, I think there are several key items that make this very compelling.

Raising the CAFE Average by 10 MPG in 10 Years

The most notable change required by the bill is that the CAFE averages be raised from 25 mpg to 35 mpg by 2019.

The bill also specifies an intermediary requirement of 29.5 mpg for passenger cards and 23.5 for light trucks by 2010.

In addition, according to the press releases I have seen, the bill also includes a provision to increase in the CAFE standards 4% / year from 2020 through 2030. I cannot find the actual text of this change in the bill itself, but I may just be looking at an older version.

If this was all the bill did, I think we could have a big debate about whether this was enough or not. Many advocates had been hoping for a 40 mpg standard so 35 mpg is shy of that goal.

My general take though is that it is about time that they are finally making changes here and I think that some of the other changes (discussed below) are important enough to justify this 5 mpg gap.

Elimination of the SUV Loophole

Honestly, I think this maybe even more important than the previous section.

As I understand it, the existing CAFE standards basically exempt “work vehicles”. The idea here is that the CAFE standards were not intended to apply to farming trucks or big rigs.

Specifically, “Light trucks that exceed 8,500 lbs gross vehicle weight rating (GVWR) do not have to comply with CAFE standards. These vehicles include pickup trucks, sport utility vehicles and large vans.”

However, this loophole has been massively exploited by the auto manufacturers. Specifically, vehicles like the Hummer and other SUVs were large enough that they were not categorized as “passenger cars” and because of this, the didn’t count against the fleet average.

This basically meant that auto manufacturers could sell more and more of these vehicles without having any impact on their fleet average fuel economy.

The proposed bill eliminates all distinctions between light trucks and passenger vehicles and requires them to both be counted toward a manufacturers fleet average.

I believe this will be absolutely huge in terms of its impact on auto manufacturers and is why I am not so worried about the 35 mpg vs. 40 mpg debate above. If I could choose between a 40 mpg average for all passenger cars but no standard for SUVs compared to a 35 mpg combined average, I think I’ll go for the latter any day.

This will create immediate pain for the auto industry every single time they sell another gas guzzler. This will force them to apply the same fuel efficiency standards to all of their vehicles and improve the worst of the vehicles.

No longer will the worst cars get an exemption.

Onboard Fuel Economy Indicators

One very small element of the bill is that it will require all cars manufactured after 2014 to have “an onboard electronic instrument that provides real-time and cumulative fuel economy data”.

I actually think this will be very valuable. I’ve always wondered how much of the benefit that Prius owners get is because they can monitor and manage their driving patterns. They can learn how their driving patterns affect their fuel efficiency and can change their behaviors to increase their fuel efficiency.

I’ve heard similar stories about home owners being able to dramatically reduce their home electricity usage simply by getting real time monitoring of their electricity usage.

In both cases, it creates a very direct causal link between an individuals behavior and their consumption which allows them to change their behavior. There is a saying that “You can’t manage what you can’t measure” and I think that adding these monitors to cars will help educate drivers.

This is a relatively small item, but I like the idea.

Creation of Fuelstar Program

Another small part of the bill would create a “Fuelstar” that is analogous to the EnergyStar program for home appliances.

The idea is that cars would have “Fuelstar” labels on them that would allow a consumer to compare the environmental friendliness of two different vehicles.

One element that I like about this program is that it will not be purely based on fuel efficiency — it will also take into account the greenhouse gas emissions of the vehicle.

I’ve always thought that too much attention is paid to the fuel economy of cars. Honestly, I think it is more important that my Prius is a “Partial Zero Emissions Vehicle (PZEV)” than the fact that it gets 55 mpg since it is the emissions that ultimately wind up affecting pollution and climate change. So, it is good to see them take this into effect.

In addition, this program will also take into account factors like the recyclability of cars and “any other pollutants or harmful byproducts related to the automobile, which may include those generated during manufacture of the automobile, those issued during use of the automobile, or those generated after the automobile ceases to be operated.”

As a Prius owner, I am particularly happy about this clause. Why? For months, there has been a series of articles running around the Internet talking about the overall environmental impact of a Hummer vs. the environmental impact of a Prius. Every one of these articles harkens back to a single original analysis called “Dust to Dust” and a follow on commentary called “Hidden Cost of Driving a Prius” by CNW Research.

This single report has spawned dozens and dozens of articles talking about which is better: a Hummer or a Prius.

As a Prius owner, I would love to have the government include all of these environmental impacts in their assessment so we can cut to the chase here and have a real analysis of which cars are better for the environment. Let’s get this debate out of the blogosphere and base it on real facts rather than one report by a market-research company.

Prospects for Passage

Ok, so the Commerce Committee sent the bill to the full Senate. So, what? Is it going to actually pass?

That’s obviously the $50,000 question, but I am cautiously optimistic.

What I have read says that the Senate has broad support for this bill. And, because of the filibuster, the Senate tends to be the much more difficult body to get legislation through. If this bill can pass through the Senate, then it just needs a majority in the House. And if the Dems can’t find a simple majority in the House for a bill like this, shame on them.

Of course, the ultimate question is what The Decider will do. Would he bow to the pressure of the auto manufacturers and veto? Who knows.

Anyway, I think this will be a very important bill to watch as it makes its way through Congress.

Related:

I’m back

Posted in Environment by erichard on the May 9th, 2007

I’m back from California and about to begin blogging again.

-Eric