The nation's first greenhouse gas rules for vehicles don't stop at the tailpipe, at least not for electric vehicles.
When the EPA and U.S. Department of Transportation released their new fuel efficiency and greenhouse gas emissions rules for cars and light trucks today, they included a plan to eventually count electric vehicles' emissions all the way back to their power source: CO2-emitting power plants.
Counting only the tailpipe emissions, EVs clock in at zero. That's great news for automakers, who under the new rules will have to meet a fleetwide average greenhouse gas standard of 250 grams per mile by 2016 (roughly equivalent to 35.5 miles per gallon).
But that's not the whole story, as EPA Administrator Lisa Jackson explained:
Electric vehicles are frequently advertised as zero emissions, but "we all know that that's not entirely true, because when you plug in, there's some emissions from the source." Currently in the U.S., that source is often burning coal, and that means greenhouse gas emissions.
According to the EPA's calculations, for a midsize car, electricity's upstream emissions are about three times higher than gasoline's upstream emissions.
"Based on GHG emissions from today's national average electricity generation (including GHG emissions associated with feedstock extraction, processing, and transportation) and other key assumptions related to vehicle electricity consumption, vehicle charging losses, and grid transmission losses, a midsize EV might have an upstream GHG emissions of about 180 grams/mile, compared to the upstream GHG emissions of a typical midsize gasoline car of about 60 grams/mile," the EPA writes.
"Thus, the EV would cause a net upstream GHG emissions increase of about 120 grams/mile. ... The net upstream GHG impact could change over time, of course, based on changes in electricity generation or gasoline production."
That's still a benefit to automakers, since the fleet average goal is 250 grams per mile, but it isn't a strong as when EVs count as zero emissions.
The special rules for electric vehicles won't hit immediately. To help promote the still young technology, the new federal rules offer a temporary incentive: Each manufacturer can count its first 200,000 EVs, fuel cell vehicles and the electric portion of plug-in hybrid electric vehicles produced in model years 2012-2016 as "zero emissions." Manufacturers who produce more than 25,000 of those vehicles in model year 2012 can go up to 300,000.
Realistically, the U.S. market is unlikely to see 200,000 electric vehicles on the road any time soon, according to analysts. So, the incentive gives automakers a hand in meeting their fleetwide emissions obligations, promotes the production of electric vehicles, and creates an extra five-year time span for utilities to begin cleaning up their emissions. State renewable portfolio standards and uncertainty about the regulatory future of coal-fired power are already pushing many utilities toward greater reliance on clean energy and renewable sources.
It also gives automakers time to promote electric-powered vehicles and to work with government and industry to develop the supporting infrastructure.
Consumers are becoming more willing to buy electric vehicles, but cost and infrastructure — where to recharge — are still issues, said AutoPacific analyst Stephanie Brinley.
"If people don't adapt to buying EVs fast enough, there will still be a need for government incentives," she said.
Several of the major automakers had urged the EPA to keep the "zero-emissions" label permanent, in part to raise consumer confidence in a relatively new type of vehicle.
The Alliance of Automobile Manufacturers argued during the comments period on the rule that "customers need to receive a clear signal that they have made the right choice."
Nissan, which is shipping its first Leaf EVs later this year, went farther, arguing that the zero-grams-per-mile rating was legally required because the EPA's 2-cycle test procedures don't account for upstream greenhouse gas emissions. EPA's decision to not include upstream emissions for other types of vehicles would "disrupt the careful balancing embedded into the National Program," Nissan said.
EPA disagreed, saying it had discretion under the law to structure the emissions standards in a way that promotes advances in emissions control technology and addresses air pollution problems.
"EPA recognizes that we have not previously made adjustments to a compliance value to account for upstream emissions in a section 202(a) vehicle emissions standard, but that does not mean we do not have authority to do so in this case," the agency wrote.
In the new federal rule, the agencies acknowledge the industry's concerns, stating that EVs and PHEVs are "potential GHG game changers if major cost and consumer barriers can be overcome and if there is a nationwide transformation to low-GHG electricity." They intend to re-evaluate the incentive program for the 2017 model year based on improvements in those areas.
And Nissan isn't likely to dump its electric vehicles simply because of a coming change in how the U.S. calculates emissions. Brinley pointed out that Nissan is taking a global view: North America is important, but there are other markets where electric vehicles have even greater potential.