FEDERAL REGULATIONS NEEDING AMENDMENT to STIMULATE the PRODUCTION and INTRODUCTION of ELECTRIC/Solar VEHICLES IV-1

ACKNOWLEDGEMENT The Department of Transportation is grateful to those organizations and individuals who provided information on the subject of commercialization of electric vehicles for this report. º*-i-º-º-º-º-º-º-º-º-º-º-º--- - ---- 3O2(2. TABLE OF CONTENTS Section I INTRODUCTION II FEDERAL REGULATIONS APPLYING TO ALL MOTOR VEHICLES II-1 III EXISTING FEDERAL REGULATIONS PECULIAR TO ELECTRIC-SOLAR VEHICLES III-1 IV FEDERAL REGULATIONS NEEDING AMENDMENT TO STIMULATE THE PRODUCTION AND INTRODUCTION OF ELECTRIC/solar VEHICLES IV-1 ADDITIONAL FEDERAL REGULATIONS NEEDED TO STIMULATE THE PRODUCTION AND INTRODUCTION OF ELECTRIC-SOLAR VEHICLES VI AIR POLLUTANT EMISSIONS FROM ELECTRIC VEHICLE USE VI-1 VII SUMMARY OF RECOMMENDED FEDERAL REGULATORY CHANGES VII-1 VIII REFERENCES VIII-1 IX BIBLIOGRAPHY IX-1 APPENDIX A SOUTHERN CALIFORNIA EDISON COMPANY LETTER AND ATTACHMENTS APPENDIX B ELECTRIC POWER RESEARCH INSTITUTE LETTER APPENDIX C CITY OF LOS ANGELES DEPARTMENT OF WATER AND POWER LETTER APPENDIX ELECTRIC VEHICLE DEVELOPMENT CORPORATION LETTER APPENDIX E CALIFORNIA ENERGY COMMISSION LETTER APPENDIX FORD MOTOR COMPANY LETTER APPENDIX CALIFORNIA AIR RESOURCES BOARD LETTER APPENDIX COMMONWEALTH EDISON LETTER APPENDIX EXAMPLE OF LETTERS TO POTENTIAL STAKEHOLDERS i LIST OF TABLES Table State of EV Technology Factors II-1 Federal Motor Vehicle Safety Standards Code of Federal Regulations II-2 VI-1 Estimate of Electric Vehicle Weights VI-6 VI-2 Simulation Results for EV Propulsion Efficiency VI-7 VI-3 Battery and Charger Efficiencies VI-7 VI-4 Electric Utility Energy Required for Electric Vehicle Propulsion Emission from Fossil-Fueled Electric Utilities Mix of Electric Utility Fuels in the U.S. in 1988 VI-12 Emission from U.S. Utility Mix VI-12 Electric Utility Emissions for EV Propulsion VI-12 Electric Utility Emissions Due to EV Air Conditioning VI-15 Emissions from Small Engine Powering EV Air Conditioner VI-16 WI-11 Exhaust Emissions: Diesel-Fueled EV Burner-Heater VI-18 VI-12 Total Emissions, Electric Sedan VI-19 VI-13 Emissions from Conventional Light Duty Vehicles VI-22 VI-14 Emissions Comparison, Electric and Conventional Light Duty Vehicles VI-23 ii * º | Soala REPORT TO THE CONGRESS PURSUANT TO P. L. 100-494, SECTION 7 - ELECTRIC VEHICLES SECTION I: INTRODUCTION A. Purpose The purpose of this report is to inform the Congress of: 1. the regulations in place which affect electric vehicles (EVs) and solar powered vehicles (SPVs), 2. existing regulations which are barriers to EV and SPV production and introduction into commerce, 3. the effect of EV use on air quality, 4. the Department's recommendation for amendment of existing regulations and promulgation of new regulations for furthering the production and use of EVs. Only recommendations which could be implemented through regulations promulgated under standing legislation have been considered. Regulations which would require legislative action to empower a department or agency to promulgate regulations "to stimulate the production and introduction of electric vehicles into commerce" have not been considered. Particularly, the many suggestions dealing with subsidies, tax incentives, and accelerated depreciation schedules for EV and battery manufacturers and EV purchasers are not discussed here. I-1 B. Summary Three questions are posed by Section 7 of the Alternative Motor Fuels Act of 1988 (P.L. 100-494): 1. Should current regulations be amended or additional regulations be promulgated to stimulate the production and introduction of EVs into commerce? 2. What would be the effect of EV use on air quality? 3. Is it feasible or desirable to promulgate regulations to stimulate production and introduction of solar powered vehicles into commerce? The categories of federal regulations considered for this report were safety, emissions, and consumer protection. Other regulations which may be relevant to EV commercialization (e.g., control of electric power rates) are the responsibility of the individual state and local governments. It was found that no current regulations act as a barrier to the introduction of EVs into commerce. The present stimulatory regulation, the Corporate Average Fuel Economy (CAFE) credit for EVs, is not sufficient to bring EVs into production, but should be maintained. The petroleum equivalency factors in this regulation expired in 1987, but are currently being updated by DOE. There is a strong consensus among the various groups engaged in EV development and research, that automobile manufacturers retain the I-2 option to include equivalent petroleum-based fuel economy values for EVs in their corporate average fuel economy (10 CFR Part 474), provided EVs are not used to determine the manufacturer's capability for purposes of establishing a fuel economy standard. No future regulations which could be promulgated under standing legislation would be sufficient to accelerate the introduction of EVs. Some regulations, for which authority does exist, may need amendment and others could be initiated to meet societal goals (air quality and safety) and reduce uncertainty on the part of the manufacturers as to government requirements for these vehicles in mass production. The main barriers to large scale introduction of EVs have been initial cost and performance (range, acceleration, and top speed) when compared to conventional vehicles. The issue of range (generally 60 miles, but demonstrated to be 120 miles by the GM Impact prototype) is a matter of refueling time. A conventional vehicle's range is a function of fuel tank size and fuel used per mile traveled, however "range" is seldom discussed for conventional vehicles since refueling takes only a few minutes and the range is generally considered adequate by consumers. In areas where fuel is readily available, range becomes effectively infinite. EVs, on the other hand, currently require 8 to 12 hours (overnight) for refueling--charging the battery pack--during which they are unavailable for use. Again, the GM prototype is claimed to recharge more rapidily, in a period of only two hours. In preparation of this report the Environmental Protection Agency (EPA) has projected benefits, compared with conventional vehicles, in reduced milligram per mile of emissions of carbon monoxide, formaldehyde, methane, and volatile organic compounds (VOC) with c., e present level of controls on power plants for these pollutants. On the same basis, the milligram per mile emissions of particulate, sulfur dioxide, and possibly oxides of nitrogen would be increased with EVs. These estimates are based on the 1988 power plant fuel mix. Regulatory action which applies to EVs will also apply to SPVs. The technological readiness and experience of SPVs at this time is so limited that it is not possible to define SPV-specific regulations. Most interested parties agreed that, assuming a market for EVs develops, the EVs to be introduced should meet all applicable Federal Motor Vehicle Safety Standards (FMVSS), some of which may need amendment to include language relevant to EV operation and components; further, EV-specific safety standards should be considered by the National Highway Traffic Safety Administration at such time as the need becomes apparent, the regulation becomes practicable and objective test procedures are available. I-4 Several interested parties suggested that regulations might be developed allowing power plants to "trade-off" stack emissions for introducing EVs, either selling them to other fleets or using them in their own fleets. This would be viable only for power plants required to meet certain standards at 40 CFR Part 60. C. Background 1. Legislative and Requlatory The only legislation dealing exclusively with the development of EVs was the Electric and Hybrid Vehicle Research, Development, and Demonstration Act of 1976 (as amended by the Federal Energy Administration Act of 1978 and the Chrysler Corporation Loan Guarantee Act of 1979), administered by the Department of Energy. Light vans and subcompact cars that are operating in U.S. fleets do so under the Test and Evaluation activities of the DOE's Electric and Hybrid Vehicles Program. During FY 1988, over 300 DOE EVs were assigned to ten private and public sector fleets, the largest of which is the U.S. Navy's fleet of approximately 220 EVs. These demonstration fleets test not only new vehicles, but new types of batteries and vehicle components (air conditioning, heating, brakes, etc.). A report to Congress is submitted annually on the Electric and Hybrid Vehicles Program from the DOE Assistant Secretary for Conservation and Renewable Energy [1,2]. Under authority of the Act, regulations at 10 CFR Part 474 provided a method for calculating fuel economy of EVs to include EV production in an automobile manufacturer's Corporate Average Fuel Economy (CAFE). Section 18 of the Chrysler Corporation Loan Guarantee Act of 1979 required the Secretary of Energy to "conduct a seven-year evaluation program of the inclusion of electric vehicles ... in the calculation of average fuel economy .. and to - -----i.e. Clie value and implications of such inclusion as an i...centive for the early initiation of industrial engineering development and initial commercialization of electric vehicles in the United States." A report was submitted to Congress in 1987 OIn the results of this evaluation program which concluded "the EV CAFE provision has not yet provided the desired incentive to assist in the commercialization of electric vehicles in the United States," and, "According to the responses received from the automobile manufacturers, the provision has not provided an incentive for the early initiation of industrial engineering development for electric vehicles" [3]. The petroleum equivalency factors in this regulation expired in 1987 with no manufacturer ever taking advantage of the EV fuel economy calculation. The Electric and Hybrid Vehicle Loan Guaranty Program established by regulation at 10 CFR Part 791 attempted to "encourage and assist qualified borrowers to accelerate development . of electric and hybrid vehicles for introduction into the Nation's transportation fleet." Two loan guarantees were issued; the program expired in September of 1983.

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