“Heavy Vehicle emissions standards recently proposed by the Environmental Protection Agency (EPA) would boost the electrification of trucks and buses, but standards stronger than what EPA proposed are needed to de-carbonize transportation at a pace to prevent catastrophic climate change. While leading utilities are showing that they can help build out the infrastructure at the scale necessary to support the proposed standards, they and their customers will need to invest far more ambitiously to support more robust standards.,” claims Daivie Ghosh, Transportation Senior Research Analyst at the American Council for an Energy-Efficient Economy, aka ACEEE. (AutoInformed: EPA Final Heavy-Duty Truck Standards Released, Well, Finally)
The proposed “Phase 3” heavy-duty vehicle (HDV) rules include new emissions standards for model years 2027–2032. The EPA projects that the standards would reduce emissions primarily via an increase in zero-emission vehicles (ZEV). This electrification would significantly improve public health (ACEE Study) and help address today’s climate challenge. Money interests are fighting the rule.
The proposed EPA standards AutoInformed notes in EPA’s words “do not mandate the use of a specific technology, and EPA anticipates that a compliant fleet under the proposed standards would include a diverse range of technologies (e.g., transmission technologies, aerodynamic improvements, engine technologies, battery electric powertrains, hydrogen fuel cell powertrains, etc.). The technologies that have played a fundamental role in meeting the Phase 2 GHG standards will continue to play an important role going forward as they remain key to reducing the GHG emissions of HD vehicles powered by internal combustion engines (referred to in this proposal as ICE vehicles).
“In developing the proposed standards, EPA has also considered the key issues associated with growth in penetration of zero-emission vehicles, including charging infrastructure and hydrogen production. In our assessment that supports the appropriateness and feasibility of these proposed standards, we developed a technology pathway that could be used to meet each of the standards. The technology package includes a mix of ICE vehicles with CO2-reducing technologies and ZEVs. EPA developed an analysis tool to evaluate the design features needed to meet the energy and power demands of various HD vehicle types when using ZEV technologies. The overarching analysis is premised on ensuring each of the ZEVs could perform the same work as its ICE counterpart while oversizing the battery to account for its usable range and that batteries deteriorate over time,” EPA said.
Some of the folks who brought you deadly diesel (in AutoInformed’s view) at the Truck and Engine Manufacturers Association and American Trucking Associations are pushing to weaken Phase 3 rules, arguing that the lack of sufficient charging infrastructure and uncertainty around the timing of its deployment remain obstacles to the successful rollout of EVs.
“Despite complaints, a strong Phase 3 rule is needed to send the necessary market signal to boost the buildout of an extensive HDV charging network. Those warning that the proposed standards levels are unachievable might be surprised to see what utilities – expected to play an important role in helping develop the charging infrastructure- have to say,” said Daivie Ghosh today.
“Edison Electric Institute (EEI), the primary trade organization representing investor-owned utilities, supports the rule at its proposed stringency. EEI is confident that there is sufficient time to deploy charging infrastructure for HDVs to support the proposed rule and is actively planning for it. The trade organization emphasizes that the standards would provide utilities the regulatory certainty needed to proactively plan for the necessary charging infrastructure
“Public comments from utilities and their representatives clearly indicate that infrastructure build-out at the proposed level is doable. However, the proposed rule does not realize the full potential for emissions reduction and could reflect much higher EV penetration rates (for example, by applying Advanced Clean Truck ZEV penetration rates for states that adopt that rule before the Phase 3 rule is finalized—among other improvements). While the proposed standards would provide GHG benefits worth $87 billion, increased electrification rates through stronger standards could yield even higher social benefits for avoided GHG emissions (worth $190–231 billion), according to an ICCT analysis. ACEEE thus advocates for a stronger rule to deliver more significant public health and climate benefits.
“Given project and regulatory approval timelines, the success of a stronger rule rests on utilities (among other players) accelerating investments sooner. Utility filings to date will only result in 25,000 MHDV charging stations (Level 2 and DCFC). According to a 2021 analysis by Atlas Public Policy, to get on track for all HDVs to be electric by 2040 (a target reflecting higher electrification rates than EPA’s proposed rule), the United States could need between 10,000–93,000 charging ports by 2030 for long-haul trucks alone. Deploying these chargers would require private and public stakeholders to commit between $62–124 billion in investments by 2030, with utility-side upgrade costs being passed on to customers. (The estimate reflects the total investments needed by all stakeholders and assumes the final cost to utilities to be zero (by passing it on to customers). The investment value includes costs other than electrical grid upgrades for items such as hardware, project costs (permitting, etc.), and labor. While utilities are not expected to fund all of it, they will still play a key role in investing in the infrastructure to build (and upgrade) the necessary electrical infrastructure, as well as through other utility programs.
“A study commissioned by EDF found that if utilities covered the initial cost of EV infrastructure upgrades, they could generate millions in revenue without increasing ratepayers’ bills. Another study found that, between 2012 and 2017 in California, EVs increased utility revenues more than utility costs. Utilities can reduce their overall investment costs by instituting managed charging programs and increasing charger utilization for HDVs. They also have diverse options to recover the costs of their programs and investments. Thus, if implemented correctly, investments in HDV charging present a lucrative business opportunity for utilities,” said Daivie Ghosh.
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The Corrupting Influence of Money on US Public Health
“Heavy Vehicle emissions standards recently proposed by the Environmental Protection Agency (EPA) would boost the electrification of trucks and buses, but standards stronger than what EPA proposed are needed to de-carbonize transportation at a pace to prevent catastrophic climate change. While leading utilities are showing that they can help build out the infrastructure at the scale necessary to support the proposed standards, they and their customers will need to invest far more ambitiously to support more robust standards.,” claims Daivie Ghosh, Transportation Senior Research Analyst at the American Council for an Energy-Efficient Economy, aka ACEEE. (AutoInformed: EPA Final Heavy-Duty Truck Standards Released, Well, Finally)
The proposed “Phase 3” heavy-duty vehicle (HDV) rules include new emissions standards for model years 2027–2032. The EPA projects that the standards would reduce emissions primarily via an increase in zero-emission vehicles (ZEV). This electrification would significantly improve public health (ACEE Study) and help address today’s climate challenge. Money interests are fighting the rule.
The proposed EPA standards AutoInformed notes in EPA’s words “do not mandate the use of a specific technology, and EPA anticipates that a compliant fleet under the proposed standards would include a diverse range of technologies (e.g., transmission technologies, aerodynamic improvements, engine technologies, battery electric powertrains, hydrogen fuel cell powertrains, etc.). The technologies that have played a fundamental role in meeting the Phase 2 GHG standards will continue to play an important role going forward as they remain key to reducing the GHG emissions of HD vehicles powered by internal combustion engines (referred to in this proposal as ICE vehicles).
“In developing the proposed standards, EPA has also considered the key issues associated with growth in penetration of zero-emission vehicles, including charging infrastructure and hydrogen production. In our assessment that supports the appropriateness and feasibility of these proposed standards, we developed a technology pathway that could be used to meet each of the standards. The technology package includes a mix of ICE vehicles with CO2-reducing technologies and ZEVs. EPA developed an analysis tool to evaluate the design features needed to meet the energy and power demands of various HD vehicle types when using ZEV technologies. The overarching analysis is premised on ensuring each of the ZEVs could perform the same work as its ICE counterpart while oversizing the battery to account for its usable range and that batteries deteriorate over time,” EPA said.
Some of the folks who brought you deadly diesel (in AutoInformed’s view) at the Truck and Engine Manufacturers Association and American Trucking Associations are pushing to weaken Phase 3 rules, arguing that the lack of sufficient charging infrastructure and uncertainty around the timing of its deployment remain obstacles to the successful rollout of EVs.
“Despite complaints, a strong Phase 3 rule is needed to send the necessary market signal to boost the buildout of an extensive HDV charging network. Those warning that the proposed standards levels are unachievable might be surprised to see what utilities – expected to play an important role in helping develop the charging infrastructure- have to say,” said Daivie Ghosh today.
“Edison Electric Institute (EEI), the primary trade organization representing investor-owned utilities, supports the rule at its proposed stringency. EEI is confident that there is sufficient time to deploy charging infrastructure for HDVs to support the proposed rule and is actively planning for it. The trade organization emphasizes that the standards would provide utilities the regulatory certainty needed to proactively plan for the necessary charging infrastructure
“Public comments from utilities and their representatives clearly indicate that infrastructure build-out at the proposed level is doable. However, the proposed rule does not realize the full potential for emissions reduction and could reflect much higher EV penetration rates (for example, by applying Advanced Clean Truck ZEV penetration rates for states that adopt that rule before the Phase 3 rule is finalized—among other improvements). While the proposed standards would provide GHG benefits worth $87 billion, increased electrification rates through stronger standards could yield even higher social benefits for avoided GHG emissions (worth $190–231 billion), according to an ICCT analysis. ACEEE thus advocates for a stronger rule to deliver more significant public health and climate benefits.
“Given project and regulatory approval timelines, the success of a stronger rule rests on utilities (among other players) accelerating investments sooner. Utility filings to date will only result in 25,000 MHDV charging stations (Level 2 and DCFC). According to a 2021 analysis by Atlas Public Policy, to get on track for all HDVs to be electric by 2040 (a target reflecting higher electrification rates than EPA’s proposed rule), the United States could need between 10,000–93,000 charging ports by 2030 for long-haul trucks alone. Deploying these chargers would require private and public stakeholders to commit between $62–124 billion in investments by 2030, with utility-side upgrade costs being passed on to customers. (The estimate reflects the total investments needed by all stakeholders and assumes the final cost to utilities to be zero (by passing it on to customers). The investment value includes costs other than electrical grid upgrades for items such as hardware, project costs (permitting, etc.), and labor. While utilities are not expected to fund all of it, they will still play a key role in investing in the infrastructure to build (and upgrade) the necessary electrical infrastructure, as well as through other utility programs.
“A study commissioned by EDF found that if utilities covered the initial cost of EV infrastructure upgrades, they could generate millions in revenue without increasing ratepayers’ bills. Another study found that, between 2012 and 2017 in California, EVs increased utility revenues more than utility costs. Utilities can reduce their overall investment costs by instituting managed charging programs and increasing charger utilization for HDVs. They also have diverse options to recover the costs of their programs and investments. Thus, if implemented correctly, investments in HDV charging present a lucrative business opportunity for utilities,” said Daivie Ghosh.
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