Dear Director Brooks,
Environment Maine Research & Policy Center would like to thank the Baldacci Administration and the Department of Environmental Protection (DEP) for proposing the adoption of the next piece in the clean cars program. We strongly support the Department’s proposal to adopt global warming vehicle emission standards as a key piece of Maine’s clean air and global warming reduction strategies.
The global warming emissions standards before the Board of Environmental Protection (BEP) are the next step for keeping Maine on track to clean our air and reduce global warming pollution. Maine and eight other states have already adopted strong standards for tailpipe pollution and this program will allow our state to continue to reduce air pollution and global warming pollution.
Auto emissions threaten our environment; automobiles are the largest single source of global warming pollution in Maine. Global warming has the potential to totally change the ecosystems of our state. We have already started to see its effects, with a severe drought three summers ago, a 3.4 degree increase in the average temperature in Auburn and a slowly rising sea level. Maple syrup production has decreased in the region and the trend will continue if the winters are warmer or drier. The ski industry has to rely more on snowmaking to provide reliable cover on the slopes. To our south in Connecticut, Rhode Island and Massachusetts, recent research points to increased water temperatures as the cause of the shell disease and abrupt decline in the lobster population. Global warming-induced changes in Maine’s climate would alter our state’s environment, cultural heritage and economy.
Enacting global warming emission standards for vehicles would provide the second largest reduction in global warming pollution, according to policy rankings in A Climate Action Plan for Maine. This option has a cost savings of $48 per metric ton of CO2 reduced, ranking as the seventh most cost effective policy. In fact, it is likely that the savings for Maine and vehicle owners now would be even higher, considering the recent increase in gasoline prices.
The technology to make cleaner cars is here. Various technologies currently available enable gasoline vehicles and hybrid gas-electric vehicles to easily meet the global warming emission standards. The current generation of hybrid-electric vehicles—such as the Toyota Prius and the Honda Civic—are approximately 90 percent cleaner than the average vehicle in Maine today. Not only are these vehicles much cleaner than conventional vehicles, but also they are approximately 30 percent more efficient at using gasoline. The five model-year 2005 hybrid-electric vehicles (Toyota Prius, Honda Insight, Civic and Accord, and Ford Escape) achieved an average EPA-rated fuel economy of 46.6 miles per gallon —significantly more than the nearest gasoline-powered vehicle.
Consumers are buying cleaner cars faster than they can be shipped to Maine. Auto dealers in Maine report that they have a waiting list for certain hybrids between four and eight months long. Often, people looking to buy a hybrid settle for some other car because they cannot wait for a hybrid to become available. There is plenty of circumstantial evidence about the high demand for hybrids, such as consumers who do not attempt to bargain the price down and simply sign up at list price, and car manufacturers that do not have to offer special deals to sell these vehicles.
Auto manufacturers are producing even more hybrid models to choose from. In addition to the seven hybrids already available – the Toyota Prius and Highlander, Lexus RX 400h, the Honda Insight, Accord and Civic, and the Ford Escape – consumers will be able to purchase a number of different hybrid vehicles in upcoming years, including the Toyota Sienna, Dodge Ram, Saturn VUE, and Nissan Altima.
Also, vehicles are now available in which components of hybrid technology—such as idle shut-off and regenerative braking—are employed to add to the vehicle’s performance and reduce emissions. The GM Silverado, for example, uses these technologies to provide power to four 110 volt outlets and cuts global warming emissions by about 10 percent.
Hybrids are not the only vehicles with cleaner technology; conventional gasoline vehicles can cut global warming emissions with a host of available technology. These technologies include:
• variable valve timing, installed in most Toyotas and the Ford F-150, which improves air/gasoline mix for better combustion by permitting different valve compression times;
• cylinder deactivation, used in Dodge Hemi v8 and GM Vortec v8 engines, which allows half of the cylinders to stop firing when the engine is not accelerating;
• turbocharged engines, mounted in most Saabs, Volvos and some Chryslers, which enable drivers to get better performance and acceleration out of smaller engines;
• five- or six-speed automatic transmissions, in most Audis and some BMWs and Chryslers, which increse gearing choices and allow the engine to work closer to its optimal speed;
• continuously variable transmissions, in the Saturn Ion and Vue, and Nissan Murano, which provide infinite choices of “speeds” using belts instead of gears and optimize engine speed;
• automatic shift manual transmissions, available in most Subarus, which eliminate the loss of energy from mechanically shifting gears as you would in a standard manual transmission;
• integrated starter generators, in all hybrids and the GM Silverado and Sierra, which can start the engine instantaneously so the engine does not have to idle when the car is stopped;
• 42 volt electrical systems, available in the Toyota Crown Royal and some hybrids, which run integrated starter generators and reduce engine load from air conditioners and other systems;
• low-leakage air conditioning units, which eliminate leakage of refrigerants such as HFC-134a, thought to be 1000 times more potent a global warming gas than carbon dioxide.
The fact that these technologies are available in mass-produced vehicles currently on Maine’s car lots undermines the auto manufacturers’ claim that these vehicles are impossible or too expensive to build. To meet the standards of reducing emissions by about 22 percent by 2012, a car manufacturer might only have to install two or three of the technologies listed above. According to the California Air Resources Board, the average retail price increase for passenger cars and light trucks would be $367 for the 2012 standard and $1064 for the 2016 standard, compared to the 2009 baseline vehicle. For large trucks and SUVs the average price increase is estimated to be $277 in 2012 and $1029 in 2016. This modest increase in cost is expected to be more than offset by operating cost savings in three years. In addition, there are new technologies being designed and tested to further decrease emissions and boost engine performance.
In April of this year, automakers signed an agreement with the Canadian government to cut vehicle global warming emissions to levels similar to those called for in the Chapter 127 standards. In the Memorandum of Agreement with Canada, automakers agreed to use technologies, which they claim are too expensive or infeasible to use in cars sold in the U.S., in order to cut global warming pollution from cars and light trucks in 2007. Similar agreements are in place in the European Union.
Despite the availability of the global warming pollution-reducing technology, agreements with other countries to reduce emissions and the widespread public popularity of cleaner vehicles, most automakers are dragging their feet and fighting laws to reduce vehicle emissions. Automakers are needlessly suing California for regulating global warming emissions from cars, using tactics similar to those they used in fighting catalytic converters and air bags.
At the public hearing, lobbyists representing some automakers and auto dealers made a number of misleading statements that are in direct conflict with factual evidence. Primarily, the arguments of the auto industry lobbyists were based on the false claims of insignificant reductions in air pollution, increased cost of vehicles and decrease in vehicle choice.
Both representatives made false claims that these regulations would do nothing to improve air quality or global warming. On the contrary, reducing global warming pollution from cars by 30 percent by 2016 would have a significant impact on Maine’s contribution to global warming. The amount of carbon savings from these standards was estimated to be 933.6 thousand metric tons of carbon dioxide equivalent by 2020, the second largest amount of reductions from a single policy in A Climate Action Plan for Maine. Cars that emit reduced global warming pollution will emit fewer smog-forming pollutants and air toxics. As evidence of this, one only needs to look at the North East States for Coordinated Air Use Management (NESCAUM) analysis of the California emissions standards that reported that 30 percent of the pollution reductions in Vermont could be attributed to the Zero Emission Vehicle (ZEV) standard. The ZEV standard is similar to the global warming emission standards in that both programs require the sale of more hybrid and advanced technology vehicles.
The second specious argument employed by the auto industry is that the price of cars will increase drastically, up to $3,000 per vehicle. An analysis by the California Air Resources Board estimates an increase of $1064 in the price of a car in 2016, with a payback of two or three years in lower operating costs at 2005 gasoline prices. Even if cleaner more efficient vehicles stayed at $3,000 more than conventional vehicles in 2016, they would pay for themselves quickly in avoided operating costs. Currently, a Honda Civic Hybrid with manual transmission gets 45 city/ 51 highway miles per gallon and costs about $3,000 more than the conventional manual transmission Honda Civic LX, which gets 40 city/ 48 highway miles per gallon. If gas prices were $3.50 per gallon and the car was driven 15,000 miles per year, a hybrid owner would save money after 6 years. If the past few years are any indication of gasoline prices, one could easily argue that average gasoline prices over the next 5 years might be $5.00 per gallon, letting a Civic Hybrid owner cash in on savings after 4 years. Regardless of gasoline prices, premiums for hybrid vehicles will continue to drop and cleaner conventional vehicles will continue to be close in price to regular vehicles.
Another fictitious argument of some automakers and auto dealers is that performance, size and hauling capacity would be limited by these rules. Despite these claims, roomy, sporty and hauling-capable cars and trucks with advanced technologies are currently available and already meet, or nearly meet, the standards. Some of these vehicles include the Saturn Vue, the Nissan Murano, the Ford Escape Hybrid, the Lexus RX400h, the Toyota Highlander, the GM Sierra, the Dodge Magnum and the Honda Accord Hybrid.
In an effort to ‘greenwash’ the auto industry’s actions and intentions, their lobbyists asserted that cars are much cleaner, burn less gasoline now than they did before and that fuel economy “has doubled over the last generation of cars.” Although US fleet fuel economy went from 17.7 miles per gallon in 1977 to 24.6 miles per gallon in 1984, current fleet fuel economy is at its lowest since 1984. Also, the representative from the Maine Auto Dealers attempted to undermine the pollution reductions of advanced technology vehicles operated in Maine, inventing that “hybrids do not get good fuel economy on the highway,” and thus Mainers, driving on highways or rural roads would not reduce global warming emissions. This is also untrue: the Honda Accord Hybrid uses cylinder deactivation on the highway, making it run on three cylinders and cutting emissions over city driving. Other standard gasoline vehicles such as the Dodge Magnum use this technology as well, improving highway emissions and efficiency.
Finally, opponents alleged that Maine does not need to adopt the standards to remain in the California emissions program and that the state should not adopt a rule that is being held up by an auto industry lawsuit. The opposite is true – Maine is legally bound to adopt this standard before the end of the year to remain consistent with California and retain strong emissions standards. On the second point, an auto industry lawsuit is nothing new, will likely be struck down by the courts and should not keep the state from moving forward.
In conclusion, Maine must approve the program by the end of the year to stay on track with other Northeast states and retain strong emissions standards for new cars. Environment Maine encourages the BEP to approve this program for the sake of cleaning our air and slowing global warming.
Sincerely,
Matthew Davis
Advocate
