What in the World is Well-to-Wheels and Why Does It Matter?
By Norm Brinkman
GM R&D Technical Fellow
Since gasoline has been the predominant source of fuel for our cars and trucks for the last 80 years or so, you may not give a second thought to where it comes from and how it gets to the pump at your local station.
But if you care about the impact of transportation on energy and the environment, you might be like me and some of my colleagues at General Motors who ponder this as we plan the fuels and powertrain systems for future GM cars.
The energy conversion losses and greenhouse gas emissions (mainly carbon dioxide or CO2) that occur when fuels are produced and delivered to the service station is part of a science called fuel life cycle analysis, or LCA. When gasoline and diesel were alone in the market, we didn’t have to think much about LCA. But now with flexible-fuel vehicles running on E85 ethanol; people driving hydrogen-fueled Chevrolet Equinox fuel cell vehicles, and the Chevrolet Volt extended range electric vehicle coming late next year, we need to compare vehicles on more than just the miles per gallon sticker on the window. We also need to account for the energy and emissions that result from making the fuel also.
LCA is simply an accounting tool which measures all of the energy and raw materials used and all of the emissions (CO2) generated in the production of the fuel. In the case of petroleum-derived fuels, this means LCA includes everything from the time the oil is extracted from the ground, transported to the refinery, made into fuel and distributed to your local gas station. This is also known as a Well-to-Wheels Study because it starts at the oil well and ends at the wheels – or more specifically the tailpipe of your car or truck.
My colleagues and I at GM performed a study with Argonne National Laboratory that looked at these issues and found that E85 using ethanol made from corn reduced CO2 by about 20 percent compared with gasoline while ethanol made from cellulosic energy crops reduced CO2 by about 75 percent.
Let’s take the example of E85. To get ethanol, we grow corn that is used to make most of today’s ethanol in the U.S. Very soon, wood residues left over after logging will be used as the source, or feedstock, for ethanol conversion processes being developed by companies like our partners Coskata and Mascoma. Ethanol made from logging residues have near zero greenhouse gases on a lifecycle basis because the logging is going to happen whether or not the residue is used for fuel. We just need to account for transporting the materials and any fossil fuel emissions from the ethanol refinery. Depending how the plant is powered, those emissions can vary.
For a crop like corn ethanol, the LCA is much more complex. We keep track of the energy and emissions it takes to plant the corn, and make the fuels, fertilizers, and pesticides to grow the corn. We also estimate whether growing the corn increases or decreases carbon in the soil. Next we estimate how much fuel it takes to get the corn to the ethanol refinery and how much energy is consumed and the amount of emissions that are generated in the biorefinery. Corn ethanol refineries typically make a co-product called distillers grain, which is a high-protein feed for cattle. This production is counted as a credit in our accounting spreadsheet. We also include the impact of getting ethanol to the service station by rail and truck.
These are the conventional requirements for a fuel LCA. However, some influential scientists have written that more should be considered, speculating that planting more corn in Iowa sets off domino effects throughout the world, leading to rainforests being burned in Brazil. Most prominent fuel LCA scientists believe these indirect land use change (iLUC) effects should not be included in the lifecycle analysis. You can learn more about this from a recent blog by Bruce Dale of Michigan State University.
At GM, we care very much about the energy and environmental footprint not only of our vehicles (including their manufacture), but also of the fuels that go into them before they ever reach the vehicle. That’s why we contribute to developing a greater understanding of the full life-cycle issues surrounding personal transportation.
I hope this primer on Life Cycle Analysis was helpful. I’d be happy to read your comments and respond to any questions.
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Mr. Brinkman,
Another term for LCA or “well-to-wheels” is a concept called “embodied energy” which takes into consideration the total energy consumed in bringing a product to market, whether it’s a car, a liquid fuel, or a sport jacket.
For example the “embodied energy” in a hybrid car or the Volt, will be quite high because of the energy needed in the extraction from the earth and reforming of the alkaline minerals that go into the batteries.
The “embodied energy” of ethanol ~ particularly corn ethanol ~ or of hydrogen fuel is also quite high because of corn’s high synthetic fertilizer demands and the need to use fossil fuels to distill fermented corn into ethanol.
As it turns out, the embodied energy in fossil fuels is quite low, because Mother Nature did all the heavy lifting of converting vast amounts of organic mass (algae and plankton) to oil by providing millions of years of absolutely free high heat and pressure. (You might say oil is the original bio-fuel.)
While fossil fuels carry a lot of energy, none of us had to pay to put it there as we do when we grow corn and turn it into ethanol, or when making hydrogen fuel from natural gas or water molecules.
“At GM, we care very much about the energy and environmental footprint not only of our vehicles (including their manufacture)…”
Can you tell us the findings of your analysis of how much “embodied energy” goes into the production of a Volt and its several hundred pound battery?
I am in constant wonder at the efforts put into “alternative fuels”. As a parallel development cycle, shouldn’t the automotive company’s be looking at ways to improve mileage with current technologies?
I ask these questions with an underlying motive. First, to make these “alternative fuels” be they ethanol or electrical, we must use another form of energy and convert it. In the end, we will be looking at those sources also (like coal). Perhaps we can look at reengineering aspects of the car that are relevant to improved performance.
This is where my ulterior motive comes to play. I have developed an automotive wheel that will improve mileage 30-50% with current technology. Imagine this on an electric vehicle! However, it is extremely difficult to present new ideas to car companies. I cannot find out if it is a legal issue or ego issue. I would think that some form of clearing house of ideas would be most appreciated and needed in these times.
If anyone reading this can offer me any help, it would be appreciated!
“I cannot find out if it is a legal issue or ego issue.”
Geoff,
I’m sure it’s a bit of both. Have you seen Flash of Genius the movie about the guy who invented the interval windshield wiper, and whom Ford stole it from without proper compensation? Flash of Genius
GM’s lawyers will not let GM even acknowledge your blog above, no matter how sound your development may be and how much potential it might have. If they even hint that you might have a good idea and they then later use your concept or something similar, it would open them up to a potential lawsuit.
It’s too bad you can’t just walk into the GM or Ford research center and say, “Well boys, take a look at this and tell me what you think.” without the lawyers being involved.
Best of luck finding someone who will listen, evaluate, and act on your development.
Norm,
A bit off-topic, but perhaps interesting to you nevertheless. You’ve no doubt heard the news of the last few days where engineers at MIT think they have found a way to charge Li-ion batteries faster. But even with faster charge times, the energy density of the carrying agent plays a big role in the efficiency of a vehicle and it’s “Well-to-Wheels” efficiency. Below is a comparison of the energy density of gasoline and Li-ion batteries showing the energy each can carry and deliver per unit of weight.
Li-ion: 0.46 mj/kg
Gasoline: 47.0 mj/kg
Gasoline can carry over 100 times as much energy per unit of weight as can a Li-ion battery.
Geoff, you would probably be more successful at selling the idea to an automobile parts supplier, rather than to one car company. A parts supplier can market the product to multiple manufacturers. I’d start with tire companies, but patent the idea first.
the big problem with alternate fuels is the government has not found a way to collect the taxes like on natural gas cars fueled at home. as soon as this problem is solved there will be lots of alternate fuel options available to the public.
Dear GM
Like 50 million guys I want a new Truck. I presently own a 1992 Chevy Silverado 1500, 4×4, V6 standard shift. MY house is paid for; my credits have 00.00 balances both vehicles are paid for.
My problem is just like the other 50 million guys, we can’t afford the payments. My wife and I live on one pay check at $11.30 an hour. I can’t afford much over $150 a month, I am not going to over strap myself. The truck I want is a ¾ ton 4×4 V8 four with a 6 ft bed.
I know I can dream on think that I can buy a new ¾ truck for $150 a month, unless I put down n about $25,000, but if I $25,000 I would spend $8,000 and restore the truck I have now.
So the real question: Is how do I and 50 million other guys afford the trucks we want, and for GM to make a profit?
Try change the equation
We got 50 million guys that want new trucks, GM wants to sell each one of us a new truck, but there is a $25,000 brick wall between us.
So how do we get rid of the wall?
There are 300, 000, 000 people that live in this country, and there is one thing we can commonly afford, and that is a $5.00 raffle ticket to win a new car or truck.
Would I and the 50 million other guys buy a $5.00 ticket for chance to win a new truck?
Why not?
So if GM raffled off one truck for $5.00 and receive 1,500,000 entry’s, what would be the profit one the truck? Answer $7,500,000 or if you the sub track $35,000 price tag it comes to $7,465,000
Here is were it gets real interesting, so pay attention, no napping.
This say Gm needs to sell the rest of the trucks $35,000 a piece to make ends meet. But I and the other guys still can only afford $10,000 and we still have that $25,000 brick wall in front of us.
Take the $7,465,000 and divide it by $25,000 which equals about 306 trucks, and sell them at $10,000 each, they will be gone in a week.
You could bump the price up from $10,000, but I hope GM learned its lesson about greed.
By using creativity I just sold 307 Chevy trucks at $35,000 each, in a week, in this shitty economy, and my customers are bragging on how they stole the trucks.
Toyota and Nissan make a much better quality truck the GM and dodge does. GM has the ugliest truck on the planet.
If I owned GM I go back to the 1957 Chevy front end designed, if you did! You wouldn’t be able to make them fast enough.
Dan H
Dear Norm,
I have posted the below comment to Mr. Lutz some months ago, but have never received any answer. Well, maybe you will have the time. There is no LCA if you produce the energy at home. (But quite a change for the oil industry, the automobile parts industry, and the Middle East. Luckily the new president cares more about our children.) So the comment, so that you understand the above:
‘Just a small calculation and some questions regarding product development: a full charge of the Chevy Volt requires 8 kw, right? (great achievement by the way!)The average capacity of a 150 Watt solar panel is 1 kwh / square meter /day in continental Europe (8 kwh in the Sahara desert), so to fill up your Chevy Volt, you would need 5 hours of sunlight at your 20 square meter garage roof solar panel, is that correct?
Or let’s take the wind turbine. With the 8 kw for charging the Volt, you would need 2920 kw per year, to charge it every day. So you need a wind turbine with a yearly 3 000 kwh output. A 2 kw wind turbine produces in average 5000 kwh on a yearly basis. Such a turbine costs at a retail price 7 000 USD.’
GM could rewamp his image by actualy starting to produce the Volt. As to the concerns, that it is not feasible, well, there are a lot of cars not feasible, but still produced at big automakers. Those are called image boosters. Not an unknonw term. And who knows, some day an image booster can evolve to something far bigger and better than anybody would have thought.
Well, let’s hope I will get an answer this time about the calculations.
Best regards,
Barna
Merlin, imagine that you are standing on the 5th avenue in New York. The weather is nice, the sun is shining, so you take a deep breath of fresh air, and tell your 5 year old daughter also to do so. You point a good friend at the other side of the road, you shout over, and he actualy hears it, and waves back.
But you’re right. Let’s use something mother nature has already prepared for us. There’s much less work with it, right? And let’s use something, with which some can make good money with. Something, which is not there in unlimited quantities, like the wind, or solar power. Let’s use oil! Yeeehaaa!
Barna
@László Steiner
You have to multiply the effective energy density of your examples by the TTW efficiency. Approximately 18% for a gasoline non-hybrid, and approximately 80% for a typical brake-regenerative electrical vehicle.
Li-ion: 0.46 mj/kg actually closer to 0.36 mj/kg.
Gasoline: 47.0 mj/kg actually more like 8 mj/kg.
That’s the point of a WTT-TTW study. If you read the study, it takes these into account – you cannot have an accurate report of Wheel-to-Tank, and Tank-to-Wheel without estimating these efficiencies.
@Geoff McCue
No disrepsect, but a simple analysis of energy usage in a typical passenger car or truck, unless your wheel has active “energy capacitance” capabilities, shows that a change to a passive wheel/tire CANNOT result in a 50% improvement in efficiency. You are saying that you can take a Cobalt XFE at 37 Miles per gallon, and install your wheel and magically get 48 to 56 MPG. I find this a dubious claim.
If it is that easy, then demonstration of such a product – good solid scientific demonstration that can be duplicated (you already have the patent pending, right? so you are protected) – will give you the opportunity to be a billionaire. Start a company if you really have such a product – you will find thousands of investors. Only do this if you have a real product.
Please, no “clinical studies”. LOL
If you are serious, Geoff McCue, then Bob Lutz has not yet retired from GM. I will end my post by quoting him from April of 2007:
“”Academics assure us that for $200 we can get 30 percent better mileage. If anyone can figure out how to do that for $200 – or even for $1,000 – I want them in my office today. Show me how to do it and we’ll adopt it. If I could increase mileage by 30 percent for $200, why wouldn’t I? What’s my motivation not to when a gas-electric hybrid gets 27 percent better mileage, and I hope someday to get the cost down to $9,000?”"
-Bob Lutz, April 2007
GM has a long history of engineering facts so that they conveniently illustrate the message they are trying to convey.
Unfourtunatley the public will be extremly skeptical of this type of analysis when we all still have fresh in our minds the report that said a HUMMER was less harmfull to the environment than a Prius… Why sell HUMMER and make a battery powered car if that is the case??
“But you’re right. Let’s use something mother nature has already prepared for us. There’s much less work with it, right? And let’s use something, with which some can make good money with.”
Barna,
You and I actually agree. Oil is energy dense and a tremendous value. Mother Nature made it from algae and plankton and gave it to us free. But it’s finite, or if not finite, it will take Mother Nature at least 75 million years to reload the supply of bio-fuels she gave and that we squandered in a century.
But there is an unlimited supply we have barely tapped ~ that big ol’ fusion reactor in the sky ~ the Sun. More energy from the Sun falls on the earth each day than we could burn in a century ~ we just have to use it. (And I’m including the wind power you obliquely referred to which is a derivative of Solar energy.)
“Would I and the 50 million other guys buy a $5.00 ticket for chance to win a new truck?
Why not? So if GM raffled off one truck for $5.00 and receive 1,500,000 entries, what would be the profit one the truck? Answer $7,500,000.”
Interesting idea Dan. You could be on to something. All the state governments get to be in the lottery business, so why shouldn’t GM?.
But there is one big problem with your lottery — the odds. A I in 1.5 million chance of winning is not good. That’s why they say the state lotteries are really nothing more than a tax on the mathematically illiterate.
~ Li-ion: 0.46 mj/kg actually closer to 0.36 mj/kg.
~ Gasoline: 47.0 mj/kg actually more like 8 mj/kg.
Eccentric Observer,
You are certainly correct. But that’s still a ratio of 22:1in favor of gasoline.
Cordially,
László
@László Steiner,
What’s a factor of 5 between friends?
Fact of the matter is this, though: nobody cares how heavy their car is if they are shopping for a fuel efficient commuter. It all depends on the application.
If they did care about weight (as in a heavier weight to power ratio would cause slower acceleration and people not to buy your car), then nobody would buy a car that stops in 150′ when others stop in shorter distances, nor would they buy this car if it had pitiful acceleration performance, like 11 seconds 0-60.
You guessed it, I just described a Prius.
People care about miles per gallon, and even further – if you remove the miles per gallon the next question is “how much will it cost per mile”? This gets at the root of the issue: what’s it cost me?
The answers are pretty simple: @ $2/gallon, gasoline is about 7 cents a mile. @ $4/gallon, gasoline is about 14 cents a mile. (based on an average mileage of around 28 MPG – less and your cost per mile is higher).
12 useable kWh for the Volt (100% charge to 20%-30% charge) for 40 miles electrical only driving works out to about .320 kWh/mile. @ 9 cents a kWh, electricity only costs the consumer a bit less than 3 cents a mile, and doesn’t vary much. This is the equivalent of getting your gasoline (@ 28 MPG average) for about 80 cents a gallon. It’s an even cheaper comparison if your normal vehicle averages worse fuel economy.
Who cares what the two vehicles actually weigh? So long as they are initially affordable, and so long as they have sufficient maneuverability and performance so as not to present a hazard, most people will be satisfied – provided they deliver what is expected. People buying a Volt are not in the market for a ZR1. They have different priorities. People buying a Volt are looking to see how long they can keep a tank of fuel from being consumed.
That’s what I’ll be doing if I decide to throw my hat in and buy one. You can bet I won’t be modifying my Volt for drag racing or autocrossing.
That’s why the ZR1 is not electrically powered by stored energy in a Lithium-ion battery.
GM execs, here’s some quick notes and thoughts of how and what can be done to turn the tide on CAFE and why I believe the Court will favor it. This action might get 6-3 in favor by the Supremes. See if you like it.
Unconstitutional applications of Corporate Average Fuel Economy (CAFE) and Emissions rules by the Environmental Protection Agency (EPA) and the U.S. Department of Transportation (DOT) through its National Highway Traffic Safety Administration (NHTSA).
Issues
Question 1. Has the Secretary of the Department of Transportation violated American auto company Constutional rights and/or liberty interest by not including E-85 flex fuel vehicles in the governments Corporate Average Fuel Economy calculation applied to the company.
Answer: Probably yes.
Question 2. Has the Director of the Environmental Protection Agency violated American auto company constitutional rights and/or liberty interest by requiring a misreporting of “gas mileage” as fuel economy of E-85 flex fuel vehicles on EPA ratings.
Answer: Probably yes.
Question 3. Would this action be in the public interest.
Answer: Affirmative.
Brief discussion
The legislative purpose of the Clean Air Act and the Corporate Average Fuel Economy law is clear. The government has repeatedly defined the respective purposes and/or legislative intent of these Acts for example to regulate pollutants and to reduce dependence on foreign oil; moreover, the purpose of the Clean Air Act has never been to regulate clean fuels, but rather to promote their use. Thus the respective EPA/DOT regulations would probably not withstand a proper Judicial Review.
What is the highway “gas mileage” for a flex fuel Buick Lucerne? According to the EPA its 26 mpg. Gallon of what? Why gasoline of course. However, in reality, by the EPA testing results, a flex fuel Buick Lucerne’s E-85 highway gas mileage is actually 173 miles per gallon of gasoline (26/.15 for E-85 calculation of actual “gas mileage”). The maker of flex fuel vehicles has provided a product which actually achieves 173 miles per gallon highway of gasoline, the fuel which the EPA and the DOT purport to regulate under the Clean Air Act and the CAFÉ legislation. The EPA regulation compels the auto maker to misrepresent the mileage as 26 mpg fuel economy which we believe violates the auto companies liberty interest to display its true “gas mileage.” Although we believe the application of this EPA/DOT rules would not pass a rational basis review, we also contend they these rules should receive a higher intermediate level of scrutiny, since they collectively unreasonably restrict the liberty interests of the automaker, namely the rights of free speech of the auto maker to inform its consumer. Further, the regulation deprives the auto company of property, namely its profit for having to comply with an inaccurate calculation for its Corporate Average Fuel Economy (CAFÉ) in the form of fines.
Further, rules regarding the use of high occupancy vehicle lanes on Interstate Highways such as those in California discriminate against E-85 flex fuel vehicles. These regulations would similarly fail even a rational basis review.
An action based on the foregoing would help to establish public policy goals of promoting clean fuel by stimulating federal and state governments to enact clean fuel E-85 friendly policies. One can make the case that the combination of CAFÉ/Emissions conflicting rules have been a failed regulatory regime that has created market distortions and resulted in higher cost of vehicles, less profit, and ultimately a reduced flow of new technology to the market place which has driven consumers to purchase used vehicles. Suppose an economy where 20 percent of vehicle sales are new with 80 percent being used. A shift to an economy with less stringent CAFÉ/Emissions and voluntary ratings may increase sales to 30 percent new 70 percent used, thereby increasing the flow of new technology to the market place. The Chevy Malibu achieves higher fuel economy than the Camry or Accord, this is clearly the result of free market competition and not CAFÉ standards. CAFÉ/Emissions standards also deserve heighted scrutiny for their adverse impact on families with children which require larger vehicles such as SUVs. Thus stricter CAFÉ/Emissions combination which ultimately reduces profits and increases costs is not necessarily in the public interest. Prior studies have ignored the impact of a slowed flow of new technology from increased vehicle cost to the average consumer on the total market. Actual results of CAFÉ/Emissions in the U.S. have yielded less safe, smaller vehicles which are less able to navigate highways alongside the dramatic increase in 18 wheel tractor trailers on the highways which are the primary culprits for fuel use and emissions output.
Continued: Turning the tide against CAFE.
Just as the DOT/EPA or statutes do calculate the type electricty (nuclear, coal, etc.) used to charge an electic hybrid in the CAFE/emissions regime or its environmental impact; the government has no rational basis basis to discriminate against flex fuel technology (which is probably cleaner/safer overall anyway).
Further, such discriminatory treatment of flex fuel amounts to an unconstitutional sumptuary rule (regulating consumer spending choices). The Framers specifically denied Congress sumptuary authority at the Constitutional Convention of 1787 where the Mason sumptuary amendment was defeated by a nearly unanimous vote. We contend that sumptuary rules are prima facie unconstitutional (we don’t dismiss the possiblity that CAFE itself may one day be held unconstitutional itself from the Framers intent). Such an application of CAFE/emissions rules by DOT/EPA discriminate against clean flex fuel in the way that we contend is sumptuary and may therefore be held as an unconstitutional application of the statutes. The DOT/EPA have no mandate, obligation, prerogitive, or lawful purpose to assume a flex fuel vehicle uses all gasoline and not E-85 in its CAFE/emissions calcuations. Consumer interest in fuel cost is merely informative and should not be part of CAFE mandate placed on the automaker. The current CAFE/emissions calculations buttress an undue burden on commerce. The consumer’s choice of fuel use is not the automakers prerogative. Courts have held consistenly that manufacturers are not responsible for the consumer’s use of someone else’s product (ie. the fuel producer’s product). (eg. Simonetta v. Viad Corp., No. 80076-6, 2008 WL 5175068 (Dec. 11, 2008), cf. Baughman v General Motors 780 F.2d 1131).
The American auto makers true CAFE/emissions therefore should include the true “gas mileage” of flex fuel vehicle. In Massachusetts v. EPA (2007, the U.S. Sumpreme Court held that the “EPA must ground its reasons for action or inaction in the statute.” Therefore, we contend that the DOT/EPA have violated legislative intent of the Clean Air Act and CAFE law, since the clear legislative purpose of the statutes is to regulate pollutants and reduce dependance on foreign oil, and not to burden clean fuels, but to promote their use.
Cap-and-Trade proposals, excessive energy taxes and the like create market distortions, increase costs, and damage profits which in sum inhibit the development and flow of new technologies to the market place. Reducing the cash flow of producers and consumers doesn’t work. It is in part a reason for the failed CAFE/emissions regulatory regime. Punitive regulatory and tax regimes damage profits and thereby discourage innovation. We suggest system bases on disclosure and voluntary incentives.
Is the DOT/EPA CAFE/emissions calculation which discriminates against flex fuel a violation of trade agreements like the WTO? American automakers may be able to seek relief from regulatory discrimination by the DOT/EPA as a barrier to trade in the WTO. Moreover, such a ruling by the WTO or the Supreme Court would also pre-empt California from ignoring flex fuel vehicles in its emissions calculations.
typo correction above
Just as the DOT/EPA or statutes do NOT calculate the type electricty (nuclear, coal, etc.) used to charge an electic hybrid in the CAFE/emissions regime or its environmental impact; the government has no rational basis basis to discriminate against flex fuel technology (which is probably cleaner/safer overall anyway).
Mr. Brinkman,
A repeat of my question from last Friday, 13 March:
~~ Can you tell us the findings of your analysis of how much “embodied energy” goes into the production of a Volt and its several hundred pound battery? ~~
Eccentric Observer and alt propulsion hobbist,
Your equations may be missing many dynamic variables and denominators. Statistics can be re-arranged to say just about anything. You may want to challenge your own thinking. Nevertheless, more efficiency may not always the desireable result, choice, or option. There may be diminishing returns to chasing too much efficiency. Too much science may ignore the artistic side of life. It may be better to be free and less efficient, than to be unfree and efficient. Some may claim dictorship to be more efficient – but for how long?
“Its not just your car, its your Freedom” General Motors
Think about it.
In Summary
The legislative purpose and intent for the various Acts impacting Corporate Average Fuel Economy (CAFE) and vehicle emissions are generally phrased as the ‘nation’s need to conserve energy’, ‘reduce dependence on foreign oil’ (for energy security), and ‘regulate pollutants’. The more general statement regarding the “national need to conserve energy” is too broad and unconstitutionally vague for the government to apply it to Flex Fuel Vehicles (FFV) regarding CAFE/emissions rules. Thus, in a proper Judicial Review, the Court may be persuded to limit the government to “action or inaction grounded in the statute” (EPA v. Mass).
http://www.nhtsa.dot.gov/portal/site/nhtsa/menuitem.43ac99aefa80569eea57529cdba046a0/
UNCONSTUTIONAL LIMITS ON FLEX FUEL CREDITS
The automaker should receive full credit for FFV mileage on CAFE not a partial or limited credit. For example, a 26 mpg E-85 flex fuel car should be counted as 26/.15=173 mpg of gasoline and not a lower weighted average. The DOT/EPA have no Constitutionally sound legislative purpose or authority (express or implied) “grounded in the statute” to assume a flex fuel vehicle uses all gasoline and not E-85 in its CAFE/emissions calculations, since none of the applicable Acts could give a sound reason to regulate clean fuel. Consumer interest in fuel cost is merely informative and should not be part of CAFE mandate placed on the automaker. The current CAFE/emissions calculations buttress an undue burden on commerce, namely the automakers ability to make FFVs and earn a profit. The consumer’s choice of fuel use is not the automakers prerogative. Courts have held consistently that manufacturers are not responsible for the consumer’s use of someone else’s product (ie. the fuel producer’s product). [eg. Simonetta v. Viad Corp., No. 80076-6, 2008 WL 5175068 (Dec. 11, 2008), cf. Baughman v General Motors 780 F.2d 1131]. A holding in the automakers favor by the Supreme Court would be in the public interest since it would give government an incentive to increase flex fuel availability at the pump instead of nickel and diming the automaker with rules and fines.
The government clearly discriminates against flex fuel vehicles (FFV) in its calculation for CAFE. Just as the DOT/EPA or statutes do not calculate the type electricty (nuclear, coal, etc.) used to charge an electic hybrid in the CAFE/emissions regime or its environmental impact or long run cost to the consumer of increased utility bills. The government has no rational basis to discriminate against flex fuel technology (which is probably cleaner/safer overall anyway). These types rules applications which burden clean flex fuel vehicles (FFV) are probably unconstitutional through their sumptuary as well as capricious and arbitrary nature.
CAFE studies have ignored the negative impact on technology flow from decreased profits increased costs to consumers who are often forced to buy older used models. The studies ignore the safety implications of smaller less safe vehicles for families with children.
Well to wheels also needs to take into account externalized costs. Ethanol from corn, wood chips, or algae does NOT need a trillion dollar military defending it. It also doesn’t require sending our national treasure to terrorist supporting kingdoms. Corn, trees, and algae absorb C02 when they grow; oil on the other hand fossil fuels just releases stored ancient C02. Electric power for cars can come from dirty coal fired plants or it can come from renewal sources like solar, wind, and geothermal. We need to look at the whole picture, not just the misleading PR from some Green Washing Energy Multinationals wishing to sell us a “pig in a poke”.
Mr. Brinkman,
I repeat my question from March 13th:
You’re right, “well-to-wheels” is important. Can you tell us the findings of GM’s analysis of how much “embodied energy” goes into the production of a Volt and its several hundred pound Li-ion battery?