PROMISES PROMISES

PART 3 of 3

Facts and Fantasies on auto emissions


We begin to see that far from being at least a good start at reducing tail pipe emissions, the 2005 Voluntary Agreement injures the public interest. Here is a list of just some of the defects we have observed:


1. The agreement is primarily an intention to note or witness what is happening in the auto making field that would be done, and largely has been done, without any agreement.

2. The level of gas efficiency has not been going up, it has been going down for over 15 years and this agreement masks that fact while providing no improvements of its own.

3. This agreement is fundamentally BAU or Business As Usual in car making. If we need to reduce emissions in a serious way, we are deceived by it.

4. As a result of the way we have watched our Federal Government proceed Canada is pretty well at the bottom of the performance list for western nations. Only the USA is worse, though we are not even sure of that. Apart from Kyoto treaty obligations we are a long way from Japan or the European Union. It is stated in one of the best studies of the whole question: "The United States and Canada have the lowest standards in term of fleet average fuel economy rating, and they have the highest greenhouse gas emission rates based on the EU testing procedure".
(Greenhouse Gas Emissions and Vehicle Fuel efficiency Standards for Canada. Pollution Probe. February 2005. p.142)

5. By supporting this Agreement the Federal Government is assisting the car makers to avoid reductions they could and should be making, and hiding from Canadians that the Government already has a law that it can and should Proclaim, the 1976 Regulatory statute we have had on the books since then, and move promptly to regulate standards and enforce them.

6. In going along with the car makers the Federal government has allowed itself to be gradually moved away from legitimate public policy in reducing harmful emissions and into the promotion of sales interests of the car makers, which are not regulatory interests at all. The development of improved air conditioning in cars will reduce emissions overall by about 1.2 Mt CO2 e (as we can see from the California university study, Impact of Canada's Voluntary Agreement. U of California (Davis). Institute of Transportation Studies.N.P. Lutsey 2006) but that object is pursued to please buyers, not to cut emissions. There is no need to push the car makers to please customers, as they are regularly doing that anyhow. We are permitting a car maker distraction activity to deceive the public.

7. Much the same can be said about the gradual substitution of lighter parts or new materials in the construction of car engines and bodies, which is also contributing a small amount to reductions (or increased power), as we can learn by review of the Lutsey study. It is however ridiculous for the Government to stand beside the industry ad men as they brag about the marvels of tail pipe emission reductions being achieved when the little that is done is simply the normal development of autos and is not undertaken to reduce emissions.

To do that would require the setting of standards that forced the car makers to substitute emission reduction for power increases, which they do not wish to do and do not have to do at present. Thus power improvement itself will lead to a modest 0.9 Mt CO2e emission reduction over the whole period of 1999 to 2010, but we need to do a great deal more than that. The same goes for variable valve lift, direct gasoline injection, cylinder deactivation and the other high tech terms we have been fed.


Despite industry bragging in the web page of the Canadian Vehicle Manufacturer's Association, we have not adopted a non-contentious way to bypass controversy and magically deliver painless emission control, we have just put ourselves in the position of suckers applauding carnival pitchmen while those elected to serve our true interests have gone along for the ride. If there have been any real improvements that is due to the influence of US standards development, which died over a decade ago excepting the push from California. However the Americans have not been heroes either, and we bump along at the bottom of world efforts, with them.


8. US standards are now voluntary as the Bush administration doggedly seeks to sabotage and delay any standard setting, though the EPA is going forward with Tier 2 now that the Supreme Court has largely brushed aside the Bush administration hindrance that delayed Federal Standards for CO2. While California has projected improvements in its 2006 legislation, it is contested by the car makers in the Courts. It is not that the goal of a 1/3 improvement over current standards (if they were being met) in the US, or the goal of 120 grams per kilometer in the EU, ( a standard being fought over now), cannot be realized. It is a question of the public will involved. against the opposition of the car makers.


9. The car makers use many dodges to fight against standards improvements. One is the claim that Canada is not a big enough market to do anything that varies from what the Americans do. We have seen that all kinds of different initiatives are happening in the US with individual states adopting the California law of 2006 (they can be called CAFE plus, or Tier 2) because of the failure of the Federal government to act. California does have regulation now and its population is similar to Canada. If they can cause the car makers to get moving on standards, and they certainly have, why can we not do so. We are a separate sovereign country and should have less difficulty than California. There some movement in some Canadian provinces to pick up the California legislation (BC).

10.There is good reason for suspicion that the car makers in Canada will not meet their promise to deliver 5.3 Mt CO2e even though they intended to do it without moving a muscle, so to speak. This is because they must first of all get the Federal government to agree to give them credit for everything that has happened to cars, which normally would be politically assured.

As Canadian federal politics is now developing that could become a very unpopular move for a government heading into an election before 2010. We do not know what the individual car makers have been doing, and it may be their industry association does not either, and never will. If the agreement becomes no longer a useful publicity tool, the car makers will simply drop it, behind a screen of lies about how the government has not been reasonable. Then our government will have no agreement, no progress that is provable, no data, no data bank for the past 10 years from industry, and no knowledge of what each company has been doing.

Of course it could be that the government has been collecting data all this time. One imagines federal inspectors secreting this or that car and measuring the tail pipe product. But it is pretty hard to get industry or company wide averages out of that. So it may be the case that the sooner the government tells the car makers to take their agreement and shove it, the better.

11. We can see some of the double dealing we can expect from the car makers in a few items already. For example, the Tier 2 regulations coming up in the US. Will the car makers get credit for those, say in nitrous oxides? One industry statement is referred to in the Lutsey study to the effect that there is "no double billing for NOx" but in a different statement it is set out that the Canadian auto industry expects to be credited with GHG emissions reductions for their actions in response to the Tier 2 standards ( in this case established for pollutant criteria control).

12. The same problem will surely come up with respect to fuel substitution such as blending ethanol in gasoline. A government official has stated that this is outside the Voluntary agreement but that is probably because the government has its own program to promote ethanol, so it would not want to see any improvement credited to two different programs. But who is ready to bet that the car makers will not claim it, and have already figured on a credit for it. The California study estimates that ethanol will reduce emissions by 0.68% in one year, 2010, and this is about 12.8% of the total of 5.3 Mt CO2e the car makers have promised.


13. And there are wild cards that the car makers will surely make a fuss about. Real world driving is not the same a lab conditions tests, and so standards need to allow for reality. There is plenty to argue about here. The Voluntary agreement assumes a gap of 20% but each new study seem to be widening the gap. Will our government throw up their hands when the car makers go off into a long argument about that.This item may amount to as much as 1.12% of the reduction (21.2% of the total 5.3 Mt CO2e) car makers promise.

14. It has turned out that tire pressure has a role in emission reduction and drivers need to be educated about that (apparently it could amount to as much as 0.5% of on road fuel use. The car makers in Canada have already announced they will be claiming for that. Can we doubt they will put in a claim for the One Tonne Challenge (a program since abandoned by the new Conservative government in its determination to get rid of whatever the last government was doing), and other driver education programs. But how can car makers claim a credit for an improvement in emission reduction associated with a government mounted consumer education program? They will.


15. So we can see, following the detailed account in the California university study, the car makers can meet the promise of 5.3 Mt CO2e if they are credited with everything that has reduced emissions, whether it was the result of outdated reference case projections from 1999, or involved technologies already in use when the Voluntary agreement was signed, whether it was already set to occur due to previous agreements or would occur regardless of the Voluntary agreement (Tier 2,on road real life driving adjustments, harmonized fuel consumption with USA, ethanol adjustment) or whether the result of regulations made for reasons other than climate change such as Tier 2 for specific pollutants and tire monitoring programs for safety reasons, even driver education.

There is plenty for government to resist there in the Government-Industry committee set up by the Voluntary Agreement to "adjust" the claims of the car makers to ensure "fairness". It is hard to see even the pro-business Harper regime going for all of it, but where are we if they do? And how will we know what they are about to do until after they have done it and put out the usual joint statement.



16. If the industry obtains credits, as described in the California study, since the Government-industry group that is supposed to be functioning under the Voluntary agreement has not published anything, then the result can be a little greater that 5.3 Mt CO2e. The industry will make its "contribution". The Lutsey study also considers a more strict definition for the car makers to match. This one would be based on new emission reductions that did not include already established programs as GHG reduction initiatives. In other words this program would not credit the already established vehicle fuel and technology trends. In this case the target of 5.3 Mt CO2e reduction by 2010 is not met.


17. The conclusions of the California study are sobering:

"The question arises as to whether the intent of the MOU is to witness a 5.3 Mt CO2e emission reduction or to actually be responsible for causing a 5.3 Mt CO2e emission reduction. It is apparently possible for the MOU agreement to be met with little or no impact on GHG emissions from Canada's fleet. If the MOU oversight committee decides to credit each of the mechanisms discussed, the primary role of the Canada GHG MOU would be to simply re-label a series of already-established programs as a GHG reduction initiative. "

Impact of Canada's Voluntary Agreement Lutsey U of Cal (Davis) 2006 at p.31


18. For the reasons set out Gramps concludes that the industry will try to push the government into accepting industry credit that makes the Agreement a mockery. Whether it succeeds or fails depends on public pressure on the issue of accountability. Either way, we have lost a lot of time. The government should be urged to proclaim the 1976 Regulatory legislation, move quickly to establish the equivalent of Tier 2 as a Regulatory goal to be met in tandem with the progress of the California standards (assuming court challenges to that program fail) and move on to rapid implementation.

August 28,2007


Conclusion of the post Promises, Promises on Auto Emissions

Gramps

Gramps