Gobbledy-Gook: The EPA's “SmartWay” is Stupid, But You Knew That, Right?

Humanitarian and patriot Dan Collins reads and interprets the EPA's SmartWay drivel so you don't have to.

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I ran across the EPA's SmartWay scoring system for vehicles when I was researching the SmartWay Transport program for a trucking company that wanted some copywriting for their web site.  SmartWay Transport was a Bush-era program aimed at partnering EPA resources and freight companies in order to come up with the best ways of maximizing resources, especially fuel.  For example, the EPA provides loans so that companies can invest in battery banks on their cabs that keep trailers cool and bunks warm when drivers are laying up en route to their destinations. This reduces idling times.  EPA also supports the use of smaller diameter tires with better aerodynamic profiles, a variety of cowlings and flairings that reduce drag and the amount of debris thrown up by tractor-trailers.

On average, these sorts of investments pay off over anywhere from one to three years, far less than the average "life-span" of a tractor.  Whether one believes in Global Warming or not, it makes economic sense to promote and to adopt the best of these public-private partnered ideas--the overwhelming majority of which originated in the private sector and were subsequently approved by the EPA as both environmentally sound and cost effective.

That was then, and this is now, though.  If you go to the vehicle ratings these days what you find is gaming the system in the service of politics. I am an anthropogenic climate change denier or skeptic , but for the purposes of this discussion I'm going to try to "bracket off" that debate, except insofar as it's relevant to the selection criteria employed by the EPA in telling Americans which vehicles demonstrate their good global citizenship, and undergirding their advice with market interventions.

Here is the homepage of Smartway's automotive guide

They let you know that they're here to help you choose your vehicle wisely, and you're confronted with the familiar pull-downs for Year, Make and Model.  Some of the variation in the ratings, and some of the confusion on first glance is generated by the site's inclusion of variations for model depending on whether they meet California's more stringent guidelines.  Those models that do meet the requirements of getting good gas mileage scores plus good emissions scores appear with the SmartWay logo next to them.

Well, searching by year, make and model doesn't provide a lot of side-by-side comparative information, so you can also choose to use another set of pull-downs to select a year and a category of vehicle (such as small, mid-sized, mini-van, SUV), and pull up a whole class of them listed from A-Z, by manufacturer.  On the right-hand margin where you find the splashy logos, or not, you can see which ones met the guidelines and achieved the SmartWay designation, or the even more elite SmartWay Elite designation.  But what does it all mean?

We're in the process of imposing California's standards on the rest of you.

Naturally, you go to SmartWay's About the Ratings page to find out.

The best environmental performers receive the SmartWay designation, which means the vehicle scores well on both Air Pollution and Greenhouse Gas.

EPA periodically evaluates the greenhouse gas and air pollution score criteria to ensure that they accurately reflect the state of the vehicle fleet, while enabling us to reserve SmartWay certification for the cleanest, most fuel efficient vehicles available. As a result, environmental scoring thresholds are subject to change. Please note that a vehicle's scores and SmartWay status reflect its environmental performance relative to other vehicles for model years with the same scoring thresholds only.

EPA and the California Air Resources Board [CARB] are working together so that that this rating system continues to be harmonized and effective nationwide.

There are a couple of interesting things here, but for the moment, let the cynics among us just note that "harmonization" with CARB is just bureauspeak for saying that we're in the process of imposing California's standards on the rest of you.

Continuing:

Emission standards are for the major pollutants in vehicle exhaust:

NMOG, NMHC, or THC—types of carbon-containing compounds, including hydrocarbons

NOx—Oxides of Nitrogen, which combine with hydrocarbons to create smog

PM—Particulate Matter, tiny particles of solid matter that lodge in the lungs and deposit on buildings

CO—Carbon Monoxide, a colorless, odorless, poisonous gas

HCHO—Formaldehyde, a lung irritant and carcinogen

Well, hallelujah!  No mention of CO2?  That's awfully sporting of them. 

They go on to discuss fuel economy, stating that better mileage is good, yadda yadda, assuming "city" driving 55% of the miles and "highway" 45% of the miles, yadda yadda, YMMV and . . . oh, wait:

Vehicles with higher fuel economy save natural resources and create less carbon dioxide–a greenhouse gas–than vehicles with lower fuel economy. Every gallon of gasoline burned puts 20 pounds of carbon dioxide into the atmosphere and takes money out of your pocket.

Scientists.  Not some scientists.  Just scientists. 

I don't like where this is going.  Naturally, we are then confronted with the real nub:

Greenhouse Gas Score

This score reflects emissions of carbon dioxide (CO2)and other greenhouse gases. Scientists say that increasing the concentration of greenhouse gases in the atmosphere will change the planet's climate.

Oh, yeah.  Scientists.  Not some scientists.  Just scientists.  Having thus established the validity of their suppositions, we get the following:

The Greenhouse Gas Score is based on the vehicle's fuel economy. Vehicles with higher fuel economy burn less fuel to travel the same distance. As less fuel is burned, less CO2 is emitted. Vehicles with higher fuel economy receive a higher Greenhouse Gas Score.

Okay, I'm with you there, just so long as the scoring is based relative to other vehicles.

The emissions of CO2 and the Greenhouse Gas Score vary by fuel type, since each fuel type contains a different amount of carbon. 

Well, sure, but isn't it the oxydization of hydrocarbons that powers the vehicle, and isn't this all getting a bit confusing, now that we have two different pollutions standards and multiple fuels?

The score reflects a vehicle’s tailpipe greenhouse gas emissions. A vehicle’s CO2 emissions are based on the carbon content of the fuel used and the fuel economy of your engine. In addition to CO2, the GHG score includes the tailpipe greenhouse gas emissions of methane (CH4) and nitrous oxide (N2O), which are largely dependent on a vehicle’s emission control technology and the miles traveled. Currently, the GHG score does not account for leakage of air conditioning refrigerants such as hydrofluorocarbons (HFCs), or emissions of black carbon. Both of these pollutants are believed to be relatively small contributors to vehicle GHG emissions. 

And, here it comes:

Another way to calculate the greenhouse gas impact of your vehicle includes full fuel lifecycle estimates, considering all steps in the creation and consumption of the vehicle fuel, from production and refining to distribution and final use. Including full fuel lifecycle impacts on greenhouse gas emissions tends to improve GHG scores of vehicles using biofuels by a few points when compared to vehicle performance with petroleum. Including accurate full fuel lifecycle emissions in the green vehicle guide scores requires significant updating of the guide’s existing data for biofuel technologies, thus it is not currently included in the current guide. 

Now you've really opened up a can of worms.

It makes sense, doesn't it?  I mean, anyone who's driven by refineries at night sees the plumes of burnt off hydrocarbons lighting up the sky in the distance.  And heck, exploring for oil, putting down wells, transporting it . . . all of that consumes energy and releases "Green House Gases," yeah?  Shouldn't that all be in the calculations?  Sure.

Hefty calculations with large fudge factors

But what about those biofuels?  You've got to lay down a lot of petroleum based fertilizer for that corn that you turn into ethanol.  And there are plows and combines.  And then there's the use of water resources, and the energy required to turn it into fuel,... and then distribution,... and then reduced fuel efficiencies,... and engine wear requiring that engines be replaced more often... and those engines are manufactured in plants that use power that causes GHG emissions,... and those plants use metals that come from mining and refining operations … and those use power that causes GHG emissions, transported to mills.... and so on and so forth. 

That's a pretty hefty calculation with an awful lot of variables, and as always, it seems, it creates a lot of wiggle room for fudging in the interests of one's interests.

If you'd like, you can look at the PDFs regarding vehicle scoring, and if you want to know more about GHG, you are directed...

. . . to the EPA's website.

Hmmm, but what about diesel, I hear some of you asking.  Let's see. 

It's over there under the FAQs that ask and answer: Why do some diesel vehicles receive low Air Pollution Scores even though they have good fuel economy?

 You can look for yourself if you enjoy brainfreeze, but let me sum the insanity up.

Smog. When is a problem not a problem? When it is unionized.

Sometimes, apparently, smog is a bigger problem than GHG emissions, even though the latter will undoubtedly swallow up Al Gore's beachfront properties sometime in the near future . . . unless we buy carbon credits that will line his pockets. 

Other times, smog is not so much a problem.  Smog has been a problem in the not-so-distant past in California, it is true, but is a little smog really that big a problem when we're talking about the survival of the planet, here?  Mind you, if the EPA did place more weight on emissions of particulate matter, sulfates and oxides of nitrogen than on CO2, it would seem sensible to me.  But for this mechanism to have any coherence, the EPA needs to demonstrate the assumptions and research behind their weighting.  Otherwise, it's all too easy to try to manipulate the market in any direction that is profitable to the institution and its allies.

By and large, the exclusion of diesel vehicles benefits the American auto industry.  And that's nice, since the government gave so much of two of those companies, bailed out with taxpayer cash, to unions who are sympathetic to the political aspirations of Progressives, and to their policies, such as ObamaCare, at least till such time as they seek exemptions.  US automakers do know how to build diesel vehicles--mostly trucks--but they are presented instead with incentives to create $40k-per-shot boondoggles like the Chevy Volt.

Less sprawl, fewer Red State barbarities

On the whole, too, shouldn't American citizens, as citizens of the world, renounce their use of costly beasts such as diesel pick-ups?  Practically nobody in Hyde Park uses them, though here in the benighted Vermont countryside one sees them with some frequency, hauling firewood and doing other awful stuff.  Certainly, people should give all that up and move to cities, where they will use less resources, theoretically, and where they can give up their keys, so that there are more people who live the righteous life, smaller families, less sprawl, fewer Red State barbarities.

Speaking of smaller families, it's true that the SmartWay standards are measured among vehicles, but those standards are measured among all vehicles in all classes, so that if you are searching for a mid-sized SmartWay approved vehicle, your choices are much fewer than if you were searching for a small one. 

There are only a handful of SUVs that qualify, and only a handful of 4-wheel and AWD vehicles, though here in Vermont, especially in winter on the dirt roads, that's a very nice thing to have from a safety perspective.  Yes, I do wish that Subaru would go back to making its cars with 4-wheel on demand, rather than continuous AWD, because of the gas mileage savings during good weather.  But we're talking about the safety of the planet, not the safety of your family (which should be smaller than it is, by the way) even if that means that all those pensions and government programs like Social Security are unfunded pie in the sky.  Goodness knows, the fierce urgency of now requires us to put all that aside, so that we can stop sipping on our Slurpees™ and help Obama push the car out of the ditch in D rather than R.

It's not all academic, either, since the EPA offers subsidies (in the form of discounted loans) for individuals and businesses purchasing their cars of choice.

Of course, the most sensible thing of all would be to rate cars on the pollution (as regarded by the EPA) generated in their creation, their use, and their recycling.  Let's say that a diesel variety of an auto tends to last twice as long as the gas variety.  Calculate in the replacement cost of the latter vehicle in pollutants.  You'll see all of the hybrids getting very high scores here, too, without regard to the rare earth elements used to produce them, and the resulting ground, air and water pollution from some very toxic chemicals, and the much-ballyhooed American reliance on China for all those materials.

But you've just got to "bracket" some things, you know? That's important when you're the EPA whose invisible motto is: “We're from the government and we're here to control you.

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Dan Collins

Dan Collins hails from Boston. Married with three children, he has lived and taught abroad in Italy, Mexico, the Czech Republic, and other places. Dan has been writing online for several years, and was a regular at the linguistically oriented Protein Wisdom blog before striking out on his own as the founder and leader of Piece of Work in Progress. He and his family and his kittens live in Vermont--where Dan continues to study Renaissance art and poetry (his first scholarly love).

View all articles by Dan Collins

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