Everyone Should Weigh In on the New EPA Vehicle Ratings

I recommend that everyone learn about the new EPA ratings that, when implemented, will represent the first change from the famous city and highway MPG ratings that were put into effect decades ago. In fact, as you’ll notice when you go to the site linked above, the EPA, in conjunction with the Departments of Energy and Transportation, actively solicits your input on the new system under consideration. Here’s mine:

Both versions of the proposed plan have the potential to confuse more than they clarify. Apparently, there is an effort to migrate from the old MPG ratings to new numerical and letter ratings with as little change as possible. For example, this results in a new number for electric vehicles: the number of miles on a charge. That, of course, is the equivalent of providing the size of a car’s gas tank; it has nothing to do with the issues in question, which are simply:

1) What is the cost of operating this vehicle? And

2) To what degree is this vehicle environmentally friendly?

Moreover, letter grades actively invite criticism and doubt, ::continue::on the basis that they’re often subjective as they are used in our culture. (“Oh, I got a C+. Like an idiot, I forgot Mr. Jones doesn’t like essays that question his position on gun control.”)

The cost of operating the vehicle is the average cost per mile to fuel the car, given the national average prices of gasoline and electricity. If the vehicle has no plug, this is the average price of whatever liquid fuel it takes, divided by the MPG. If it’s a battery electric, it’s the average cost per kilowatt-hour divided by the car’s use of kilowatt-hours per mile. If it’s a plug-hybrid, this is less clear, but should be provided as a range depending on the percentage of miles the owner believes he’ll drive in the battery-only range.

The degree to which the vehicle is environmentally friendly should also be expressed as a single number – perhaps pounds of carbon per mile, using the national well-to-wheels averages associated with the fuel – or blend of fuels -- in question. Obviously, this will change over time (even if the cars themselves remain constant) as the migration to renewable energy creates an ever-widening discrepancy in favor of EVs.

Notice how this suggestion represents an improvement over the proposed plan in two important ways:

Clear, numerical expressions of the only two relevant data points, and

No letter grades that would appear subjective or disputable.

I’m sure I’ll see this implemented exactly as it’s written here, and I’m expecting a note of appreciation from the EPA to arrive any minute. Just kidding.

Craig Shields is editor of 2GreenEnergy.com and author of "Renewable Energy -- Facts and Fantasies" (Clean Energy Press, 2010)