CARB ZEV credits for rapid refueling, gone in 2018?

[TonyWilliams]

The answer to the "DC fast charging" credit question is HYDROGEN.

The whole purpose was to reward hydrogen cars, which is what the state is really supporting.

Hydrogen cars get 9 credits each.

A Nissan LEAF, with or without DC charging, gets 3 credits.

 

[ydnas7]

The answer the "DC fast charging" credit question is HYDROGEN.

The whole purpose was to reward hydrogen cars, which is what the state is really supporting.

Hydrogen cars get 9 credits each.

A Nissan LEAF, with or without DC charging, gets 3 credits.

CARB's intent is to promote Hydrogen as the ultimate ZEV
never mind its less efficient than a frugal diesel

fast flow diesel, now that rapid refill :lol:

battery swap will stay around, just so Elon Musk can say its faster than fossil fuels (petrol, diesel, hydrogen)
but fast charging is where its at

What chances do you think the government would make hypothetical DC charging credits to be CCS Frankenplug only? The least likely to given credits is Tesla SC, the most worthy of credits is Tesla SC .

 

[TonyWilliams]

What chances do you think the government would make hypothetical DC charging credits to be CCS Frankenplug only? The least likely to given credits is Tesla SC, the most worthy of credits is Tesla SC .

Zero chance. None of our state or federal government programs actively support CCS over other DC charging standards.

There is no "national" DC charging standard in the US, or California. The CCS folks would certainly want you to think otherwise.

 

[edatoakrun]

Why has ARB never considered the vehicles ability to utilize higher kW DC charging as a factor in awarding ZEV credits?

Excellent point...

In any case, I am not inclined to complain about Tesla's apparent sluggishness in terms of battery swapping infrastructure. They have done a superb job of deploying their Supercharging infrastructure and deserve kudos for that...

And, IMO, Tesla should be given extra ZEV redits for DC charging, which they have not, in common with the rest of the DC capable BEVs.

But IMO it's beyond ridiculous that ~$100 million worth of ZEV credits (three extra per Tesla S) should have been granted before any Battery swapping ever occurred, and that now Tesla is arguing that only 4% of the Teslas In CA, swapping one time, twice a month on average, at one station, should now allow Tesla to collect Five extra ZEV credits for every S sold.

Analysis: Understanding Tesla’s Potemkin Swap Station

http://dailykanban.com/2015/05/analysis-understanding-teslas-potemkin-swap-station/" onclick="window.open(this.href);return false;

Have you considered how Tesla's battery swap is even less scalable than its silly "free Supercharging forever" scheme?

Say you are an S driver who wants to waste your time and cause a much larger toll on the environment by driving from southern California to southern Canada along I-5, and return ~the same route. (I know, why not just fly, but people actually do this).

Of course, a trip of thousands of miles like this, requires hundreds of dollars worth of kWh, and probably costs much more, in dollars worth of degradation to your battery.

But if you swap at Harris ranch on the way up, degrading someone else's battery pack, and use "free Supercharging" the rest of the trip...

You think the $80 in swapping fees is going to magically pay for the hundreds (or maybe thousands of dollars) of real costs you have just incurred on this trip?

Sure, it will work for a while, but only if CARB gives Tesla the millions of dollars worth of bonus fast refueling ZEV credits, and lets the rest of us pay for it...

BTW, I'm no fan of the nine-ZEV-Credits-per-FCV subsidy for "fast refueling" either, but they at least claim to have a plan to have a ~59 H station network in place within ~ a year.

I notice it looks the collective bureaucratic decision is to screw over the ~Northern third of California by omitting this publically subsidized infrastructure, just like as been done (so far) with public DC.

http://www.cafcp.org/stationmap" onclick="window.open(this.href);return false;

 

[Zythryn]

...

But IMO it's beyond ridiculous that ~$100 million worth of ZEV credits (three extra per Tesla S) should have been granted before any Battery swapping ever occurred, ...
...

CARB set the rules, Tesla followed them.
The cars needed to be "capable" of the battery swaps, and they were.
If you want to get ticked off at someone, save it for CARB.

As for their free charging forever, I think it's wonderful, and brilliant marketing.
I suppose time will tell, and I don't know that they will continue that with the Model 3.
It is one of the top 5 reasons I won't be buying from anyone else (unless they adopt a similar plan) ever again.

 

[jpadc]

Sure he is sucking up government subsidies wherever he can, but at least he is producing SOMETHING with them. My bar may be ridiculously low, but I'm just glad to see real tangible products being created with that money (or at least most of it) --- which unfortunately seems not to be the norm when it comes to government subsidies for so many things.

 

[edatoakrun]

...

But IMO it's beyond ridiculous that ~$100 million worth of ZEV credits (three extra per Tesla S) should have been granted before any Battery swapping ever occurred, ...
...

CARB set the rules, Tesla followed them.
The cars needed to be "capable" of the battery swaps, and they were.
If you want to get ticked off at someone, save it for CARB...

You might consider actually reading the posts you comment on.

Previous page:

edatoakrun
...I'm not really concerned with whoever it was at Tesla who made the decision to grab the free candy CARB was offering in past years, and may decide to in the future.

Tesla is a for-profit corporation, and its officers and employees have a duty to shareholders to seek profits.

I am concerned that CARB made the ill-considered decision to award Tesla the excess three credit per S sale in the first place, and not just because the excess credit sales was egregious rent-seeking activity by Tesla.

The fact is, every Tesla sale S in California (and, If I understand correctly, the other nine ZEV states) gave an extra three credits that Tesla could and did resell to other manufactures, many of which were unenthusiastic (to put it mildly) about selling their own BEVs, and chose to evade the mandate by buying the excess credits from Tesla, rather than put more of their BEVs on the road.

So every tesla S sold (seven credits in total) may have reduced sales of other (three credit) BEVs, by a factor of more than two.

In other words, it looks like there certainly would by many thousands more BEVs on California's roads today, if Tesla had never sold any S's here at all.

Is that sort of market distortion really what CARB should be trying to achieve, when it makes decisions on awarding ZEV credits?

="Zythryn"...As for their free charging forever, I think it's wonderful...

Does Santa Clause give you all the other goods and services you consume daily?

If not, did it ever occur to you that those goods and services are readily available, only because you pay for them?

 

[edatoakrun]

You almost have feel sorry for the TSLA rep who showed up at Carb hearing just last week, arguing that Tela S battery swapping was a viable fast refueling program, and arguing for additional future ZEV credits.

The long statement by Elon Musk below, might be paraphrased (IMO) as:

We knew from the beginning Tesla's fast refueling plan was so impractical and half-assed, it would never work, but we gave it a try anyway.

Of course, the extra ~$100 million of fast refueling ZEV credits we soaked CARB for, had nothing to do with our actions...

Elon Musk Comments On Failed Tesla Battery Swap

At the Tesla shareholder’s meeting, CEO Elon Musk responded to a question on the status of Tesla battery swapping. His response seems to indicate that battery swapping is dead (or extremely unpopular, at least), as Tesla Model S owners prefer Supercharging.

Here’s his response in its entirety:


“We have the LA-to-San Francisco pack swap capability in place, and I believe all Model S owners in the California area have been invited at this point to try it out. And what we’re seeing is a very low take rate for the pack swap station. So we did an initial round of invitations, where we did basically like 200 invitations, and I think there were a total of four or five people that wanted to do that, and they all did it just once. So, okay, it’s clearly not very popular. And then we said, okay, let’s expand that invitation to all customers, but I would expect that all customers roughly behave like that initial sample group.

It’s just, people don’t care about pack swap. The Superchargers are fast enough that if you’re driving from LA to San Francisco, and you start a trip at 9AM, by the time you get to, say, noon, you want to stop, and you want to stretch your legs, hit the restroom, grab a bite to eat, grab a coffee, and be on your way, and by that time, the car is charged and ready to go, and it’s free. So, it’s like, why would you do the pack swap? It doesn’t make much sense.

We built the pack swap into the car because we weren’t sure if people would want to choose the pack swap or not. We thought people would prefer Supercharging, but we weren’t sure, so that’s why we built the pack swap capability in. And based on what we’re seeing here, it’s unlikely to be something that’s worth expanding in the future, unless something changes.

For the Superchargers, as we said in the initial press release, the Superchargers are free. It’s basically free long distance for life, forever. So free long distance forever is what the Superchargers are providing. Now, there are a few people who are quite aggressively using it for local Supercharging, and we will sort of send them just a reminder note that it’s cool to do this occasionally, but it’s meant to be a long-distance thing. But it is free long distance forever, and it’s basically built into the cost of the car. And based on what we’re seeing in terms of the economics, it looks quite supportable.”

http://insideevs.com/elon-musk-comments-failed-tesla-battery-swap/" onclick="window.open(this.href);return false;

 

[Nubo]

You almost have feel sorry for the TSLA rep who showed up at Carb hearing just last week, arguing that Tela S battery swapping was a viable fast refueling program, and arguing for additional future ZEV credits.

The long statement by Elon Musk ...

Elon Musk Comments On Failed Tesla Battery Swap

...Now, there are a few people who are quite aggressively using it for local Supercharging, and we will sort of send them just a reminder note that it’s cool to do this occasionally, but it’s meant to be a long-distance thing. ...

That particular statement really gave me pause. They actually sent customers notes to tell them their behavior "wasn't cool"? Is there actually a polite way to handle such correspondence? "We're watching you and we don't like what you're doing". I generally root for Tesla but sometimes their hubris is beyond belief.

I'm surprised to see that people affluent enough to afford a Tesla would resort to such "camping" behavior to scrounge for free electrons but I guess it happens. Rich people make meals out of free samples too. You're not going to change that behavior with reminders. The policy probably needs to be amended to something like free supercharging anywhere more than 30 miles from home, or some such. Keep road trips free but add enough hassle to discourage all but the most determined misers.

 

[TonyWilliams]

You almost have feel sorry for the TSLA rep who showed up at Carb hearing just last week, arguing that Tela S battery swapping was a viable fast refueling program, and arguing for additional future ZEV credits.

The long statement by Elon Musk ...

Elon Musk Comments On Failed Tesla Battery Swap

...Now, there are a few people who are quite aggressively using it for local Supercharging, and we will sort of send them just a reminder note that it’s cool to do this occasionally, but it’s meant to be a long-distance thing. ...

That particular statement really gave me pause. They actually sent customers notes to tell them their behavior "wasn't cool"? Is there actually a polite way to handle such correspondence? "We're watching you and we don't like what you're doing". I generally root for Tesla but sometimes their hubris is beyond belief.

I'm surprised to see that people affluent enough to afford a Tesla would resort to such "camping" behavior to scrounge for free electrons but I guess it happens. Rich people make meals out of free samples too. You're not going to change that behavior with reminders. The policy probably needs to be amended to something like free supercharging anywhere more than 30 miles from home, or some such. Keep road trips free but add enough hassle to discourage all but the most determined misers.

What about Uber and taxis? (In addition to Ebeneezer Scrouge).

 

[TonyWilliams]

CARB definition of "Fast Refueling" is 95% full in 15 minutes. Hydrogen is exempt.

Notice how it doesn't say XXX miles gained in 15 minutes... just percent of full.

 

[Nubo]

CARB definition of "Fast Refueling" is 95% full in 15 minutes. Hydrogen is exempt.

Notice how it doesn't say XXX miles gained in 15 minutes... just percent of full.

If I were going to intentionally game the requirement against BEVs, this is exactly how I'd go about it.

 

[edatoakrun]

Follow up report and commentary on the DK that Tesla will continues to receive additional ZEV credits (unless CARB finds its own behavior questioned) even though actual battery swapping, even at the single station, does not seem currently active, at least as (not) reported on the Tesla forum thread below.

Tesla Battery Swap: CARB’s Bridge To Nowhere

June 23, 2015 By Edward Niedermeyer

Tesla and California’s Air Resources Board are standing by the controversial “fast refueling” credits that are directing as much as hundreds of millions of dollars to the California-based electric car maker for its little-used battery swap capability. At the same time, both Tesla and CARB admit that battery swap has not shown much promise and CARB staff tell Daily Kanban that they tried to completely eliminate the credits out of concern over Tesla’s “gaming” of the system only to be overruled by board members. The tension between Tesla and CARB’s defense of ZEV credits earned by Tesla’s battery swap capability and their apparent lack of optimism about the technology going forward confirms the fundamental concerns that surfaced in Daily Kanban’s initial investigation: battery swap credits seem to have done nothing to advance the cause of ZEV adoption, Tesla appears to have gamed the credit system for huge financial gain, regulators show little interest in ending Tesla’s obvious abuse and the public remains under-informed about the entire situation.

In a telephone interview with Daily Kanban, CARB’s Emissions Compliance, Automotive Regulations and Science branch chief Analisa Bevan revealed that CARB staff had recommended fully eliminating fast refueling credits for battery swap in late 2013 out of growing concerns that Tesla was “gaming” credits intended to make electric vehicles competitive with gas-powered cars. The “staff solution was to just get rid of [credits for battery swapping],” Bevan explained, but the board rejected that proposal in favor of “a more thoughtful approach.” ...

CARB’s all-too convenient “adjusting to complexities” narrative also just happens to track Tesla’s equally implausible storyline about its battery swap program. At the recent Tesla shareholder’s meeting, CEO Elon Musk continued to pour cold water on the battery swap program that has earned his firm huge amounts of credit-based revenue, even going as far as to suggest that he had never believed battery swap would take off...

Meanwhile, even the policy stakeholders who have helped quietly call out Tesla’s credit gaming in regulatory comments seem oddly at peace with a swap credit program whose only measurable success was its ability to provide Tesla a discreet revenue stream to carry it through to the launch of the Model 3. Simon Mui of the National Resources Defense Council, one of the environmental groups that has argued for better accountability for swap credits, calls battery swap a “trial balloon” and “a technology that’s ahead of its time.” While Mui admits that CARB staff has had to “tidy the ship” as it became increasingly clear that swap credits weren’t delivering on policy goals, he was more worried about “backlash” affecting the overall ZEV program than overfunding a technological dead-end. “We should see [battery swap] as a test case,” said Mui. Emphasizing CARB’s “good intent” and the overall success of the ZEV program, Mui explains that “we don’t want [swap credits] to become the issue that causes the public to lose sight of what the ZEV program is about.”

Yet by refusing to acknowledge the clear failure of battery swap credits, CARB and its stakeholders raise very real questions about who exactly their policies are designed to serve. Were CARB and NRDC really worried about the health of the overall ZEV program, they would be willing to admit in plain English that the swap credit policy had failed, that its reporting requirements have never been strong enough. By defending swap credit policy as a noble experiment years after its own staff tried to kill it off, and even as its main beneficiary admits he never thought battery swap would go anywhere, ZEV program stakeholders run the risk of associating their entire program with what appears to be a highly sophisticated and cynical subsidy of a local automaker. For a policymaker as perennially contentious as CARB, admitting failure when it is this obvious is the only way to defend its broader policies and goals.

Instead, CARB and Tesla are wrapping their unconvincing “noble experiment” narrative in a thick layer of non-transparency. Huge amounts of information critical to measuring the success or failure of the swap credit program is protected by CARB and Tesla as commercially sensitive, protecting it from public oversight...

Staffers for California state representatives who asked not to be named tell Daily Kanban that they are currently looking into the options for a ZEV program audit in response to concerns raised about battery swap credits. Though it is almost certainly too late to prevent Tesla from earning untold millions for a technology it has no intention of making widely available, at least the citizens of California may still be able to gain some better understanding of this expertly-concealed boondoggle and precisely how much money it has diverted to Tesla...

http://dailykanban.com/2015/06/tesla-battery-swap-carbs-bridge-to-nowhere/" onclick="window.open(this.href);return false;

Harris Ranch is getting first battery swap station

http://www.teslamotorsclub.com/showthread.php/31947-Harris-Ranch-is-getting-first-battery-swap-station/page49" onclick="window.open(this.href);return false;

 

[abasile]

CARB definition of "Fast Refueling" is 95% full in 15 minutes. Hydrogen is exempt.

Notice how it doesn't say XXX miles gained in 15 minutes... just percent of full.

This is rather disingenuous.

By avoiding the use of higher SOCs, however, a BEV could theoretically comply with this "fast refueling" requirement. Instead of using an SOC range from, say, 5-95%, a BEV could limit itself to 5-60%. In other words, 60% SOC would be considered "full" and could potentially be attained within 15 minutes with a sufficiently powerful charger. While staying below 60% would reduce the overall utility of the vehicle, it would improve battery life.

Tesla could accomplish this by selling all models with the same size battery pack, while charging less for "ZEV credit cars" that are limited to 60% SOC. They already sort of did this with the early "40 kWh" Model S.

Also, in my opinion, Tesla should be getting those fast refueling credits anyway. But CARB should tighten up its handling of credits based on battery swapping and should instead reward Tesla for its deployment of Superchargers and its customers use of them.

 

[GRA]

CARB definition of "Fast Refueling" is 95% full in 15 minutes. Hydrogen is exempt.

Notice how it doesn't say XXX miles gained in 15 minutes... just percent of full.

This is rather disingenuous.

By avoiding the use of higher SOCs, however, a BEV could theoretically comply with this "fast refueling" requirement. Instead of using an SOC range from, say, 5-95%, a BEV could limit itself to 5-60%. In other words, 60% SOC would be considered "full" and could potentially be attained within 15 minutes with a sufficiently powerful charger. While staying below 60% would reduce the overall utility of the vehicle, it would improve battery life.

Tesla could accomplish this by selling all models with the same size battery pack, while charging less for "ZEV credit cars" that are limited to 60% SOC. They already sort of did this with the early "40 kWh" Model S.

Also, in my opinion, Tesla should be getting those fast refueling credits anyway. But CARB should tighten up its handling of credits based on battery swapping and should instead reward Tesla for its deployment of Superchargers and its customers use of them.

No, there are range requirements tied to the refueling time. See http://insideevs.com/carb-zev-program-changes-tesla-takes-largest-hit/" onclick="window.open(this.href);return false;

 

[edatoakrun]

Video recording of May 31, 2016 webinar, available at this link:

http://www.arb.ca.gov/msprog/zevprog/zevtutorial/zevtutorial.htm

Specifics of CARB 2018-on ZEV and PZEV credits program begin at ~15 minutes into the video.

The rapid refueling credit will be no more.

But the ZEV credit formula's as described there may be subject to change.

CARB may be considering toughening up its ZEV credit program, at least as reported by Bloomberg:

California Ponders Changes to Fuel Rules as Tesla Cries Foul

,,,California’s Air Resources Board has projected 15.4 percent market share for zero-emission vehicles, or ZEVs, by 2025. But because so many credits have flooded the system, automakers may now be able to fulfill their requirements with as little as 6 percent of their fleets consisting of electric or fuel-cell vehicles, said Dan Sperling, a professor of civil engineering and environmental science at the University of California at Davis. To bring those figures back in line, the state may increase its ZEV requirement, said Sperling, who serves on the board.

“If anything, the inclination here is to make the mandate tougher,’’ he said...

The board could strengthen the mandate by simply raising the number of credits and sales automakers need to comply. Or, conscious that the requirements could be seen as a “Tesla subsidy program,’’ regulators could limit the credits that any individual automaker can sell, Sperling said..

http://www.bloomberg.com/news/articles/2016-07-07/california-considers-change-to-fuel-rules-as-tesla-cries-foul

And TSLA's financial disclosure shows just how much money it makes on credit sales, almost $580,000,000.00 in just the last three years:

Regulatory Credits

California and certain other states have laws in place requiring vehicle manufacturers to ensure that a portion of the vehicles delivered for sale in that state during each model year are zero emission vehicles. These laws and regulations provide that a manufacturer of zero emission vehicles may earn regulatory credits (ZEV credits) and may sell excess credits to other manufacturers who apply such credits to comply with these regulatory requirements...

We recognize revenue on the sale of these credits at the time legal title to the credits is transferred to the purchasing party. Revenue from the sale of regulatory credits totaled $168.7 million, $216.3 million, and $194.4 million for the years ended December 31, 2015, 2014 and 2013.

https://www.marketvis.io/stock/tsla/financial/fy-2015/note/significantaccountingpoliciestextblock

 

[evnow]

The rapid refueling credit will be no more.

Any other sneeky way to tilt the marketplace to favor foreign fuel cell makers ?

 

[abasile]

The only reason that Tesla is able to make so much money selling ZEV credits is that the other automakers aren't selling enough EVs. It seems to me that Tesla is earning those credits fair and square, and if the other automakers don't like it, they should do what it takes to put more EVs on the road!

 

[smkettner]

Don't the automakers receive several credits depending on the ZEV type?

When more credits are issued then less ZEVs need to be produced. Brilliant.

6% is the new 15% :roll: No one saw this coming?

 

[TonyWilliams]

How about this scam:

Produce "60kWh" / 200 mile range car with a 120kWh battery (certainly possible with today tech)

The car should refuel to 95% in 15 minutes with a 300-350kW charger (coming)

Put on three year lease, get mega valuable "fast refueling" CARB-ZEV credits

Sell car as a 120kWh lease return in 3 years.