CARB ZEV credits for rapid refueling, gone in 2018?

[abasile]

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.

I love it! That echoes what I suggested upthread just over a year ago.

Not too many of those 300 kW chargers would be needed. Just enough to match the small number of intercity H2 fueling locations. :lol:

Of course, that "120 kWh lease return" approach is exactly what Tesla does with their software-limited S-40 cars when they're traded in. They get sold as S-60 cars. No doubt they'll do the same with today's software-limited S/X-60 cars - resell them as S/X-75.

 

[edatoakrun]

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!

Most of "the other automakers" have been very happy to build a few compliance BEVs/FCEVs or to buy ZEV credits as indulgences, rather than producing actual mass-market BEVs.

That, IMO, is the central failure of the 2012-to-present credit system, which has primarily subsidized the sales of very expensive ZEVs, Tesla BEVs and the very few HFCVs, at the expense of other (mostly less-expensive) vehicle buyers.

I give CARB credit for improvements in the proposals in the tutorial I posted on the previous page, and since it seems some have not watched it, I have posted a few highlights and when you can watch them in the video below.

ZEV requirement increases from 4.5% in 2018, to 22% by 2025, at @ ~12 minutes.

Credits from 2018 on are based ENTRIRELY on vehicle range @ ~15 minutes

THERE WILL BE NO FAST-REFUELING CREDITS STARTING IN 2018, reducing the huge subsidies Tesla and the FCEVs have received since 2012. @ ~17 minutes.

Ranging from one credit for 50 mile UDDS test cycle range, four credits maximum for 350 mile UDDS range. @ ~17:30 minutes.

A 2018 BEV with the range of a 2016 30 kWh LEAF would get ~two credits, down from three currently. @ ~17:45 minutes

Any future "200 mile range" BEV should get ~three credits. @ ~18:30 minutes

So, TESLA S/X models with 2016 MY battery capacities should get three to four credits, depending on their various UDDS ranges, down from Seven currently.

Any future 2018 FCEV with the 360 mile UDDS range of a 2015 Tucson gets the maximum four credits, down from the nine credits currently. @ ~18 minutes.

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

 

[ydnas7]

interesting

looks like they set the 4 credit bar higher, the Hyundai H2 FC vehicle passes without much margin (372 miles UDDS, to empty)

LEAF 2 at 650km JC08 cycle also just passes (calcs are 383 miles UDDS, very close), but the GM Bolt just misses out.

FWIW
Tesla S 70D UDDS would be about 322miles UDDS (so is a 3 ZEV car)

Tesla S 75D UDDS would be about 345miles UDDS (so is a 3 ZEV car) this is so close, must recheck calcs, but Tesla will able to boost range to just over 350 miles UDDS when the time comes.

Tesla S 90D UDDS would be about 378miles UDDS (so is a 4 ZEV car)

Tesla X75D 343miles (close to Tesla S on the city cycle) again 3 ZEV credits but should be able to reach 4 ZEV when the time comes

 

[TonyWilliams]

ZEV requirement increases from 4.5% in 2018, to 22% by 2025, at @ ~12 minutes.

First, understand that any percent is based in ZEV credits, not cars (see explanation below).

While the data has likely changed from previous data, the ZEV requirement ALSO includes non-ZEV cars. For instance, for 2012-2014 "Phase 3", 12% of the production of the six Large Vehicle Manufacturers had to meet yearly ZEV requirements (including ZEV's, Enhanced AT PZEVs, ATPZEVs and PZEVs). Of that 12%, 0.79% must be ZEV.

CARB equirements from 2012-2014
Model year ---- ZEV Credit % of total annual sales

2012 ------------ 0.79%
2018 ------------ 2.00%
2019 ------------ 4.00%
2020 ------------ 6.00%
2021 ------------ 8.00%
2022 ----------- 10.00%
2023 ----------- 12.00%
2024 ----------- 14.00%
2025 ----------- 16.00%

Here is how the world's largest auto manufacturer complied with CARB-ZEV then. The "big six" Large Vehicle Manufacturers (LVM) auto manufacturers of the world (Toyota, Honda, Nissan, GM, Ford, Fiat/Chrysler) were required to begin the modern day CARB-ZEV rules, starting in 2012. Toyota did with Rav4 EV primarily (there were also less than 100 Scion iQ EVs).

Over three model years, Toyota sells about 900,000 Toyota cars in California.

The 0.79% ZEV credit rule (model years 2012-2014) for Zero Emission Vehicle (ZEV) sales means that Toyota must earn 7,110 of the ZEV credits over three model years (0.79% * 900,000). Each Toyota Rav4 EV sold in California earns 3 of the ZEV credits each, so 2370 battery electric cars solve that over the three model years. Toyota actually built 2538, and discontinued the vehicle right on schedule.

For model years 2015-2017, the Toyota Murai hydrogen car earns 9 credits per car, therefore Toyota need only make 790 individual sales over three model years, or 263 per each model year during 2015 - 2017.

Should the 9 credits for hydrogen cars be retained past 2017 (they are scheduled to disappear in 2018), then Toyota would only have to sell 5,333 hydrogen cars per year IN CALIFORNIA ONLY (none in the several other CARB-ZEV states) without any battery electric cars sold, even at 16% of total credits in model year 2025. Currently, the rules allow hydrogen cars to only be sold in California, while electric vehicles (EVs) must be sold in all CARB-ZEV states in 2018 and later.

Credits from 2018 on are based ENTRIRELY on vehicle range @ ~15 minutes

Refueling time should be a variable credit. Range and refueling time are important to the consumer.

THERE WILL BE NO FAST-REFUELING CREDITS STARTING IN 2018, reducing the huge subsidies Tesla and the FCEVs have received since 2012. @ ~17 minutes.

Tesla hasn't received fast refueling credit for about two years. Hydrogen cars do, however.

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

Watch the hydrogen guys squeal.

 

[ydnas7]

it seems that many credits have been 'banked' for the future, upto 2021, despite the big ramp that starts
http://www.arb.ca.gov/board/books/2015/102215/15-8-7pres.pdf

and that was before Tesla model 3, Bolt, LEAF 2

 

[edatoakrun]

Good story on CARB's dysfunctional ZEV credit market, with interesting report of current market values of credits.

No wonder you can lease a new LEAF so cheaply, and why most all the compliance BEVs are even cheaper...

California’s Zero-Emission Vehicle Program Is Stuck in Neutral

Toyota’s zero-emission vehicle sales in California this year amount to a drop of hydrogen in an ocean of gasoline.

The world’s largest automaker has so far sold about 270 hydrogen fuel cell cars in the state, where it delivered nearly 400,000 gas-powered vehicles last year, according to an Edmunds.com analysis of IHS Markit data. Toyota ( tm ) does not currently sell an electric vehicle.

And yet the automaker will have no trouble meeting California’s zero-emission vehicle mandates — because it can satisfy those obligations with state-awarded environmental credits instead of current zero-emission vehicle sales...

the Toyota Mirai and the Honda Clarity will pay off handsomely in credits — nine of them for each sale, compared to four credits the state now gives a Tesla Model S or the three it gives a Nissan Leaf.

The credits are currently worth about $3,000 to $4,000 each, according to a source with knowledge of the private credit-trading market among automakers. But they are worth far more to Toyota and Honda as a mechanism to satisfy state mandates while continuing to sell hundreds of thousands of gasoline-powered vehicles each year in California, the nation’s biggest auto market...

http://fortune.com/2016/09/01/california-zero-emission-vehicle-sales/

THERE WILL BE NO FAST-REFUELING CREDITS STARTING IN 2018, reducing the huge subsidies Tesla and the FCEVs have received since 2012. @ ~17 minutes.

Tesla hasn't received fast refueling credit for about two years...

Source?

AFAIK, TSLA has continued to receive at least some FR credits through the 2016 MY, and the proposal to withdraw them for 2017 never made it through hearings.

...Staff’s current proposal seeks to address these concerns by amending the ZEV Regulation to require each individual vehicle earning additional ZEV credits under the fast refueling provision to document use of fast refueling. The proposed amendment would be effective for MY 2017 vehicles because MY 2015 and MY 2016 vehicles are already on the road in California...

http://www.arb.ca.gov/regact/2015/zev2015/zev15notice.pdf

But the hearing to consider this proposal was cancelled.

http://www.arb.ca.gov/regact/2015/zev2015/zev2015.htm

TSLA financials report almost $600 Million in credit sales over the last three years, but don't show number of credits per vehicle, or revenue per credit.

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. Similar regulations exist at the federal level that require compliance related to greenhouse gas emissions and also allow for the sale of excess credits by one manufacturer to other manufacturers. As a manufacturer solely of zero emission vehicles, we have earned emission credits, such as ZEV and GHG credits on vehicles, and we expect to continue to earn these credits in the future. We enter into contractual agreements with third parties to purchase our regulatory credits.

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

Primer on upcoming hearings and regs:

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

More links of interest:

http://www.greencarcongress.com/2016/07/20160722-nrdc.html
https://www.nrdc.org/sites/default/files/media-uploads/nrdc_commissioned_zev_report_july_2016_0.pdf
http://www.arb.ca.gov/msprog/zevprog/zevregs/1962.2_clean.pdf