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NASEO Transportation Sector |
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January 19, 2001 Thomas J. Gross Subject: Hybrid Electric/Gasoline Vehicle Eligibility for EPACT Fleet Compliance Dear Mr. Gross: I am writing on behalf of the National Association of State Energy Officials (NASEO). We ask that you reverse a recent administrative interpretation made by your staff that disqualifies electric hybrid vehicles (hybrids) from satisfying the alternative fuel fleet mandates of the Energy Policy Act (EPACT) of 1992. In 2001, 75 percent of federal, state and energy supplier fleet vehicles, that are centrally fueled, must be capable of using alternative fuels to meet EPACT mandates. We request that the two original equipment manufacture (OEM) electric/gasoline hybrid vehicles, the Honda Insight and the Toyota Prius, be counted as a credit toward these mandates. There are compelling reasons that support this position. Exceptions to the Definition - EPACT defines alternative fuels as fuels that are "substantially non-petroleum" and yield energy security and environmental benefits. DOE currently recognizes the following as alternative fuels: ethanol and methanol as alcohol fuels (alcohol mixtures that contain no less than 70 percent of the alcohol fuel), natural gas (compressed or liquefied), liquefied petroleum gas, hydrogen, coal-derived liquid fuels, fuels derived from biological materials, and electricity (including solar energy). USDOE interprets substantially non-petroleum as more than 50 percent alternative fuel use. As noted above, the list of allowed alternative fuels includes liquefied petroleum gas (LPG) or propane. While much of North America's LPG originates from natural gas, a significant portion is derived from petroleum. In our opinion giving credit for LPG fueled vehicles is an exception to the substantially non-petroleum portion of the alternative fuels definition. Biodiesel 20 (B20) vehicles are eligible for credit when only 20 percent of the fuel is bio-sourced and the remainder is conventional diesel fuel. This appears to be another exception to the definition of substantially non-petroleum. Hybrids Help Meet National Policy Objectives - Dual-fuel vehicles using ethanol, methanol, compressed natural gas, liquefied petroleum gas and conventional fuels are eligible for credits toward EPACT mandates. Those vehicles may use either an alternative or conventional fuel. When alternative fuels are unavailable, these dual-fuel vehicles do not aid us in achieving energy security or environmental policy goals. In addition, many dual-fuel vehicles represent traditional design with little or no improvement in vehicle efficiency. In contrast, hybrid gasoline/electric vehicles are highly efficient and do not present the uncertainty of operator fuel choice. Electric hybrids typically use the electric drive feature for 40 percent or more of their energy supply. Thus, hybrids produce consistent benefits of fuel efficiency and reduced emissions. Hybrid vehicle overall energy efficiency (Btu./mi.) is more than double that of "traditional" alternative fuel vehicles, with similar utility, that are based on conventional vehicle design. Accelerated adoption of hybrids will substantially reduce demand for foreign oil. Original equipment manufacturer hybrids on the market meet Ultra Low Emission (ULEV) or Super Ultra Low Emission (SULEV) emissions standards. Hybrids produce at least 31 times fewer hydrocarbon emissions (.04 gms./mi.), half the carbon monoxide (1.7 gms./mi.) and eight times less nitrogen oxide (.05gms./mi.) than a similar transitional low emission vehicle. This emissions performance is better than all other OEM dual-fuel vehicles. Hybrid vehicle design includes lighter weight materials, better drag coefficient and recovery of waste energy through regenerative braking. Few if any of the dual-fuel alternative fuel vehicles currently allowed under EPACT incorporate these features. NASEO has long supported, and continues to strongly support, alternative fuels programs. We need as broad a base of alternatives as possible. And, given the potential for hybrid vehicles to enhance efforts to both reduce petroleum consumption and emissions associated with fleet vehicle operation, inclusion of hybrids under EPACT is an appropriate step for the department to take. In closing, most states operate fleets of vehicles and are keenly interested in the new hybrids. The states are directly and negatively affected by the department's decision not to allow credits toward EPACT mandates for use of these vehicles. We urge you to change this interpretation and give credit for this innovative new technology. And, we would like to learn what other measures the states could expect the department take to accelerate deployment of hybrid vehicles. I look forward to a timely and written response to the concerns I have raised. Best regards, William Keese, Chairman of the Board cc: State and Territory Energy Directors;
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