Important inflation reduction act petition

[RetiredRonTesla]

https://chng.it/qSx7SyXKnK
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[cvalue13]

Seems strange (and poorly written/reasoned) to me.

“If the proposal were to pass as written…” - is it not already passed into law, over 4 months ago?

“[w]e believe this proposal, in its current form, contains a self-defeating incentive structure by overly rewarding production of plug-in hybrid electric vehicles (PHEVs)… [so] [w]e urge members of Congress to please consider a revised proposal which either:
Increases the 7 kilowatt hour requirement to something more aligned with the commensurate battery costs (perhaps 35 kilowatt hours), or [r]educes the maximum credit allowed for low battery capacity vehicles.”

So, the request is to reduce incentives for PHEVs (because they don’t reduce emission ‘enough’), but no attendant request to instead divert those funds to funds to fully-electric vehicles? The result being a request to in effect merely reduce total net credits for vehicles utilizing battery technologies? Taken on its face, the “petition” is “self-defeating” in its incompleteness.

“If the proposal were to pass as written, automakers would not be incentivized to produce the fully-electric vehicles that are needed to truly make a difference in the emissions”

Setting aside that the IRA is already passed/law, I’m not sure the asserted “incentive” results, all things considered. Hybrids on average tend to have more affordable upfront costs on a gross basis, and moreso if comparing attendant range-to-cost. Until there are cheaper full electric options with comparable range, do these lower cost PHEVs not provide access to lower income purchasers to at least participate in reduced emissions vehicles? Particularly given the IRA’s otherwise applicable caps on purchaser’s income and vehicle MSRP? Understanding that in theory a completely full-electric incentive structure may nominally incentivize manufacturers to create lower cost full-electrics, does that theory stand when met with the reality of production costs and range sacrifices? Afterall, nothing about the IRA incentivized anyone to create a car with an MSRP over $55K or Truck/SUV over $80K. Until the engineering/manufacturing/range realities are met, does the petition’s request to reduce incentives for PHEVs not at least somewhat smack of “people without sufficient money should just get more money”? Afterall, consumers would likely only choose a PHEV over a BEV due to attendant cost and range benefits of the former. As a result, the current incentive structure favoring PHEVs should also incentivize more BEV manufactures to create cost-range competitive vehicles in the lower market cost range (if manufacturers are caring much anymore, in any scenario).

“Undoubtedly, this will shift limited battery supplies towards production of higher emission PHEVs.”

So, in an environment of limited resources, we should concentrate those resources into fewer gross numbers of emissions-mitigating vehicles? Show me the data that a single full electric vehicle plus 8 ICE vehicles results in lower net emissions than 9 hybrid vehicles.

It’s late, and I’ve admittedly been through 6 days of mind-numbing holiday gatherings, but I’m not compelled.



“petition” in full:


“Stop excessive hybrid vehicle subsidies in the Inflation Reduction Act of 2022


Rob Maurer started this petition to Senator Joe Manchin III

This petition is being created to express concern about proposed changes to electric vehicle tax credits included in the Inflation Reduction Act of 2022 (see Part 4—Clean Vehicles pp. 366-406).

While petition members are fully supportive of efforts to reduce emissions, we believe this proposal, in its current form, contains a self-defeating incentive structure by overly rewarding production of plug-in hybrid electric vehicles (PHEVs).

Under the proposal, PHEVs with as little as 7 kilowatt hours of battery capacity are eligible to receive a maximum credit of $7,500. Under current legislation, such a vehicle would receive a maximum credit of $3,334. While credits for higher emission PHEVs more than double under this proposal, maximum credits for lower emission fully-electric vehicles remain the same. Undoubtedly, this will shift limited battery supplies towards production of higher emission PHEVs.

Unfortunately, real-world testing has shown that PHEVs role in reducing emissions has been dramatically overestimated. According to research by The International Council on Clean Transportation (ICCT), “PHEV fuel consumption and tail-pipe CO2 emissions during real-world driving, on average, are approximately two to four times higher than type-approval values.”

Additionally, it is difficult to justify such a large credit for low-capacity PHEVs. Bloomberg New Energy Finance estimates electric vehicle batteries cost $132 per kilowatt hour, so 7 kilowatt hours would cost just $924. A lower emission fully-electric vehicle requires 50-100+ kilowatt hours of battery capacity, putting battery costs at $6,600 to $13,200. Treating these vehicles which have such different costs and emissions profiles as identical under the proposed credit structure is untenable.

If the proposal were to pass as written, automakers would not be incentivized to produce the fully-electric vehicles that are needed to truly make a difference in the emissions in our cities, in the health of our citizens, and in the economic prosperity of our country. The US would cede the opportunity to lead in clean vehicles to countries like China while we toil away billions of taxpayer dollars on inefficient half-measures.

We urge members of Congress to please consider a revised proposal which either:
Increases the 7 kilowatt hour requirement to something more aligned with the commensurate battery costs (perhaps 35 kilowatt hours), or [r]educes the maximum credit allowed for low battery capacity vehicles.

Thank you for your consideration.

Sources referenced:
1. Inflation Reduction Act of 2022:
https://www.democrats.senate.gov/imo/media/doc/inflation_reduction_act_of_2022.pdf
2. Real-World Usage of Plug-in Hybrid Electric Vehicles:
https://theicct.org/wp-content/uploads/2021/06/PHEV-FS-EN-sept2020-0.pdf
3. Bloomberg New Energy Finance Battery Cost Estimates:
https://about.bnef.com/blog/battery...-rising-commodity-prices-start-to-bite/#_ftn1

“

 

[Crissa]

It did pass as written. It still needs to be amended.

-Crissa

 

[cvalue13]

It did pass as written. It still needs to be amended.

-Crissa

come again?

 

[Crissa]

come again?

The bill did pass as written, and still needs to be amended as the petition directs.

-Crissa

 

[cvalue13]

The bill did pass as written, and still needs to be amended as the petition directs.

-Crissa

I suppose I’m rusty in my legislative processes. But the bill itself *is* an amendment (of the previously existing law), and once signed by the president into law I don’t believe is subject to further “amending” in any normal course other than if there is an entirely new bill (like itself) needing separate passage all over again.

the petition directs that the bill shouldn’t be passed as Written, as though Manchin is still involved and n the senate amending processes

likely we’re talking past one-another

 

[Crissa]

Yes, you "amend" laws by passing new bills.

You amend bills by passing amendments.

-Crissa

 

[cvalue13]

You amend bills by passing amendments.

But … only prior to them being signed into law.

There is no more ‘amending’ the IRA. The ‘petition’ is 6+ months late.

or should I say, posting the petition here on this forum is late…

 

[Cybertruck Hawaii]

Seems strange (and poorly written/reasoned) to me.

“If the proposal were to pass as written…” - is it not already passed into law, over 4 months ago?

“[w]e believe this proposal, in its current form, contains a self-defeating incentive structure by overly rewarding production of plug-in hybrid electric vehicles (PHEVs)… [so] [w]e urge members of Congress to please consider a revised proposal which either:
Increases the 7 kilowatt hour requirement to something more aligned with the commensurate battery costs (perhaps 35 kilowatt hours), or [r]educes the maximum credit allowed for low battery capacity vehicles.”

So, the request is to reduce incentives for PHEVs (because they don’t reduce emission ‘enough’), but no attendant request to instead divert those funds to funds to fully-electric vehicles? The result being a request to in effect merely reduce total net credits for vehicles utilizing battery technologies? Taken on its face, the “petition” is “self-defeating” in its incompleteness.

“If the proposal were to pass as written, automakers would not be incentivized to produce the fully-electric vehicles that are needed to truly make a difference in the emissions”

Setting aside that the IRA is already passed/law, I’m not sure the asserted “incentive” results, all things considered. Hybrids on average tend to have more affordable upfront costs on a gross basis, and moreso if comparing attendant range-to-cost. Until there are cheaper full electric options with comparable range, do these lower cost PHEVs not provide access to lower income purchasers to at least participate in reduced emissions vehicles? Particularly given the IRA’s otherwise applicable caps on purchaser’s income and vehicle MSRP? Understanding that in theory a completely full-electric incentive structure may nominally incentivize manufacturers to create lower cost full-electrics, does that theory stand when met with the reality of production costs and range sacrifices? Afterall, nothing about the IRA incentivized anyone to create a car with an MSRP over $55K or Truck/SUV over $80K. Until the engineering/manufacturing/range realities are met, does the petition’s request to reduce incentives for PHEVs not at least somewhat smack of “people without sufficient money should just get more money”? Afterall, consumers would likely only choose a PHEV over a BEV due to attendant cost and range benefits of the former. As a result, the current incentive structure favoring PHEVs should also incentivize more BEV manufactures to create cost-range competitive vehicles in the lower market cost range (if manufacturers are caring much anymore, in any scenario).

“Undoubtedly, this will shift limited battery supplies towards production of higher emission PHEVs.”

So, in an environment of limited resources, we should concentrate those resources into fewer gross numbers of emissions-mitigating vehicles? Show me the data that a single full electric vehicle plus 8 ICE vehicles results in lower net emissions than 9 hybrid vehicles.

It’s late, and I’ve admittedly been through 6 days of mind-numbing holiday gatherings, but I’m not compelled.



“petition” in full:


“Stop excessive hybrid vehicle subsidies in the Inflation Reduction Act of 2022


Rob Maurer started this petition to Senator Joe Manchin III

This petition is being created to express concern about proposed changes to electric vehicle tax credits included in the Inflation Reduction Act of 2022 (see Part 4—Clean Vehicles pp. 366-406).

While petition members are fully supportive of efforts to reduce emissions, we believe this proposal, in its current form, contains a self-defeating incentive structure by overly rewarding production of plug-in hybrid electric vehicles (PHEVs).

Under the proposal, PHEVs with as little as 7 kilowatt hours of battery capacity are eligible to receive a maximum credit of $7,500. Under current legislation, such a vehicle would receive a maximum credit of $3,334. While credits for higher emission PHEVs more than double under this proposal, maximum credits for lower emission fully-electric vehicles remain the same. Undoubtedly, this will shift limited battery supplies towards production of higher emission PHEVs.

Unfortunately, real-world testing has shown that PHEVs role in reducing emissions has been dramatically overestimated. According to research by The International Council on Clean Transportation (ICCT), “PHEV fuel consumption and tail-pipe CO2 emissions during real-world driving, on average, are approximately two to four times higher than type-approval values.”

Additionally, it is difficult to justify such a large credit for low-capacity PHEVs. Bloomberg New Energy Finance estimates electric vehicle batteries cost $132 per kilowatt hour, so 7 kilowatt hours would cost just $924. A lower emission fully-electric vehicle requires 50-100+ kilowatt hours of battery capacity, putting battery costs at $6,600 to $13,200. Treating these vehicles which have such different costs and emissions profiles as identical under the proposed credit structure is untenable.

If the proposal were to pass as written, automakers would not be incentivized to produce the fully-electric vehicles that are needed to truly make a difference in the emissions in our cities, in the health of our citizens, and in the economic prosperity of our country. The US would cede the opportunity to lead in clean vehicles to countries like China while we toil away billions of taxpayer dollars on inefficient half-measures.

We urge members of Congress to please consider a revised proposal which either:
Increases the 7 kilowatt hour requirement to something more aligned with the commensurate battery costs (perhaps 35 kilowatt hours), or [r]educes the maximum credit allowed for low battery capacity vehicles.

Thank you for your consideration.

Sources referenced:
1. Inflation Reduction Act of 2022:
https://www.democrats.senate.gov/imo/media/doc/inflation_reduction_act_of_2022.pdf
2. Real-World Usage of Plug-in Hybrid Electric Vehicles:
https://theicct.org/wp-content/uploads/2021/06/PHEV-FS-EN-sept2020-0.pdf
3. Bloomberg New Energy Finance Battery Cost Estimates:
https://about.bnef.com/blog/battery...-rising-commodity-prices-start-to-bite/#_ftn1

“

You don’t get what you deserve. You get what you negotiate in life.

 

[Crissa]

But … only prior to them being signed into law.

you "amend" laws by passing new bills.

-Crissa

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