Fuel Economy: No Action Roadmap

Here is what it takes to make an absurd number game -- cunning rules, crafty calculations and clueless regulators.

Or how else do we describe the new proposal from the Steering Committee of Emissions Regulations (scoe) of the Union Ministry of Shipping, Road Transport and Highways on carbon dioxide (co2) emissions standards to improve fuel economy of cars and two-wheelers!

It is shocking the way they have applied convoluted principles to define and justify the proposed roadmap. They simply want official sanction for more time to increase co2 emissions and oil guzzling; legitimize status quo until 2015, and, consider real improvement only in 2020.

It is indeed very strange that the ministry should remain so obstinate about the co2 emissions approach when unanimous decision has come from the Prime Minister’s office (pmo) in September that the country needs fuel economy standards in mileage terms to strengthen energy security. The Transport Ministry, instead of getting on with the inter-ministerial discussions on this, as asked by the pmo, puts out a co2 proposal hatched in closed door discussions with the automobile industry.

Even if we set this aside the new proposal as redundant especially after the recent decision from the pmo, the new co2 proposal would still need public scrutiny only to lay bare their intent, -- a no action road map.  If its fundamental premise is not confronted right now it may continue to influence and overpower the making of these regulations.

To an uninitiated there is perhaps nothing amiss in the new proposal for cars. After all it sets progressive targets for co2 emissions reduction from cars until 2020 -- reduce from 210 g/km in 2006 to a sales weighted fleet-wide average of 179 g/km in 2010 – a 15% drop; further cut to 155 gm/km in 2015, another 13% drop; and finally achieve 128 gm/km in 2020, close to what Europe will achieve (130 g/km) in 2012. Looks innocent but not quite.

There in lurks the politics of numbers, and the camouflaged intent of their number crunching.  The new game in town is about fixing the baseline emissions of the current fleet in 2006 to play around with the future targets. Cleverly fix the baseline or the starting point of the race, at a much weaker level than what many of our cars have already met, so that the improvement target does not burden them. But it will certainly allow the car makers a wide enough margin to increase emissions and oil guzzling in the medium term especially from the heavier vehicles!

How? That’s very easy. World-wide the baseline is defined according to the average emissions or fuel economy level of the current fleet weighted by their sales and against this future improvement is decided. But scoe has junked the science. Instead it has worked out a regression of the worst performing vehicles in the current fleet to represent the current base line. They call it the all capped line that self evidently means that nearly all vehicles in the market are already performing better than this line. And use of this to benchmark improvement for sales weighted fleet-wide average in 2010. This just makes a mockery of the initiative.

It is particularly audacious because the proposal itself admits that the actual average co2 emissions of our new car fleet in 2006 is already a lot better at 155 g/km. Then why is this arbitrary decision to consider only the worst performing vehicles to make the baseline so lax at 210 g/km?  It defies logic. But this number is convenient to give advantage to the car makers. The so called 15% “improvement target” for 2010 at 179 g/km allows them substantial leniency.  This gives them the legal sanction for increasing fuel consumption of the new car fleet. This literally translates into allowing them the liberty to worsen the fleet average fuel economy of 15.1 km/litre already achieved in 2005 to 13.1 km/litre by 2010. In fact, this drop can be even worse as the average weight of the vehicle fleet is expected to increase due to weak standards. Incredible!

Complete irrationality rules in the insular world of rule making. Not content with this, in the next leg, in 2015, the roadmap wants the car industry to come back where it had started in 2005 – 155 g/km as sales weighted fleet average.  The car industry will only run to stand still until 2015. Do nothing till then. Maintain status quo.

Only in 2020 it begins to consider some real improvement over 2005 level. But even then the industry will meet on a fleet-wide basis what the best performing or the top runner models have already accomplished in 2005 i.e.128 g/km. If there was any seriousness in the rule making, the industry would have been asked to catch up with today’s top runner models by 2015. That would have led to meaningful fuel savings. But at every step the roadmap takes care to protect the industry from effective commitments. Even for its lax targets for 2015 and 2020 it softens the impact with a rider that even these may be reviewed in 2012 and 2017 as the average mass of Indian vehicles is expected to increase by then. This is indefensible!

Clearly, there is absolutely no interest in protecting the unique advantage we already have in our small car dominated fleet that is more fuel efficient compared to most other regions of the world. If protected with effective regulations this would have saved significant amount of fuels for us and offered the world an opportunity to avoid future emissions of heat trapping gases. But our regulators will not let that be. Ironically, the average co2 emissions of the Indian car fleet in 2006 is already a lot better at 155g/km compared to the current European level of 165 g/km. And yet our Transport ministry wants India to lose the race by 2020 with the advice that India must not lag behind Europe by more than 5 years. Why must India, placed much better than Europe today ever lag behind?

The roadmap only panders to the Indian industry’s fixation with heavier vehicles. This also explains why they are so up in arms against the proposal from the Bureau of Energy Efficiency on fuel economy standards and labeling for cars that are structured to prevent drift towards heavier vehicles and proposes faster catching up with the performance level of the top runners. The industry abhors the idea of putting small and bigger vehicles on a scale that gives more advantage to efficient small vehicles over bigger vehicles. The scoe obliges. They don’t learn from the plight of the Detroit car makers that are paying such a heavy price for investing in big cars and inefficiencies.

Not only has the roadmap succeeded in keeping the numerical values weak, it even refuses to consider penalty for non-compliant companies. The scoe is content to put on the blinkers if car companies fail to meet standards. Accountability is not their concern. This virtually reduces the regulation to a voluntary and ineffectual scheme. It is disturbing that the scoe that represents country’s premier technical bodies dealing with vehicles and fuels and supposed to have grown in sophistication and scientific knowledge could let such a proposal pass the scanner of science and defeat the purpose of these regulations.

Such risks are bound to surface when regulations are written only in consultation with the industry that has direct conflict of interest. But this time the pmo has categorically asked for inclusion of other stakeholders.  We need an open and transparent process to ensure that we get the principles right and protect the sanctity of rulemaking. Only that can save us from the energy crisis and protect climate.

-- Anumita Roychowdhury
Right To Clean Air Campaign