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IRS weighs in on tax rebate, mostly bad news for Model Y

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What a load! What difference does the number of seats make? If I take the third row of seats out of a Tahoe or Explorer it's no longer an SUV?
I will be interested if this is changed, or if the IRS is now part of the anti-Tesla club.

If I were a betting man, the 7 seater is likely falling under van specification ($80 MSRP limit for vans.) I believe DOT classifies any vehicle that seats more than 5, but less than 10, as MPV (the same category as minivans.) The Y is pretty close to some minivans in dimensions and ground clearance, it just doesnt have a sliding door. In fact, if you go on the NHTSA website, you can find initial assessment docs for the Model Y that refer to it as a MPV (not a SUV.)

All OEMs had to be aware of these pre-defined classifications as they have been in use for CAFE regulations (for decades.) Realistically, with the larger bill attempting to curb inflation as a whole, the Y at $55K probably isnt unreasonable. It was close to that in December with Tesla incentives and was around that price a little bit over a year ago.
 
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I'm not surprised at the IRS playing hardball with the classifications defined under Title 49. The MME pretty much has the same ground clearance as a Model 3. Is seating position enough to mark one as a sedan or SUV?
Now, the Ioniq 5, to me is a hatchback. Doesn't look anything like an SUV. But car mags and the OEM disagree. The issue is these days OEMs are playing games. Chevy called the original Bolt (not even the EUV) a Crossover, and gave it roof rails. That thing is a hatchback.

SUVs
bZ4X = 8.1"
e-tron = 8.2"
iX = 8.8"
Model X = 8.1"
R1S = 8-15"
Solterra = 8.3"
XC40 = 8.3"

Rugged Hatches (<7.88" per rule of Running Clearance not less than 20 cm)
Ariya = 7.8"
Bolt = 5.35"
Bolt EUV = 5.5"
C40 = 7"
EQS = 6.9"
I5/EV6 = 6.1"
i Pace = 7.8"
GV60 = 6.2"
ID.4 = 6-8+" (Depends who you ask)
MME = 5.7" or 5.3" (GT)
MY = 6.6"
 
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Rugged Hatches (<7.88" per rule of Running Clearance not less than 20 cm)
Ariya = 7.8"
Bolt = 5.35"
Bolt EUV = 5.5"
C40 = 7"
EQS = 6.9"
I5/EV6 = 6.1"
i Pace = 7.8"
GV60 = 6.2"
ID.4 = 6-8+" (Depends who you ask)
MME = 5.7" or 5.3" (GT)
MY = 6.6"
I'm really curious about the 2023/Chattanooga ID4. It seems like the NA ID4 has always had higher ground clearances than the EU models (and that the official docs are likely quoting the EU models.) I've heard of the US clearance as high as 8.6" for the AWD ID4. I'm curious to see the assessment doc they submitted.
 
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How far? It shows you 360 degrees surrounding information and alerts if you are getting too close. What else is missing? Sure it’s not the fancy 3D views from other cars like Hyundai, but I find those 3D videos like in Ioniq 5 tend to lag in the display, so you can’t really trust it in tight spot.
I love how Hyundai is now setting the bar for "fancy."
The rear backup camera in my Model 3 lags a bit too, but that doesn't mean it's not useful.
Is this new "360" visualization from Tesla actually the replacement for USS? If so, that works great so long as the nearby objects are in the list of recognized objects. I suspect it wouldn't show the shelves at the end of my garage, the boxes on the floor, or the wall.
 
If I were a betting man, the 7 seater is likely falling under van specification ($80 MSRP limit for vans.) I believe DOT classifies any vehicle that seats more than 5, but less than 10, as MPV (the same category as minivans.) The Y is pretty close to some minivans in dimensions and ground clearance, it just doesnt have a sliding door. In fact, if you go on the NHTSA website, you can find initial assessment docs for the Model Y that refer to it as a MPV (not a SUV.)

All OEMs had to be aware of these pre-defined classifications as they have been in use for CAFE regulations (for decades.) Realistically, with the larger bill attempting to curb inflation as a whole, the Y at $55K probably isnt unreasonable. It was close to that in December with Tesla incentives and was around that price a little bit over a year ag

My state vehicle registration lists my MY as "UT" or utility. Merriam-Webster defines SUV as "a rugged automotive vehicle similar to a station wagon but built on a light-truck chassis". I'm not finding a rock solid definition. Besides, adding two more seats doesn't put the MY from 4,400 pounds to over 6k.
 
My state vehicle registration lists my MY as "UT" or utility. Merriam-Webster defines SUV as "a rugged automotive vehicle similar to a station wagon but built on a light-truck chassis". I'm not finding a rock solid definition. Besides, adding two more seats doesn't put the MY from 4,400 pounds to over 6k.
Title 49 established a federal definition (under DOT) for constitutes a SUV. I think someone shared it earlier, but its been in use for CAFE regulation for like 60 years. All OEMs had to know of this definition.

In either case, if you look at the initial assessment for the Model Y on the NHTSA, its also referred to as the 2020 TESLA MODEL Y 5-DOOR MPV. I dont know if that's a self-classification (from Tesla), or the NHTSA though. Maybe all Model Y's can be considered a MPV, but I'm guessing not. The initial press release from the Treasury department mentioned they were working with the DOE (EPA), DOT (NHTSA), and other organizations to hone the rules. The NHTSA publishes OEM inquiries on classifications, but I couldnt find a good one on what constitutes a MPV (other than that at 10 seats, a vehicle shifts classification from a MVP to a bus lol.) It appears to include everything from third row seating options (SUVs and minivans) to cargo vans.
 
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I'm not finding a solid definition on a SUV. I found one from a legal website based on federal law.

Based on 26 USC § 179(b)(5)


1672875767656.png
 
  • Audi Q5 TFSI e Quattro PHEV SUV (MSRP $80,000 or below)
  • BMW 330e sedan (MSRP $55,000 or below)
  • BMW X5 xDrive45e SUV (MSRP $80,000 or below)
  • Cadillac Lyriq (classified as a car by the IRS, so its MSRP must be $55,000 or below. The Lyriq is on the IRS’ list even though it has a starting MSRP of $62,990 and therefore would not qualify unless Cadillac lowers its MSRP.)
  • Chevrolet Bolt hatchback (MSRP $55,000 or below)
  • Chevrolet Bolt EUV hatchback (MSRP $55,000 or below
  • Chrysler Pacifica PHEV minivan (MSRP $80,000 or below)
  • Ford Escape PHEV SUV (MSRP $80,000 or below)
  • Ford E-Transit van (MSRP $80,000 or below)
  • Ford F-150 Lightning pickup truck (MSRP $80,000 or below)
  • Ford Mustang Mach-E SUV (classified as a car by the IRS, so its MSRP must be $55,000 or below)
  • Jeep Wrangler 4xe PHEV SUV (MSRP $80,000 or below)
  • Jeep Grand Cherokee 4xe PHEV SUV (MSRP $80,000 or below)
  • Lincoln Aviator Grand Touring PHEV SUV (MSRP $80,000 or below)
  • Lincoln Corsair Grand Touring PHEV SUV (classified as a car by the IRS, so its MSRP must be $55,000 or below)
  • Nissan Leaf S, S Plus, SL Plus, SV, and SV Plus hatchbacks (MSRP $55,000 or below)
  • Rivian R1S SUV (MSRP $80,000 or below)
  • Rivian R1T pickup truck (MSRP $80,000 or below)
  • Tesla Model 3 Rear-Wheel Drive and Long Range sedans (MSRP $55,000 or below)
  • Tesla Model Y All-Wheel Drive, Long Range, and Performance SUVs (MSRP $80,000 or below for seven-passenger versions, or MSRP $55,000 or below for five-passenger versions)
  • Volkswagen ID.4, Pro, Pro S, S, AWD Pro, and AWD Pro S SUVs (only models made in Tennessee with an MSRP $55,000 or below for front-wheel-drive versions or MSRP $80,000 or below for all-wheel-drive versions)
  • Volvo S60 PHEV, Extended Range, and T8 Recharge sedans (MSRP $55,000 or below)
  • The IRS says that General Motors, Kia, Mazda, Mercedes-Benz, and Subaru have indicated that they plan to submit vehicles to the list, but have not yet done so.
*from CR

I guess a <$55k SR RWD Y is in the future... and/or all LR Y's will come with the third row to qualify
 
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  • Audi Q5 TFSI e Quattro PHEV SUV (MSRP $80,000 or below)
  • BMW 330e sedan (MSRP $55,000 or below)
  • BMW X5 xDrive45e SUV (MSRP $80,000 or below)
  • Cadillac Lyriq (classified as a car by the IRS, so its MSRP must be $55,000 or below. The Lyriq is on the IRS’ list even though it has a starting MSRP of $62,990 and therefore would not qualify unless Cadillac lowers its MSRP.)
  • Chevrolet Bolt hatchback (MSRP $55,000 or below)
  • Chevrolet Bolt EUV hatchback (MSRP $55,000 or below
  • Chrysler Pacifica PHEV minivan (MSRP $80,000 or below)
  • Ford Escape PHEV SUV (MSRP $80,000 or below)
  • Ford E-Transit van (MSRP $80,000 or below)
  • Ford F-150 Lightning pickup truck (MSRP $80,000 or below)
  • Ford Mustang Mach-E SUV (classified as a car by the IRS, so its MSRP must be $55,000 or below)
  • Jeep Wrangler 4xe PHEV SUV (MSRP $80,000 or below)
  • Jeep Grand Cherokee 4xe PHEV SUV (MSRP $80,000 or below)
  • Lincoln Aviator Grand Touring PHEV SUV (MSRP $80,000 or below)
  • Lincoln Corsair Grand Touring PHEV SUV (classified as a car by the IRS, so its MSRP must be $55,000 or below)
  • Nissan Leaf S, S Plus, SL Plus, SV, and SV Plus hatchbacks (MSRP $55,000 or below)
  • Rivian R1S SUV (MSRP $80,000 or below)
  • Rivian R1T pickup truck (MSRP $80,000 or below)
  • Tesla Model 3 Rear-Wheel Drive and Long Range sedans (MSRP $55,000 or below)
  • Tesla Model Y All-Wheel Drive, Long Range, and Performance SUVs (MSRP $80,000 or below for seven-passenger versions, or MSRP $55,000 or below for five-passenger versions)
  • Volkswagen ID.4, Pro, Pro S, S, AWD Pro, and AWD Pro S SUVs (only models made in Tennessee with an MSRP $55,000 or below for front-wheel-drive versions or MSRP $80,000 or below for all-wheel-drive versions)
  • Volvo S60 PHEV, Extended Range, and T8 Recharge sedans (MSRP $55,000 or below)
  • The IRS says that General Motors, Kia, Mazda, Mercedes-Benz, and Subaru have indicated that they plan to submit vehicles to the list, but have not yet done so.
*from CR

I guess a <$55k SR RWD Y is in the future... and/or all LR Y's will come with the third row to qualify
hahaha A Pacifica minivan is considered an SUV? What a joke.
 
There is some utter nonsense in the rules they have applied. Looks like a lot of politicking behind the scenes.
I think the issue is that if you classify the MY or Mach E as a SUV, you could potentially make the argument that all AWD sedans are actually SUVs. The Model 3 has more ground clearance than the Mach E (and not much less than the MY) so you would need some other deciding factor to split the two.

Maybe they can come with a different set of rules for EVs? I imagine EVs in general sit lower than non-EVs, but the IRS doesnt make the definitions.
 
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Are you referencing 523.5(b)? I'm not aware of what 4 requirements the MY meets. The ground clearance is less than 20 cm, so #4 doesn't apply.
Yea, I dont think the Model Y meets any of the SUV requirements regarding angles and clearances. What's fascinating though, is that the Model 3 meets more of the requirements than the Model Y; the M3 exceeds the minimum approach and departure angle requirements. According to the NHTSA, a vehicle only needs to meet 4 of the 5 requirements at one ride height. If Tesla added air suspension to the Model 3, I wonder if it could meet the ground clearance requirements (running and axle), thus passing the DOT threshold for a SUV. 🤔 😂
 
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Yea, I dont think the Model Y meets any of the SUV requirements regarding angles and clearances. What's fascinating though, is that the Model 3 meets more of the requirements than the Model Y; the M3 exceeds the minimum approach and departure angle requirements. According to the NHTSA, a vehicle only needs to meet 4 of the 5 requirements at one ride height. If Tesla added air suspension to the Model 3, I wonder if it could meet the ground clearance requirements (running and axle), thus passing the DOT threshold for a SUV. 🤔 😂
While funny, we don't want to allow the Model 3 to gain access to the $80k max price. We need to keep the Model 3 cheaper.

The Model Y needs access to the $80k max so that any of them can qualify for the credit. SUVs are always more than their sedan counterparts.

As it is, the Model 3 RWD needs a lower price as well to qualify. Right now, depending on how you build the M3, you might not qualify, which is confusing.

M3 RWD = $46,990
+ Red ($2k) + 19s ($1.5k) + White Interior ($1k) + Destination + Fee = $52,940 (Eligible)
+ EAP ($6k) = $58,940 (Not eligible)
+ FSD ($15k) = $67,940 (Not Eligible)

Which means, the M3 LR AWD can't have a base price of more than $49,049 (assuming you don't buy a UMC or Wall Connector either).
 
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While funny, we don't want to allow the Model 3 to gain access to the $80k max price. We need to keep the Model 3 cheaper.

The Model Y needs access to the $80k max so that any of them can qualify for the credit. SUVs are always more than their sedan counterparts.
In all honesty, I dont like that the bill covers vehicles up to $80K at all. If the purpose of the overarching act is to ultimately curb inflation, the Model Y at $55K sounds perfectly reasonable as a goal (same for the other vehicles in its class.) $80K is more than the median household income here in the USA. It makes me curious who is ultimately buying these vehicles that not only meet the income thresholds of the tax credit, but is also ok with the with the interest rates (the majority of new vehicles are financed.) If the average EV purchase is creeping above $60K+ (I think its $66K today), that sounds like a crisis of its own.

Secondly, I think what we're seeing in the EV market (the push towards larger, more-costly, less-efficient crossovers, SUVs, etc) is similar to what pretty much killed the [more efficient, cheaper] car market here in the US. We're already starting to see some smaller EV options being sold overseas (with decent range like the ID3) that arent coming here for the same reason (the car market is dead here.) I think the government should be incentivizing these cheaper/more efficient vehicles, but thats an argument for another day.
 
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In all honesty, I dont like that the bill covers vehicles up to $80K at all. If the purpose of the overarching act is to ultimately curb inflation, the Model Y at $55K sounds perfectly reasonable as a goal (same for the other vehicles in its class.) $80K is more than the median household income here in the USA. It makes me curious who is ultimately buying these vehicles that not only meet the income thresholds of the tax credit, but is also ok with the with the interest rates (the majority of new vehicles are financed.) If the average EV purchase is creeping above $60K+ (I think its $66K today), that sounds like a crisis of its own.

Secondly, I think what we're seeing in the EV market (the push towards larger, more-costly, less-efficient crossovers, SUVs, etc) is similar to what pretty much killed the [more efficient, cheaper] car market here in the US. We're already starting to see some smaller EV options being sold overseas (with decent range like the ID3) that arent coming here for the same reason (the car market is dead here.) I think the government should be incentivizing these cheaper/more efficient vehicles, but thats an argument for another day.
The Act is designed to sell more gas powered Hybrids (see Wrangler 4xe) and Ford Lightning, Dodge RAM REV, GMC Sierra EV trucks, etc. Those are all super expensive, hence the $80k max.

It was not, unfortunately, designed to encourage adoption by the mass market at $25-40k.