ZEV CARB News about Battery Swap credit's possible removal.

[FredTMC]

If this is already posted, my bad... See news article below:

I am strongly in favor of CARB keeping in place the Battery Swapping credit approved last September.
Why would CARB now consider removing that credit? Are EVs with battery swap now a meaningful portion of overall vehicles on the road? I don't think so...

I see a rally drive to Sacramento in my near future. This smells like "who killed the electric car?" all over again

Tesla profits could be challenged by Calif. credit-rule change

 

[deonb]

Isn't this news several months old?

Elon even answered questions about it during the swapper demo - and said they weren't doing swapping JUST for the credits.

 

[aviators99]

Isn't this news several months old?

Elon even answered questions about it during the swapper demo - and said they weren't doing swapping JUST for the credits.

Right, so they called his bluff.

 

[gregincal]

"

A decision should be made at the board's October meeting, said Analisa Bevan, chief of CARB's of sustainable transportation technology branch."

Tesla predicted that they wouldn't be making any money off of ZEV credits by the end of the year, and it doesn't seem like any rule change would take effect before then anyway. Regardless, Tesla should be racking up large numbers of ZEV credits. I can see this affecting Tesla in any way.​

 

[ChadS]

My understanding (it's been discussed on these forums before, although I have not been able to get confirmation) is that Tesla had already done a private swapping demo for CARB. So the public demo was not to get credits (especially given that Tesla had announced the demo before CARB started talking about changing the credits); I believe it was to prod the rest of the industry in to taking electrics seriously.

There's two aspects here. One is that the current CARB rules grant credits for just a demonstration of swapping. I am perfectly fine if they change that rule; a demonstration does not help meet CARB's air-quality goals. However, it sounds like CARB is thinking of not granting credits even if swapping is implemented, which does sound like CARB is once again de-prioritizing electrics at the request of the large automakers (there are still a lot of credits that can be had for hydrogen cars; in fact they have an awfully large multiplier). I don't think CARB should make that second change; but then again Tesla's implementation does not seem imminent, so as gregincal notes if they did it would not likely have a near-term material affect on Tesla.

 

[TonyWilliams]

I don't know the battery swapping issues at all, but the rules state "fast refueling" to get the higher credit. I guess you'd have to have a ruling on exactly what that meant.

The hydrogen cars are sexy for Toyota, Honda, et al for 2015 primarily because they CAN'T do what Tesla has done and make a 7 credit electric vehicle. With hydrogen, they can hit 300 miles and "fast refueling" for the maximum credit through model year 2017. After 2017, they have to actually get serious, which to me means more lawsuits to stop CARB-ZEV, just like 2000-2003.

It's no surprise that the big auto makers are in this game to make money, and right now they are making oodles off of oil burning cars. Toyota had a record quarter recently, and the tens of millions that they lose on Rav4 EV compliance vehicles doesn't give them warm fuzzies. Yes, they will lose a ton of dough on hydrogen also, but they can make less cars for the same overall credit value.

CARB 2012-2014 "Phase 3", 12% of production must meet Yearly ZEV requirements (including ZEV's, Enhanced AT PZEVs, ATPZEVs and PZEVs). Of that 12%, 0.79% must be pure ZEV.

Any type of ZEV may be used, including hydrogen

Type V - 300+ miles range "fast refueling" - Credit per vehicle: 7
Type IV - 200+ miles range "fast refueling" - Credit per vehicle: 5
Type III - 100+ miles range "fast refueling" - Credit per vehicle: 4
Type III - 200+ miles range -------------- Credit per vehicle: 4
Type II - 100+ miles range --------------- Credit per vehicle: 3
Type I.5 - 75-100 miles range ----------- Credit per vehicle: 2.5
Type I - 50-75 miles range --------------- Credit per vehicle: 2

After 2017, the credits for Type III, IV and V drop to 3

 

[FredTMC]

My understanding (it's been discussed on these forums before, although I have not been able to get confirmation) is that Tesla had already done a private swapping demo for CARB. So the public demo was not to get credits (especially given that Tesla had announced the demo before CARB started talking about changing the credits); I believe it was to prod the rest of the industry in to taking electrics seriously.

There's two aspects here. One is that the current CARB rules grant credits for just a demonstration of swapping. I am perfectly fine if they change that rule; a demonstration does not help meet CARB's air-quality goals. However, it sounds like CARB is thinking of not granting credits even if swapping is implemented, which does sound like CARB is once again de-prioritizing electrics at the request of the large automakers (there are still a lot of credits that can be had for hydrogen cars; in fact they have an awfully large multiplier). I don't think CARB should make that second change; but then again Tesla's implementation does not seem imminent, so as gregincal notes if they did it would not likely have a near-term material affect on Tesla.

Yep. It's completely unfair to incentivize mfgs to invest capital in fast swap capability and then quickly pull the rug out. In my view, fast swap capability IS really important in changing EV perceptions regarding range and slow charging inconvenience. In reality among EV owners, swap probably doesn't get used much especially given that range of EVs will improve beyond 200 mi.

 

[pfq1982]

Yep. It's completely unfair to incentivize mfgs to invest capital in fast swap capability and then quickly pull the rug out. In my view, fast swap capability IS really important in changing EV perceptions regarding range and slow charging inconvenience. In reality among EV owners, swap probably doesn't get used much especially given that range of EVs will improve beyond 200 mi.

As much as I love what Tesla represents, it makes no sense that they would qualify for "fast refueling" credits when absolutely zero Model S can be or are being "fast refueled" today. It's pretty clear Tesla is taking advantage of a loophole (good for them) in the regs. The CARB staff even said the rule wasn't intended to apply this way back in May.

However, the article in OP quotes CARB staff as suggesting the board will take some kind of intermediate approach. This suggests Tesla will keep the fast refueling credits contingent on actually rolling out battery swapping or making it accessible to X% of MS in CARB states. Seems like Tesla has an ally up there, or are paying some good lobbyists. The original intent of the regs will be forgotten and they will be amended to accommodate Tesla.

Before anyone gets mad at me for this, just imagine if the fast refueling ZEV bonus was contingent on MS actually being fast refueled. The swap stations would have already been in operation!

 

[gregincal]

The original intent of the regs will be forgotten and they will be amended to accommodate Tesla.

I don't understand what you mean by this. If they amend the rules to require operational fast refueling and Tesla deploys operational fast refueling via battery swapping as planned, how it that forgetting the original intent of the regs? It seems like an appropriate tightening of a loophole without throwing the original intent out altogether.

 

[deonb]

What's the value of a ZEV credit right now? Like $5000, right?

So you get $15000 per car if there is a battery swapper nearby, in other words, the extra credits from 33 cars pay for a battery swapping station? And from like 100 cars, you service and staff it for a lifetime.

Seems like we'll have a plethora of battery swappers soon...

 

[pfq1982]

I don't understand what you mean by this. If they amend the rules to require operational fast refueling and Tesla deploys operational fast refueling via battery swapping as planned, how it that forgetting the original intent of the regs? It seems like an appropriate tightening of a loophole without throwing the original intent out altogether.

If Tesla makes battery swapping available to everyone, I agree with you.

But if they require superchargers enabled, or have some other obstacle (other than pay per use) to the car being "Fast refueled", I think CARB would be going out of their way for them.

I don't know if the link is still around, but when I watched the CARB May staff hearing on this, I had the impression that the qualifiers for vehicle tiers for purposes of ZEV credits were supposed to be an actual operational/innate property of the vehicle. Not for a subset (i.e. if superchargers required), and not a hypothetical/theoretical. This is why the staff called battery swapping a "loophole" (I distinctly remember them describing it as such).

Anyway, it looks like the odds favor Tesla keeping this bonus credit, which I think they already receive. Should mean a minimum $30mm / year of pure margin is preserved, assuming they can find someone to buy them. If I was an auto maker, though, Tesla is the LAST person I would buy a ZEV from... I'd probably rather pay the penalty than support a disruptive competitor at this point!

 

[renim]

actual operational/innate property of the vehicle. Not for a subset (i.e. if superchargers required), and not a hypothetical/theoretical. This is why the staff called battery swapping a "loophole" (I distinctly remember them describing it as such).

One of the lessons of Better Place is that its cheaper to have battery swap deployment follow fast charging (instead of preceding it).

So battery swapping is not a loophole, but it is an technology that is much more sensible to deploy after
A) sizeable parc of battery swap capable cars are already on the road.
B) Highcapacity charging stations have already been built, allowing large cost and operational synergies to be obtained with co-located battery swap facilities.
C) The used/CPO market exists and is no longer immature.

Tesla is working hard on A, working on B, & assisting on C.

First adopters may not appreciate battery swap, but it is a key enabler for consumers who insist on the option of gas tank speed refueling.

Compared to H2, Battery Swap is so much more pragmatic