Comments on the Treatment of Electricity Used by Electric Vehicles in the EPA’s Proposed Clean Power Plan Rule Docket ID No. EPA-HQ-OAR-2013-0602

There are a number of state and utility policies that reduce total carbon emissions, while shifting emissions from other sectors to power plants. The most significant are policies to expand the use of electric vehicles (EVs) 1 . Increased deployment of EVs will increase electricity consumption and thus will generally increase carbon emissions by utilities but in most states will reduce total carbon emissions on a net basis through reduced petroleum consumption. Furthermore, the net reduction in carbon emissions due to EV adoption will increase over time as electricity generation is decarbonized. And, over the long term, transportation electrification is essential to meet the goal of deep reductions in greenhouse gas emissions from the transportation sector. While the focus of the Clean Power Plan is reducing carbon pollution from stationary power plants, the Rule should not discourage states or utilities from promoting EVs.