My Comments on the Proposed NEPA Changes

I submitted comments to the Council on Environmental Quality on February 17, 2020 on the proposed changes to NEPA Regulations. My comments in their entirety are provided below. Needless to say, I wasn’t happy.

The Current NEPA Regulations

The Proposed NEPA Regulations

Comments are due March 10th and if you are inclined to make comments on these proposed regulations, I would strongly encourage you to prepare them as quickly as possible. Please feel free to use anything that strikes your fancy.

The following comments are made with respect to the Notice of Proposed Rulemaking, Update to the Regulations Implementing the Procedural Provisions of the National Environmental Policy Act, Council of Environmental Quality (CEQ), Docket Number 2019-0003.  I make these comments as a practitioner in NEPA, Section 106 of the National Historic Preservation Act, and Section 4(f) of the US DOT Act of 1966 with over 25 years of experience at a State DOT.

NEPA is the singular environmental law in the country with 50 years of application and practice.  All of the other national environmental laws, and in practice many of the state environmental laws, point to NEPA which has acted as the umbrella environmental legislation for actions taken by Federal Agencies.  These proposed regulations weaken NEPA to such a large extent that they can only be seen as an assault on national environmental policy.  The proposed regulations should be withdrawn.

It is unfortunately necessary to remind the CEQ what the actual National Environmental Policy Act states:


Sec. 2 [42 USC § 4321]. The purposes of this Act are: To declare a national policy which will encourage productive and enjoyable harmony between man and his environment; to promote efforts which will prevent or eliminate damage to the environment and biosphere and stimulate the health and welfare of man; to enrich the understanding of the ecological systems and natural resources important to the Nation; and to establish a Council on Environmental Quality. (my emphasis).

You only need to compare the current Section 1500.1 with the proposed 1500.1 to see how far the proposed regulations diverge from the actual law and its sections.

The opening sentence of the current regulations states:

(a) The National Environmental Policy Act (NEPA) is our basic national charter for protection of the environment. 

The proposed regulations opens with:

(a) The National Environmental Policy Act (NEPA) is a procedural statute intended to ensure Federal agencies consider the environmental impacts of their actions in the decision-making process. 

The word protect appears in the current regulations 8 times as a verb.  In the proposed regulations, twice.

The shortcomings of the proposed regulations are numerous and fatal, contrary to the words and intent of the Act. Neither do they “advance the original goals of the CEQ regulations to reduce paperwork and delays and to promote better decisions consistent with the national environmental policy set forth in section 101 of NEPA” (sic).  In fact, the proposed regulations equate faster and cheaper with the goals of NEPA, leaving out the Law’s original intent to provide better decisionmaking (Section 102(C)).

My remaining comments are made in order of reference to the proposed regulations and not in order of importance.

1500.3. NEPA Compliance. The entire tone of the proposed regulations is hostile to the public’s role in commenting and treats participating agencies and the public as checkboxes that need to be filled out as quickly as possible.  The tone of the regulations could be summed up in the addition of a new Section 1500.3(c). Actions Regarding NEPA Compliance, which is not in the current regulations.  The section discusses at some length the role and timing of judicial review (upon lawsuit), and the potentials for bonds or other limiting security requirements to be placed on private parties (read the public).

With regard to Remedies under 1500.3(d), it is sometimes true that harm from the failure to comply with NEPA can be remedied by compliance with NEPA’s procedural requirements; however, there are times where harm is irreparable, especially when a project is approved and proceeds under faulty premises.  One only needs to look as far as construction of the Border wall in the Organ Pipes National Monument.  This project which had NEPA waived under the REAL ID law of 2005 has resulted in numerous destroyed and irreplaceable archaeological sites.  This controversial project is currently in the courts.  What can compliance with procedural compliances do to replace these archaeological sites, should this project be declared illegal? They are destroyed and the damage cannot be fixed.

1501.1. NEPA threshold applicability analysis.  This is a new concept that establishes a trigger to determine if NEPA analysis and related activity should be required at all. It creates a “minimal government funding or involvement” threshold, below which project planners would, presumably, not engage in a NEPA review. This is an unnecessary and potentially harmful test. First, under the current regulations, actions undergo a three-part test as to whether they have the potential for significant impacts.  Those that have been defined through a separate process of rulemaking as not having significant environmental impacts are considered. Categorical Exclusions (CE).  Yet, even the CE’s undergo a limited environmental analysis to ensure they fit the exclusion tests.  The point is that all actions are subject to EPA, but not all actions require intensive environmental analysis.  Secondly, NEPA applies to all Federal agencies (Section 102).  A threshold analysis that is premised on an agency lacking authority to consider environmental effects (1501.1(a)(2)) goes against the letter and spirit of the law.  Finally, agencies often follow multiple overlapping laws in environmental compliance.  The role of NEPA is integrating and coordinating other agencies with legal responsibilities.  Parsing out whether NEPA applies or not based on whether there is another relevant law rips the NEPA umbrella apart and creates a confusing patchwork of responsibilities.

What constitutes a major federal action is not defined. The language surround this concept mostly discusses what is not a major federal action, but even these key concepts are not clearly laid out.  There is a misunderstanding within CEQ that major equates to percentage funding.  This would suggest that Federal agencies that only have permitting control should not have oversight over privately funded projects that require permits, such as USACE permits.  Permitting is an important Federal action and falls squarely within the mandates of NEPA.  We can see today the great environmental harm from pipeline construction in places like Pennsylvania, my home state, where Congress in its infinite wisdom saw to severely limit permitting control by the USACE through the Energy Policy Act of 2005 and its Halliburton Rule.  These changes to NEPA regulations would have a similar effect but in a much wider arena.

In addition to permitted projects, increasingly public-private-partnerships (P3) are emerging as a major means by which infrastructure is addressed.  P3 sponsors are generally disinterested in following environmental laws and regulations and are only held to account by the federal agency under which they are operating.  But for NEPA and its implementing regulations, P3 projects would wholly disregard environmental considerations.  I saw this firsthand in Pennsylvania with the Rapid Bridge Replacement P3 Project, where the design firms had to be repeatedly reminded of their environmental responsibilities during design and later their mitigation commitments under construction.  Although ultimately, the contractors followed NEPA, it was only because of pressure by FHWA and PennDOT.  This particular project had almost no Federal funds involved and would not have met the test of a major Federal action, even though it involved the replacement of 558 bridges across the state at a cost of nearly $1b.

These concepts also disregard the potential for significant impacts to historic and archaeological resources, when projects fall below this line of federal funding.

1501.2. Apply NEPA early in the process. The current language of “shall” and “possible” should be retained instead of watering it down to “should” and “reasonable.”  This is especially relevant if the goals of CEQ are to reduce the time for preparation of NEPA documents and review.  Although, agencies need the discretion to structure the timing of their NEPA processes to align with their decision-making processes consistent with their statutory authorities, agencies also need to be reminded to begin NEPA early.

1501.4. Categorical exclusions. Section 1501.4(b)(1) is probably incorrect as written.  Extraordinary conditions that could mitigate to avoid significant effects are normally treated as a mitigated FONSI.  You really need to do the analysis to ensure that the mitigation will remove the significant effects. This is not normally within the purview of a categorical exclusion.

1501.8. Cooperating agencies. There are a few positive changes to the proposed regulations, as you should expect in any revision, most notably the explicit elevation of Tribes to cooperating agencies (See 1501.8(a)).  However, even this particular improvement is diminished by not treating Tribes as sovereign entities that require government-to-government relations.  Putting Tribes in with other state and local governments is a common mistake in consultation and violates treaty law.  Finally, the lack of consultation with Tribes in the formulation of this proposed regulations undercuts any positive feelings anyone should have regarding the change.  If it’s good enough to be put into the proposed regulations, why wasn’t it good enough to put into practice during its development.  CEQ, heal thyself!

1501.10. Time limits.  Under Section 1501.10, EIS’s would be completed within 2 years of NOI to ROD. EA’s would be completed within 1 year of decision to start to publication of EA.  It is unclear what formally time dates a decision to start an EA, and the ultimate decision of the EA, either a FONSI or development of an EIS, is unstated.  The 2 years for the EIS is too limiting.  An EIS is being prepared because there are significant environmental impacts.  Treating them like a hoop to jump through disrespects the Law and the role the public has in decisionmaking.  But time limits for an EIS or EA are just one place where the role of public input is diminished.

The proposed regulations repeatedly argues that the timelines for completing environmental reviews can be very lengthy, and the process can be complex and costly. This has not been my experience in over 25 years of NEPA work. In the state DOT where I worked, 97-98% of all projects were categorically excluded.  For the majority of these, the NEPA effort took days, not weeks, and was completed on a one-page form.  However, even in that expedited and programmatic format, necessary environmental issues were considered.  For smaller projects, the single factor in extending the NEPA timeframe was lack of project design preparation on the part of the design engineers – they didn’t know what they wanted to build to a level sufficient to understand the environmental footprint.  For larger projects, the single factor in extending the time to the ROD was fiscal. Projects were put on the shelf mid-way due to lack of funds.  The second factor after funding was the simple fact that these were complex and controversial projects with numerous environmental impacts.  These projects required careful analysis and full public participation, which could be rushed.  We would find that if the public was squeezed out of the process, usually due to deadline pressures, we would see them a bit later in court.  Rushing to meet a project deadline always ensured the project took longer to build than it needed.

1502.7. Page limits. As far as page limits go, the proposed regulations will be completely ineffective.  Yes, the EIS can be limited to 300 pages, but the full document will be as long as ever.  In order to meet time limits, the content will be (poorly) summarized into the body of the EIS, with all of the additional material added as appendices. The proposed time constraints (see above) will only put additional time pressure on the production of the EIS, most likely making it longer, more poorly written, and organizationally ragged.  Secondly, plain writing has been an EIS requirement for some time (1502.8 in the current regulations). Instead of mandating that the statements be written in “plain language,” you would have better luck mandating that any engineering firm that is contracted to produce an EIS be required to hire professional technical writers to produce the text. Yes, most EIS’s are led by large construction engineering firms, the vast majority of which do not value clear writing.  In theory, if you had enough engineers on enough typewriters with enough time, eventually you could produce a readable EIS.  In theory.

1502.13. Purpose and need. The changes to Purpose and Need (1502.13) are misguided and unnecessary.  Ultimately, the Federal agency is the responsible party for compliance with NEPA, not the applicants.  The project need is the basis for establishing the alternatives and what constitute all reasonable alternatives.  The goals of the applicant are not relevant to the analysis, and are frequently subject to local political pressures to build, build, build regardless. The Federal agency’s authority is either there or not there, and not subject to parsing.  I state this as a 25-year employee for an applicant for Federal Funds, at a state DOT.  The FHWA has had the ultimate responsibility for determining what is purpose and need, ultimately to the DOT’s benefit and the public’s.

1502.14. Alternatives including the proposed action. The standard of all reasonable alternatives as noted in the current regulations should be retained.  All reasonable alternatives is a much higher standard for consideration and ensures that analysts consider alternatives that might not otherwise be considered. It is a useful tool and forces the agency to sometimes think creatively and productively.  Again, I put my 25 years of NEPA experience forward as seeing additional alternatives developed when all existing studied alternatives were found wanting.  Sometimes, an agency has to turn over extra rocks to get to a good decision.  The idea of limiting the number of considered alternatives to 3, one of which is usually no-build (not completing the project), is just plain silly.

1502.24. Methodology and scientific accuracy. The proposed regulations would require agencies to “make use of reliable existing data and resources and are not required to undertake new scientific and technical research to inform their analyses.”  This allows agencies to avoid ensuring the professional integrity sometimes needed in environmental analyses, when existing data is missing or deficient.  This is particularly true in archaeology, where actual archaeological resources may be known only by conducting new scientific surveys and studies. The entire knowledge base of archaeology is premised on the fact that very few existing archaeological sites are known prior to intensive investigation of an area.

1508.1 – Definitions

Effects. The removal of the concepts of “direct effects,” “indirect effects,” and “cumulative effects” from the proposed regulations simply violates the language of NEPA, specifically in the purpose of the Law, as well as Policy:

“to improve and coordinate Federal plans, functions, programs, and resources to the end that the Nation may –

3. attain the widest range of beneficial uses of the environment without degradation, risk to health or safety, or other undesirable and unintended consequences; “ (my emphasis)

Under Section 102, “all agencies of the Federal Government shall – 

(C) include in every recommendation or report on proposals for legislation and other major Federal actions significantly affecting the quality of the human environment, a detailed statement by the responsible official on — 

(iv) the relationship between local short-term uses of man’s environment and the maintenance and enhancement of long-term productivity,…” (my emphasis)

It appears that the purpose of narrowing the definition of effects is more a nod to the fossil fuel industry than anything else and an attempt to preclude using NEPA to address the current climate crisis, despite the climate crisis being the existential environmental issue of this century. There is no other explanation.

Human Environment. This is an overly narrow definition for Human environment and disregards prehistory in  environmental analysis.  The current definition should be retained. Investigation of the archaeology within a project connects past generations with present and future generations.  Only considering present and future generations in the discussion is to erase our past.

Significantly. The current definition of significantly (1508.27) has been removed and not replaced by any comparable guidance.  Significance is a central concept to NEPA and the triggering requirement for preparing an Environmental Impact Statement, i.e. significant environmental impacts.  Not defining significance in regulations that entirely revolve around this concept is irresponsible.  The CEQ has a legislative responsibility under Section 204(4) to:

“develop and recommend to the President national policies to foster and promote the improvement of environmental quality to meet the conservation, social, economic, health, and other requirements and goals of the Nation” (my emphasis)

At the very minimum, CEQ is obligated to define significant environmental impacts.

The current regulations appear adequate for our current needs and do not require the severe makeover presented in the proposed regulations.  Indeed, the proposed regulations acknowledge that “over the past 4 decades, CEQ has issued over 30 documents to provide guidance and clarifications to assist Federal agencies to more efficiently and effectively implement NEPA.” 

These proposed regulations are badly informed and threaten the health and well-being of all Americans.  They should be withdrawn.

TRB, Taxonomy, and the Island of Misfit Toys

An open letter to the leadership of the Transportation Research Board

I write as a transportation professional with over 30 years of experience working for state Department of Transportations, both in Maryland and Pennsylvania.  My specialty is in historic preservation and I have a PhD in anthropology with an emphasis in archaeology from The Pennsylvania State University. I have been a friend or member of ADC50 (originally A1F05) during this time and have served on several 25-25 research panels.  In 2001, PennDOT chose to award me a Star of Excellence, which honors the top half of one-percent in the agency.  In 2012, the Pennsylvania State Historic Preservation Officer gave me a Visionary in Historic Preservation Award.  I’d like to think I know my business.

The Transportation Research Board has recently undertaken a complete overhaul of TRB’s Committee Structure. The new TRB structure renumbers the ADC50 Committee on Historic and Archaeological Preservation in Transportation (AME60), and moves it from the old Environment and Energy Section (ADC00) to a new Transportation and Society Section (AME00) within a new Sustainability and Resilience Group (AM000).  The Historic and Archaeological Preservation in Transportation Committee still exists, for which I probably should be grateful as many other worthy Committees have been eliminated and/or consolidated.  However, the move into the new Transportation and Society Section and a review of fellow committees within the Section and Group immediately reminded me of a scene early in the movie Animal House.   Faber College freshmen Larry “Pinto” Kroger and Kent “Flounder” Dorfman are seeking to join a fraternity and come across the prestigious Omega Theta Pi house party.  Almost immediately they are sized up and ushered into a “special” room containing all of the potential pledges that are deemed unworthy.  The image of that room, with all its lost souls, says all you need to know about Omega Theta Pi.

Animal House (1978)

The Island of Misfit Toys

The list of Committees within the Transportation and Society Section also says all you need to know about TRB decisionmaking.  Historic and Archaeological Preservation in Transportation (AME60) is buttressed by not one, but two Federal laws – Section 106 of the National Historic Preservation Act, and, Section 4(f) of the US DOT Act of 1966. One can make the case that the role of the Committee extends beyond these two laws, especially with regard to Planning and Environmental Linkage (PEL), but by and large the Committee’s work is focused on implementation of these two laws.  

AME60 is possibly the only Committee other than AME30 in the Section with a focus underpinned by Federal legislation.  Surveying the other Committees in the Section, it appears AME60 has truly been moved to the island of misfit toys.  Rightly or wrongly, most engineers will react to what they are legally required to do, not what they morally should consider.  It is the nature of working in the Land of Engineers.  Archaeology and historic preservation have a pair of 50-year old laws underpinning our work, along with supporting Federal Regulations.  If I had a nickel for every time I had to tell an engineer, “because it’s the law,” I would be writing this letter from my personal island in the Bahamas.  On these grounds alone, AME60 is misplaced.

Rudolph and the Island of Misfit Toys (2001)

Going through each Committee within the Section:

  • Equity in Transportation (AME10)  is the old ADD50, the Committee on Environmental Justice.  From their web site, the Committee on Environmental Justice identified, advanced and published research to expand understanding of the effects and implications of transportation policies, procedures and actions on minority and low-income populations (EJ populations), and sought to improve evaluation tools and methodologies.  Environmental Justice is supported by a 1994 Executive Order (12898), but no specific legislation.  In 2017 and 2019, Congress tried unsuccessfully put into effect laws to support Environmental Justice.  And we all know how tenuous Executive Orders are at this time.
  • Women’s Issues in Transportation (AME20) is the old ABE70.  From their web site, the people who proposed and supported the Women’s Issues in Transportation group recognized the need to consider gender as an important factor in the way people travel. Is there underpinning legislation to support this worthy mission?  Or to put it bluntly, is there any legislation that mandates that engineers and designers consider gender?
  • Native American Transportation Issues (AME30) is the old ABE80.  From their web site, the Native American Transportation Issues Committee is concerned with research and practice pertaining to transportation issues on or near tribal lands and communities or affecting tribal historical or cultural properties wherever located. Tribal transportation issues include all modes of moving people and goods from one place to another, all relevant agencies including tribal, state, federal, regional and local providers, and all relationships and interactive processes of various governmental units – tribal, federal, state and local – with regard to the development, planning and administration, coordination, and implementation of transportation laws, policies, plans, programs and projects.  ABE80 has worked closely with ADC50 in the past and it would probably be appropriate to put both Committees in the same Section (but see below).
  • Transportation in the Developing Countries (AME40) is the old ABE90.  Other than it being part of the old ABE Policy Section, it is unclear why this Committee is put with the others in this Section.  And it goes without saying, there is no Federal legislation underpinning the activities of this Committee.
  • Accessible Transportation and Mobility (AME50) is a combination of the old ABE60 and APO60 Committees.  From their website, the Committee’s mandate is to educate everyone on the issues and gaps related to mobility needs for people with limited transportation options – people with mobility, sensory and cognitive disabilities; older adults; and individuals without private transportation.  There appears to be no Federal legislation underpinning the activities of this Committee, although some of their work would encompass the Americans with Disabilities Act.
  • Transportation and Public Health (AME70) (new*) – This probably comes out of the NCHRP D20112 – Panel on Research Roadmap – Public Health and Transportation.  I don’t believe there is Federal Legislation to focus activities of the Committee, although there should be.
  • Community Resources and Impacts (AME80) (new*) – This probably comes from the roots of ADD20 – Standing Committee on Social and Economic Factors of Transportation.  Other than the relatively vague missives in the National Environmental Policy Act, there is no strong legal underpinning for issues related to this Committee.  I had specific experience working with community concerns over small bridges that were valued by the local community but did not fit within the eligibility criteria of the National Register and hence weren’t subject to Section 106 or 4(f).  Trying to wheel the Department around to seriously considering these as resources within NEPA was a big lift, without mandating legislation.

The NEPA Umbrella – RIP(ped)

As a cultural ecologist, one of the things that is drummed into your head is the concept of the interplay between people and the environment, especially how homo sapiens is just one species in an ecology of earth, perhaps the biggest and baddest species, but still part of the system.  I have been able to align my education and training in my transportation career precisely because of the nature and role of the National Environmental Policy Act (NEPA)

The purposes of the National Environmental Policy Act (NEPA) of 1969 are: 

To declare a national policy which will encourage productive and enjoyable harmony between man and his environment; to promote efforts which will prevent or eliminate damage to the environment and biosphere and stimulate the health and welfare of man; to enrich the understanding of the ecological systems and natural resources important to the Nation; and to establish a Council on Environmental Quality. (my emphasis)

In Section 102 (A), Congress directs that

… all agencies… shall utilize a systematic, interdisciplinary approach which will insure the integrated use of the natural and social sciences and the environmental design arts in planning and in decisionmaking which may have an impact on man’s environment. (my emphasis)

The NEPA Umbrella (Courtesy Missouri Department of Transportation)

I think it is necessary to restate the purpose of NEPA and to remind everyone that NEPA is integrative, system focused, and recognizes the interplay between human activities and the environment within which they operate.  The NEPA umbrella is a concept that has emerged from the 1969 legislation.  Multiple laws, executive orders and regulations are considered in the NEPA process. Not only are environmental features studied; so are impacts to the economy and society.  For my entire career, the NEPA umbrella has been a central starting point in any work.  Preliminary design does not end until a NEPA document is approved, which means all of the umbrellaed laws have been addressed, including Section 106 and 4(f).

In the old TRB structure, the NEPA umbrella was reflected in the makeup of ADC00 – Environment and Energy: Environmental Analysis (ADC10)Air Quality (ADC20)Ecology (ADC30)Noise and Vibration (ADC40);Historic and Archaeological Preservation (ADC50).  Each Committee had underpinning legislation tied to NEPA.

Whither NEPA in the new TRB structure?  It  has been moved to the Data, Planning, and Analysis Group as Environmental Analysis and Ecology (AEP70).  The old ADC30 on Ecology has been merged into that Committee.  Noise and Vibration (old ADC40) has been brought over to that group as AEP80.  Air Quality joins Historic and Archaeological Preservation in the Sustainability and Resilience Group, but under the Transportation and Sustainability Section as AMS10.  The old NEPA umbrella has been shredded, at least as far as TRB is concerned.

The new NEPA Umbrella

As an archaeologist, one of the things that is drummed into your head is the concept of taxonomy and classification.  This is particularly true in artifact analysis, whether it be pottery or lithics.  The goal of classification is to put like things together and separate them from things that are not the same, for the purpose of a higher analysis and understanding.  Often the goal is creating a chronology, but in the past (and to some degree still relevant), types reflect a cultural continuity, e.g., the Beaker people.  A society could be reflected in a particular artifact type.

There is a natural tendency to categorize and classify.  It’s a very human thing to do.  But classifications should be useful in some way.  You can certainly argue that NEPA analysis is an analysis just like planning analysis, and perhaps belongs in that Group.  However, to strip away half of the Committees that used to sit under the NEPA umbrella, e.g. ADC20 and ADC50, and spread them to the winds does not seem useful.

Sustainability and Resilience!

The heavy impact of a rapidly warming planet on infrastructure is indisputable and should be a matter of great concern to all of our public leaders.  It is naturally the role of TRB to get ahead of this crisis and advise agencies.  TRB is right to have created a new group on Sustainability and Resilience.

That being said, when I actually look at the composition of the Group and its sections, I get that sinking feeling that: (a) the leadership of TRB could not agree on how to structure the new Group; (b) they are clueless about how TRB should address the climate crisis; or (c) don’t care.  Simply stated, most of the Committees in the Transportation and Society Section have nothing to do with Sustainability and Resilience, e.g. Women’s Issues in Transportation, or Historic and Archaeological Preservation?!  Many of the other Committees in the Group seem like duplicates, e.g. AME70: Transportation and Public Health and AMS10: Air Quality and Green House Gas Mitigation.  Air quality is a public health issue. That’s why it’s measured. AMR 20: Disaster Response, Recovery, and Business Continuity and AMR50: Natural Hazards and Extreme Weather Events are two sides of the same coin.  

Beyond that, you could argue that real and important Transportation Planning (Section AEP00) must start with Sustainability and Resilience principles, so that maybe it would make more sense to put that entire AM000 Group into Planning, or break AE000 into Data and Analysis in one Group and (real) Planning that considers the climate crisis into another.

Why Should Anyone Care?

I’ve spent over 2,000 words complaining about the new Committee Structure.  Should anyone outside of TRB or even inside TRB even care?  Most committees are being carried forward.  AME60 will exist and persist.

In TRB, structure is resources, more specifically allocation of finite resources.  Committees compete within Sections, Sections within Groups.  It affects budget, symposia allocations, the ear of the Section or Group coordinators, and even the ability to communicate with TRB Leadership.  The balancing of Groups and Sections is the balancing of all of these competing interests, and fairness should dictate that like competes with like.  There is little cohesive within the Transportation and Society Section (AME000) or even within the Sustainability and Resilience Group (AM000).  It is as if all of the scraps from the original cuttings of Groups and Sections were swept up and put under a new rug.  In the process, the NEPA umbrella is discarded.  Important and critical work for TRB with regard to climate change impacts is diluted.  Other Committees that probably should have standing at a high level, such as AME20, are disrespected.  AME20 more realistically should be under the Executive Management Issues Section (AJE00).

To the degree that the new TRB structure is meaningful to transportation professionals across the country, this organization is yet another signal to transportation engineers that people issues are wholly secondary to concrete and asphalt.  People are unpredictable. They complain.  They challenge.  People stand up to the elegantly designed roadway and bridge plans and dare to suggest that transportation infrastructure need to be harmonious with society, not apart from it. People suggest that some of the important factors, like accessibility, or appreciation of the past, are difficult to measure, but nonetheless important to consider.  They are the ones that suggest that the welfare of the bugs and bunnies is also the welfare of all of us.  Constituting the Sustainability and Resilience Group the way it has been put together just seems like a kick in the ass.

Finally, although this might be much ado about very little, we should remind ourselves that money spent on archaeology and historic preservation in transportation projects far outstrips the funds that the National Park Service provides. In virtually every state, DOT’s spend more on archaeology and historic preservation studies than any other agency or group.  So even small signals in the transportation sector can reverberate to the larger preservation community.  To paraphrase Metternich, when transportation archaeology sneezes, historic preservation gets a cold.

The Electric Car Driving Experience. Part 1: Around Town and Hill and Dale

Had to sneak in a picture of Pennsylvania Native Ray Harroun, winner of the first Indianapolis 500. He’s behind the wheel of a Marmon Wasp, not an electric.
  • True or false.  The electric car is small and tinny and generally uncomfortable.
  • True or false.  The electric car is underpowered.
  • True or false.  The range of an electric car is still too small to be practical.
  • True or false.  The weight and distribution of the batteries in the electric car makes it poor in handling.
  • True or false.  The electric car is expensive to maintain.
  • True or false.  The instrument panel of an electric car is difficult to understand and manage.

Guess what?  The answers to all of the above questions are false.  Preacher Beckerman is here to assist you in getting over your anxieties of operating an electric car.  And although we can’t place you into the seat of an electric car to drive around,  my soaring prose should fire your imagination to feel that you are riding beside me.  Or some sh*t like that.

I can speak to the Nissan Leaf experience as we have had one for two months and have put around 1,600 miles on it.  Having had my driver’s license for 50 years with over a half million miles under my belt, I have been behind the wheel on practically every type of passenger vehicle around, as well as a 1974 Suburban and a 1967 Ford F-100 farm truck.  The Leaf is both like and unlike other vehicles on the road today.

The impression you get driving a Nissan Leaf, and probably most other electric cars, is just how normal it feels.  It has 4 passenger doors and a hatchback. You swing open the door, throw your butt on the seat and paw for the seat belt always behind you on the left in a place you almost can reach.  You pull the door shut and adjust the seat and the mirrors, because your spouse used the car last and is somehow not the exact height and trunk length you are.  Ready to go, you put your foot on the brake and press the on switch, which is where the old cigarette lighters used to be back in the day.  You can find the switch because it is lighted even though the car is not started.  You can also find the switch because it is also the same type of starter that the Prius has and I suspect most modern cars have when they use a fob system.  Once upon a time there was this thing call a key and you pushed it into a keyhole and turned it until you heard a starter motor turning. That is unless you owned a 1966 Volvo, in which case you needed to pull out the manual choke first and of course put your left foot on the clutch and the right one on the brake.  In my lifetime no less.

When you push the starter button, you get a few reassuring clicks, but nothing else, no starter motor, no engine noise.  The instrument panel in front of you goes from the dormant how-many-hours-until-the-car-is-charged mode to the operating mode.  If the parking brake is on, you press that switch and it makes a barely audible brrrr as it turns off.  Provided you have opened the garage door, you are ready to go, putting the car into reverse with that nubby little stub of a shifter.

As you back out using either the techy butt-cam as a guide or the old-fashioned over the shoulder look, the steering is remarkably tight, meaning you have to pay attention not to drive the car into the grass on either side or the light pole on the left as you exit the driveway.  Reaching the street, you put the car into drive and hit the gas (now merely a metaphor).  What is the gas pedal on an electric car called, anyway?  The weasels at Nissan call it an “accelerator pedal.”  But the brake is called the brake pedal not the decelerator pedal, so something fishy is going on here. Where’s George Carlin when you need him?

Whether hitting the gas or accelerating, the Leaf jumps to.  The biggest learning step to driving the Leaf is how quick it is from a full stop.   Almost instantly, you are at 25 mph.  What is deceptive is that getting there is in pure silence.  The dc motor doesn’t rumble, whine, or whinny.  You do have to pay attention to your speed as it always feels to be less than it is.  This should not be surprising as the more famous Teslas have 0-60 mph times slightly behind the Porsche 918 Spyder and ahead of the Lamborghinis. Electric cars do have excellent acceleration. The Leaf we have can reach 0-60 in 6.5 seconds, faster than the Honda Civic, Toyota Corolla, or Chevy Malibu, but slower than the Dodge Charger R/T.

While driving, the Leaf is incredible quiet and most of what you hear are the tires, wind, and other cars on the road.  This is a serious safety issue that will have to be addressed and soon.  Pedestrians simply can’t hear the car coming, with no muffler and no engine noise.  Currently, new cars sold in the EU must come equipped with an acoustic sound system that will produce a sound when reversing or driving below 12 mph.  The new electric Ford Mustang will generate synthetic motor sounds which apparently is like a SCI-FI v-8 in a Bladerunner movie.  Personally, I would prefer Joe Pesci yelling at people to get the f**k out of the way.

2019 Leaf Battery pack

Driving the roads, hill and dale, an electric car handles just like a regular car- brakes brake, the steering wheel turns, the accelerator thingy does its thing.  The Leaf is not a large car, certainly not the Buick, more on par with the Prius, perhaps a smidge smaller.  The seats are comfortable and adjustable and even heated (an option we took to get the safety package).  Other than the overall quiet and the quick acceleration, an electric car is about as normal as a car can get, once you have it on the road.  Speaking of handling, the batteries on the Leaf are situated low in the body literally between the four wheels.  This helps keeps the Leaf on the road, in twists and turns.

2019 Leaf Dashboard

With regard to the instrument panel, Nissan has divided duties between the instruments that are in front of the steering wheel and instruments on an 8-inch touch screen where the radio would be.  The instrument cluster in front of the steering wheel gives you the standard time, speed, etc.  The central control panel is where the standard radio, phone, and climate controls are placed.  As with most recent cars, much of the audio, climate control, and cruise controls can be operated on the steering wheel itself. The differences between the 2019 Leaf and the 2015 Prius are only one of degree and probably due to the difference in ages of the two cars rather than the one being electric and the other a hybrid.  What the Nissan does have are additional screens in both panels to monitor and track electric usage.  The kWh gauge replaces the mpg gauge.  On the touch screen display there are gauges to monitor climate system electric usage versus other systems usage, overall usage and scenarios for added or reduced range from turning the climate system on or off.  Most of these additional gauges and displays are geared to help the driver control and monitor the overall range.  

1927 Chevrolet dashboard
1930 Ford Model A dashboard

As a historical note, the locating of controls and gauges to the right of the driver is not new.  In the 1920’s, all of the controls were in the center of the dash, not in the driver’s line of sight.  In summary, the location of controls and gauges in the Leaf, an electric, is very similar to that of the Prius.  The main difference is the addition of gauges that monitor electric usage.

And as a final point, when driving home from an errand and past a gas station, I usually smile as this vehicle will not be visiting there, unless I need a coffee or beef stick.  The routine we’ve settled into is to charge the Leaf overnight on our Level 2 charger we have in the garage.  With a charge, we are getting about a week’s worth of travel around town and running errands.

In another post, I discussed the issues of range, availability of charging stations in Pennsylvania, and cost of operation.  The intent of this blog was to demystify the actual driving experience.  Driving an electric car is much like driving a gas-powered vehicle, except it is quieter and has more pep.  All things being equal, I’ll stay with the electric car as a superior form of transportation, at least for local trips less than 75 miles.  Based purely on the driving experience, if you are in the market for the next car, Preacher Beckerman says you should take a look at an electric.

An Electric Runabout? In 2019?

Although not clear from the book cover, Tom’s electric runabout was painted glossy purple to distinguish it from the other race car entries.

The initial blog, “Ira Beckerman and the Electric Runabout” and the heading for future posts, “The Electric Runabout” uses words that seem positively archaic, especially when talking about cutting 21st century age technology.  Why that choice?

 In 1910, a publisher Edward Stratemeyer, began a series of children’s books featuring Tom Swift, an inventive and science-minded teenager.  In quick order, Tom creates a motor cycle, a motor boat, an airship, and a submarine boat before coming to his project for the 5th story, an electric car.  This vehicle featured a powerful new rechargeable battery that could go 100 miles per hour and had a 400 mile range. One hundred and ten years later, we are still striving for a car as good as Tom Swift’s.  Elon Musk, are you listening?

Key to Tom’s electric runabout was the use of a solution of potassium hydrate and a lithium hydrate boost to run an oxide of nickel with steel and oxide of iron negative electrodes.  The nickel-iron battery had been perfected by Edison in 1901.  Keep in mind that most electric cars of the time ran on lead acid batteries.  Lithium might have been a lucky guess for Tom, but it is the key to modern rechargeable batteries.  Tom’s new battery would take half the recharge time of other batteries.  The race that he entered was 500 miles around a track in Long island. Twenty cars were entered, including other electric cars, steam and gasoline powered.  In 1910, electric cars were at their zenith and it was not clear that gasoline powered vehicles would prevail.  Introduction of the electric starter in 1912 pretty much sealed the advantage of gasoline powered cars, along with the inherent problems of electric cars of the time, being range, recharge times of the lead acid batteries, and the initial higher cost of manufacturing.

A 1909 roadster at the Vanderbilt race. No windshield, two seats, relatively light.

The runabout that Tom Swift built was a common vehicle of the time, a light basic style with no windshield, top or doors and a single row of seats.  They were designed for light use over short distances, distinguishing them from the tonneau, touring, phaeton, coupe, and sedan.  Over time, the runabout was replaced by the roadster.  We don’t use the term runabout much anymore, but it is still used in Britain to refer to the same kind of small car used over short journeys.

Tom Swift was inspired by inventors such as Henry Ford, Thomas Edison, Glenn Curtiss, and Alberto Santos-Dumont.  He inspired more recent inventors such as Bill Gates, Paul Allen, Steve Wozniak, and Ray Kurzweil.  Given that the current crop of electric cars are best used for light use over short distances, perhaps runabout would be a fair descriptor.  So thank you, Tom Swift.

Ira Beckerman and the Electric Runabout: An Introduction

On September 16, 2019, Linda and I bought our first all-electric car, a 2019 Nissan Leaf.  How we came to buy an electric car was the result of a the convergence of several events.  First, we had reached the emotional limit on the 2008 Buick Lacrosse we had acquired from Linda’s mom, a big lumbering couch that got 18 miles per gallon.  It ran and we owned it clear, but that was about all you could say about it.  Secondly, we had someone inquire about the car/couch, someone who wanted that basic transportation.  It got us thinking about what would replace it.  We have a 2015 Prius with about 60000 miles on it.  Our strategy for the last 20 years has been to have one newer car and one older car, rotating out the older one after driving it into the ground (figuratively, please!).

We had a long discussion as to whether we could actually manage on one car only, which would be cheaper if somewhat inconvenient.  We are both busy in our retirements and have enough appointments independent from one another as to make a single vehicle household impractical.  So a second car was going to be in our lives for a while. But an electric?

Why Should We Care?

We have been mindful of what is happening around us in the world.  The Environment Section of the Blog is a result of that mindfulness. If we are going to be better than OK Boomers, we need to continue to reduce our carbon footprint.  Last year, we put up solar panels, a start.  The next step seemed to be getting an electric vehicle, an EV.

On moral grounds, decarbonizing where we can seems compelling.  The average automobile uses something like 650 gallons of gasoline a year.  [The number is squishy, because no one really tracks it.  We don’t track average mpg for all cars, only new cars. We count total gallons used nationally, but not for the individual car. So any rough number will do.]  We do know that each gallon yields 19.64 pounds of CO2 into the atmosphere.  So, roughly each gasoline powered car pushes a bit over 6 (2,000 pound) tons of CO2 into the air each year.  For comparison, 6 tons is slightly less CO2 than Pennsylvania produces every second of every minute of every day in a year.  While you might think that this means cars don’t produce much CO2, keep in mind that there are over 8 million passenger cars on the road in Pennsylvania, so the automotive car sector contributes 20% of all CO2 produced each year, which is not insignificant.  One car barely qualifies as a flea bite, but a swarm of cars can affect our climate.

The economics behind electric cars don’t seem to be in our favor. Gasoline is $2.70 a gallon, the lowest it’s been in 20 years.  The Administration is pushing coal, and is fighting CAFE standards.  Americans bought 43 pickup trucks for every electric car bought last year. Toyota sold more RAV4 SUV’s by March 10th than all of the electric cars of all models sold last year.  Registered electric cars in Pennsylvania topped 7,600 last year, all of 0.09% of registered cars statewide.  In Cumberland County, we were likely the 120th registered electric car.  What is wrong with this picture?

Fritchie Electric Car, ca. 1905

The Case for Electric Cars

Electric cars have been among us for over 100 years.  In urban areas, they preceded gasoline powered vehicles.  In 1900,  38 percent of cars were electric powered, with 22 percent powered by gasoline.  The remainder were steam powered.  Today, the technology for EVs is reasonably mature.  Practical electric cars, relying on lithium-ion batteries, have been on the road for around 10 years, beginning with the Tesla Roadster in 2008.  The issue with range is being addressed stepwise, so that now there are several choices for cars that get more than 200 miles on a charge.  Infrastructure is being developed nationwide, but unevenly, so that it is possible to see a day in the not too distant future where effective and quick chargers will be no more than 40 miles from anywhere.  And finally, electric cars do not emit CO2.

Cost has also dropped, largely due to the cost of manufacturing the batteries.  Both the entry level Chevy Bolt and Nissan Leaf Plus have MSRP’s under $37,000 (before any credits or rebates).  [See Ford Vs Ferrari?… for a side-by-side comparison of Leaf Vs Bolt.] The cost of ownership is also greatly influenced by Federal and state credits and rebates.  The tax credit landscape is uneven, as some cars have reached the 200,000 car limit for full rebates.  As of this writing, The Tesla rebate for the Model 3 has expired.  The Chevy Bolt has a $1,875 Credit until March 31, 2020.  The Nissan Leaf has a $7,500 Credit that is not set to expire in the near future.  In addition to the Federal Tax Credits, Pennsylvania is offering a $1,500 rebate at least through December 31, 2019.


To be clear, owning an electric car isn’t for everyone, at least not yet.  Range is an issue, but not insurmountable.  Few EVs have a range comparable to a gas-powered vehicle, which is usually over 300 miles.  More importantly, using an EV for travel depends on the presence and abundance of EV charging stations.  Charging stations come in two main types – Level 2 and Level 3.  Level 2 chargers run at 240 Volts and most vehicles can use them interchangeably.  However, it takes approximately 8-12 hours to fully charge a vehicle that has a 200+ mile range.  For a road trip, that’s a show stopper, unless your one-way trip distance is within that 200 mile range.  Level 3 chargers generally can put 80% of the electricity bank into the “tank” in 30-45 minutes.  This translates to stops every 3 hours to take a break and recharge.  Which is not bad for most drivers, who should take breaks every couple of hours of driving.  

These Level 3 Chargers run at 480 Volts and in Pennsylvania are not everywhere common.  For example, on the Pennsylvania Turnpike, there are exactly 5 stops with ESVE stations: Oakmont Plum, New Stanton, Bowmansville, Peter J. Camiel, and King of Prussia Service Plaza.  From Harrisburg travelling west, the first and only charging station is 170 miles away.  Travelling east on the Turnpike, the distance between Oakmont and the next charging station (Bowmansdale) is 240 miles, beyond the range of most EVs.  As one might expect, the bulk of the Level 3 stations are in and near Pittsburgh and Philadelphia. Outside of these urban areas, you need to know and memorize the locations of Level 3 stations to plan a trip. Fortunately, or unfortunately, you don’t need to memorize a long list.

Driving habits also can and should play into the decision to own an EV.  If you are primarily using a car to run errands and get around locally, an EV can definitely fit.  We have the luxury of owning 2 cars – one for local driving (the Leaf) and one for trips (the Prius).  We also have the luxury of a garage and owning our own house.  So we have installed a Level 2 charger in our garage, for around $1,200 including wiring.  Currently, we are getting about 7-9 days between charges.  When the battery gets low, we just plug it in overnight.  There are incentives that Pennsylvania provides to put in publicly accessible Level 2 and 3 charging stations, which could include apartments and stores.  More places are needed.

Leaf under the Hood – The motor is under the big black box.

Let’s return to the economics of the electric car.  On the negative side is the range and the higher initial cost.  The base model Nissan Leaf Plus, with the 226 mile range, has an MSRP of $35,550.  A base model Nissan Sentra, somewhat comparable, has an MSRP of $17,990.  However, the MSRP is not the only number.  Taking the available Federal Credits and Pennsylvania Rebate brings the MSRP down to $26,550.  Secondly, EVs have a “fuel” economy about twice that of gas-powered vehicles.  To drive 100 miles in a Leaf, you would use about 27.4 kWh, which at $0.1275 per kWh (Pennsylvania’s average), would put you out $3.49.  The same Sentra, which gets a combined 30 mpg, would use 3.33 gallons of gas.  At the current $2.70 per gallon, you would be spending $9.00.  For a driver who puts 15,000 miles on a car a year, the savings in fuel would be $825 a year. Over 5 years, it would add up to over $4,000, to the advantage of the Leaf owner.  So our $17,000 original differential between Leaf and Sentra is now more realistically $4,000.  On top of that, you have a much simpler mechanical system, with no exhaust or catalytic converter, no fuel injectors, no radiator, no oil changes, etc.  Kelly Blue Book puts the Leaf at around $250 less in maintenance over the first 5 years.

When we discuss a car in the terms of economics, we are usually buying transportation.  We are not brand loyal, having owned a Toyota, Dodge, Plymouth, Mazda, Volvo, Subaru, Ford, and Buick. This usually means we are price sensitive, and so it was with this purchase.  I had to wipe the drool off the Tesla Model S, or the Jaguar I-Pace.  So although we were willing to pay more to reduce our carbon footprint, we were not willing to simply surrender bushels of money to make a point.

Ultimately, once we were all in, we see our responsibilities differently.  Having now purchased an EV, we feel that our civic responsibility is to act as a resource and answer questions for others that might be curious.  You might say we have become proselytizers for EVs.

The Bottom Line

If you are considering the next car, do not dismiss an EV as a choice.  Ask yourself first, “Are you using this primarily for around town and do you have a second alternative for long trips?  Do you have a place to charge an EV?” If the answers are yes, you may be a candidate for an EV.  If you aren’t ready yet, consider paying attention to the market and emerging models.  The direction is going to be toward electric and away from gasoline as we enter the 3rd decade of this century.

Ford Versus Ferrari? No, Nissan versus Chevrolet.

In Pennsylvania, as in much of the country, the choice of electric cars under $50,000 is sorely limited. Both the Hyundai Kona EV and the Kia Niro EV, which have more than 200 mile range and are both under $40,000, are currently the darlings of the electric car press. Neither are sold in Pennsylvania.  This leaves the Nissan Leaf Plus, the Chevy Bolt, and the Tesla Model 3 as the three contenders sold here at this time.

The Tesla Model 3 comes in 3 levels, with the Standard Plus coming in for a 250 mile range, making it the level that is comparable to the Nissan and Chevy. For the Model 3 specifically, the MSRP is $39,490.  Destination charges and fees are an additional $1,200 and the current Federal Tax Credit is $1,875 through the end of 2019.  There is also a $1,500 Pennsylvania rebate for the purchase of an electric car. All Teslas come with driver assistance features including emergency braking, collision warning, and blind-spot monitoring.  As these were important for us, I am including these features in the comparisons.

The sale price for the Tesla comes to $37,315, not including taxes or other registration fees. Of the three potential electrics, the Tesla was the most expensive.  Much has been written about the Model 3 and we did not test drive it.  We did not consider the Tesla Model 3 primarily due to the higher net cost, and some concerns about manufacturing quality; however, for the reader interested in the Tesla, do not let our judgments cloud yours.

Linda and I had the opportunity to test drive both the Leaf Plus and the Bolt and our comments are listed below.  Although I will be talking about the Leaf throughout, it should be understood that it is the Leaf Plus with the bigger battery and range that is our focus.

Nissan LeafChevy Bolt
Trim LevelSV Plus w/ Technology PackageLT with Driver Confidence Packages I and II
Motor214 hp front wheel drive200 hp front-wheel drive
Battery (kWh)6260
Range (miles)215238
Mpg-e104 combined119 combined
Curb Weight (lbs)3,7803,563
Wheelbase (in)106.3102.4
DC Charge Cable IncludedYes$750 option

There were a number of criteria important to our decision in choosing a vehicle.  Side-by-side, here are our judgments.

Safety Features. We wanted both vehicles to have advanced safety features such as blind spot monitoring and collision avoidance.

Included in the Technology package (which could not be added on to the base S model)-Automatic Emergency Braking with Pedestrian Detection , Intelligent Forward Collision Warning , Blind Spot Warning , Rear Cross Traffic Alert , Intelligent Lane Intervention 

Included in the Driver Confidence Packages I and II – Rear Park Assist, Rear Cross Traffic Alert, Lane Change Alert with Side Blind Zone Alert, Low Speed Forward Automatic BrakingForward Collision Alert, Lane Keep Assist with Lane Departure Warning, Following Distance Indicator, Front Pedestrian Braking, IntelliBeam automatic high beam headlamps

Conclusion: Both Leaf and Bolt have all the safety features we would want.

Instrument:  The layout of the instrument panel is a concern for us.  We need to be able to drive the car and monitor performance and controls without being distracted.  We are concerned that a 100% touch screen approach would not be safe.

Instruments were clearly marked in front of the driver, with the usual range of speed controls, audio, and phone on the steering wheel.  The 8-inch touchscreen in the dashboard to the right contains more information on performance, phone and audio settings, and climate control indicators. The climate controls are actually on a button panel below the screen, but it is intuitive.

Instruments were clearly marked in front of the driver, with the usual range of speed controls, audio, and phone on the steering wheel.  The 10.2-inch touchscreen in the dashboard to the right contains more information on performance, phone and audio settings, and climate control indicators.

Conclusion: Both the Leaf and Bolt instrument panel layouts were intuitive and easy to use without distracting from driving.

Handling and Street Performance

The Leaf handled well and compared to other compact sized cars such as the Corolla or Civic.  We did not use the special e-pedal feature to brake, which would have reduced the distance to a stop.  

The Bolt was more nimble than the Leaf and handled and cornered well, as would be expected from a smaller car.

Conclusion: The Bolt was clearly the better driving experience.  Being lighter and smaller, it handled better than the larger and heavier Leaf.

Seating Comfort

The car could clearly seat 4 adults comfortably; putting in a 5thadult might have been a bit tight.  Leg room and head room both in front or back was good, but neither of us are tall people.

Even though the Bolt was a smaller car than the Leaf, there was still adequate seating room for 4 adults.  The potential for a 5thadult was definitely not there.

Conclusion: For everyday driving, with two adults, both the Leaf and Bolt are comfortable.  Should there be a need for carrying 5 adults, the Leaf could manage and the Bolt could not.

Driver Vision

Vision from the driver’s side to the rear and to the left and right rear was generally unobstructed. Even without the additional safety features, we were able to see around us.

Vision from the driver’s side to the rear and to the left and right rear was generally unobstructed. Even without the additional safety features, we were able to see around us.

Conclusion: Independent from the driver assist technologies, both the Leaf and Bolt had mostly unobstructed 360 degree views from the driver’s side.

Cargo Space

At 23.6 square feet, the Leaf has enough room for two suitcases, or several bags of groceries, without folding down the rear seats.  The folded seats do not go flush with the trunk floor, as there are batteries underneath. This diminishes the overall rear cargo area.

At 16.9 square feet, the Bolt can barely hold two small suitcases or three bags of groceries.  As with the Leaf, the folded down seats do not go flush with the trunk floor.

Conclusion: The Leaf has enough cargo space in the trunk area to do light shopping or travelling.  The Bolt has minimal cargo space in the trunk area, reminiscent of what you get in a two-seater roadster like the Miata.

DC Fast Charger (Level 2). An essential extra to be able to charge on the road.

Included in Trim Level

$750 additional

Cost as equipped

$32,205MSRP of $41,205 less $7,500 Federal Tax Credit less $1,500 Pennsylvania State Rebate

$36,415MSRP of $39,790 less $1,875 Federal Tax Credit (expiring December 31, 2019) less $1,500 Pennsylvania State Rebate


Both the Leaf and Bolt appear to be more than adequate cars for in-town driving and short trips.  The Bolt is smaller, but more nimble.  The Leaf has more cargo room and much more usable cargo room than the Bolt.  The Leaf uses the CHAdeMO fast charging standard, while the Bolt uses the more common CCS standard.  Currently, there are more CCS fast chargers out there than CHAdeMO fast chargers; however the caveat for now is that either car is more or less limited to short trips and in-town driving.  Unfortunately, this seems like the old VHS/Beta wars over standards, which hopefully gets resolved before most everyone is driving electrics. For now, place your bets.  

Before rebates and credits, the Bolt is $1,500 cheaper than the Leaf Plus with a longer range.  Because the Chevy Volt took most of the Federal credits sales for Chevy, the Bolt only has a $1,875 tax credit attached to it.  Sales of the Leaf have been slow since the beginning, I believe primarily due to the limited range of early Leaf models.  For now, the Leaf has a $7,500 Federal Credit, and when added to the Pennsylvania State Rebate, offers you a $9,000 discount on the vehicle.  On this basis alone, the Leaf Plus is the better value.


What ultimately decided the choice of vehicle for us was the cargo space, with the Leaf winning hands down. As either car would have to be our all-purpose shopping and transport vehicle, cargo space was important.  The configuration of the Leaf cargo space was also more friendly to activities such as grocery shopping.

If you generally have a small family (1 or 2 adults) and are planning to pair your driving with another vehicle for longer trips, go with Leaf Plus.  The 216 mile range takes it to the same class of electric car as other contenders. For now, you have to go to another state or spend much more (Tesla Model 3 or Model S) to get above 240 miles in range.

If you plan to make this your only car and plan to use it for trips and you can live with the smaller cargo space, go with the Bolt.  The charging standard (CCS) is more common and the range is greater.  The cost differential between the Leaf or Bolt is small enough to not be the only criteria

Natural Gaslighting

Recently, I received a cheery e-mail from UGI, who provides our natural gas.  They were touting their “Environmental Sustainability Initiatives.” It said, in part: “Natural Gas is much cleaner than alternatives like coal, oil and electric (site to source)…switching households to these alternative fuels (sic) to these alternative fuels to natural gas has reduced greenhouse gas emissions equivalent to removing 103,000 cars from the road, resulting in nearly $108 million in annual energy cost savings.” (My emphasis) (Their emphasis)

Now, I expect to be outright lied to by the current Administration in Washington on matters related to the environment.   I expect to hear about jobs and cost savings from the fossil fuel industry. I did not expect UGI to blow smoke up my behind regarding the purported environmental virtues of natural gas.

An e-mail from UGI

Let’s deconstruct UGI’s statements.  On the surface, once natural gas gets into your home, it is half as bad as coal and oil with regard to CO2 emissions.  CO2 is one of the greenhouse gases that is heating up our planet at an unprecedented rate.  Cutting them drastically is required for our children and grandchildren to have something like a normal existence on this Earth.  If you are burning coal, then your CO2 production will be approximately 205-228 pounds for each million BTU, depending on the type of coal.  Bituminous burns dirtier than anthracite.  If you are burning home heating oil, then you are producing 161 pounds of CO2 for the same energy.  For natural gas, it would be 117 pounds of CO2.

Is this environmentally sustainable?  The short answer is no.  The most optimistic scenarios state that we need to be carbon neutral (no net addition of CO2 into the atmosphere) by no later than 2050 to avoid heating the planet more than 2.7 degrees Fahrenheit above what it is today.  Bad things will happen even if we achieve this goal, but much worse will occur if we don’t.  

Scientifically Accurate Rendering of Earth on January 1, 2100.

To avoid the worst, we have to get to carbon neutral and quickly.  And while natural gas may emit half the CO2 of other fossil fuels, it is not a long-term solution and will not lead to environmental sustainability.  It is like Stalin and Hitler in a room talking to Roosevelt, and, Stalin saying, “Hey, FDR, I’m only half as bad as Hitler.”

Claim 1

How is natural gas cleaner than “electric (site to source)”?  Electric, site to source, means taking into account the fact that electricity is usually generated at a power plant, then transmitted some distance to the home.  In transmission, some electricity is lost, so there is a factor worked in.  Fair enough.  UGI, I believe, is also assuming electric generation is averaged from a combination of coal, natural gas, nuclear, and other (including renewables) some of which are CO2 emitters.  When you figure in the creation of electricity from dirty sources and factor in the loss in transmission, it is probably true that natural gas burned in the home is cleaner than site to source electricity.

However, the statement leaves you with the impression that natural gas is cleaner (in CO2 emissions) than electricity, which is false if that electricity is produced from nuclear or renewables like solar or wind.  Under some scenarios, natural gas is cleaner than electricity, but the statement completely avoids the option of renewables, which I believe was intentional.  Their claim also sweeps under the carpet the issue of site pollution from natural gas production at the well (see below).  We have an apples to oranges comparison here.

Claim 2

Let’s look at the second claim of reducing emissions equivalent to removing 103,000 cars from the road over 10 years.  I’m don’t know what UGI means by that statement.  There is no citation.  Secondly, this claim only makes sense in relation to something.  I could claim reading this blog is equivalent to extending your life by 2 months.  (No, it only seems like the time spent reading this was like 2 months.)

Let’s humor our good folks at UGI.  What is the emissions equivalent of 103,000 cars from the road over 10 years?   We can do a back of the napkin analysis.  First, let’s assume its 10,300 cars a year for 10 years.  The average US car is driven 13,476 miles per year (FWHA’s numbers).  There is no place to find the current gas mileage for the entire US fleet, just new cars (which is 24.7 mpg in 2016).  In 2018, cars and light vehicles consumed 142.86 gallons of gasoline (US Energy Department).  In the US, we drove 2,220,801 million miles in 2017, per the USDOT.  This computes to an average of 15.5 mpg.  To drive 13,476 miles at 15.5 mpg, you would need 869 gallons of gas.  Each gallon produces 19.60 pounds of CO2, so in a year each car would produce 17,032 pounds of CO2, or 8.52 tons (hereon in when we say ton, we mean the 2,000 pound short ton).  Our 10,300 cars a year would end up producing 87,756 tons of CO2 a year.  Sounds impressive…

…Until you realize that Pennsylvania’s total CO2 emissions are 239.1 million tons a year (US Energy Dept.), and that there are 4.68 million cars registered in PA (in 2015).  Against some unknown standard, UGI has reduced Pennsylvania’s CO2 emissions by 0.024 percent and reduced the number of CO2 emitting cars by 0.22%.  103,000 sounds like a large number, until you figure out what it means in the big picture. 

But Wait! There’s More.

To now, we have limited our discussion to source consumption of natural gas (although UGI was more than happy to compare source natural gas to site electricity).  If we squint, we can try to believe that natural gas is only half as bad as other fossil fuels and therefore might be a bridging fuel to the carbon-neutral future. What happens when we look at the site production numbers.  

For years, we have known that methane is a greenhouse gas.  The good news is that methane stays in the atmosphere for only a few decades, as opposed to CO2 which can remain for centuries.  The bad news is that methane is a far more potent greenhouse gas than CO2, something like 34 times a potent.

Furthermore, the calculation of 34 times as potent is comparing methane and CO2 over a 100 year span.  Methane’s greatest impact is in the first 20 years. For the shorter 20-year span when methane is active, the global warming potential (GWP) is 84-87 times that of CO2 (EPA).

So what does this have to do with natural gas? Natural gas is mostly methane.  All wells leak a bit and what they are leaking is methane-dominated natural gas.  Leaking from the well head is not a given and well designed and constructed wells leak very little.  The current EPA estimate is that wells leak about 1.4%.  Unfortunately, a new analysis suggests that the current methane leak rate is closer to 2.3 percent, as reported in the Journal Science

Without running you through another calculation, I think you can see that any small leakage that is magnified 84 times will have a large impact over the next 20 years, totally overwhelming any short-term advantage of natural gas over other fossil fuels.  Clearly others are seeing that methane leakage from natural gas is a problem and in Pennsylvania our Governor Wolf rolled out methane restrictions in 2016.  Unfortunately, those restrictions are limited to new wells. Existing wells continue to remain unregulated for methane.  Ultimately, natural gas is bad for the atmosphere in the short term.  Under current ground rules and regulation, there is no benefit for using natural gas as a bridging fuel. None.

It’s Complicated

Last year, we finally took the plunge and installed solar panels on our house which will generate clean and renewable energy for 30 years.  Rated at 7.5kw, we are removing 3.2 tons of CO2 from the atmosphere each year.  Good for us.  However, in 2011 we replaced our oil furnace with a high energy natural gas boiler, which produces both our heat and hot water.  Last year we added a gas range for cooking.  On average we have used 97.84 mcf (thousand cubic feet) of natural gas each year.  Yes, we reduced our carbon footprint by changing from heating oil to natural gas, but we did not eliminate it.  Not considering the site sources of methane emission and focusing only on the source CO2, we are putting an average of 5.7 tons into the atmosphere. Not good for us.

Our Natural Gas Boiler

The hot water heating system we have is efficient and effective and keeps our home toasty through the winter.  The hot water is essentially on demand as we have no water heater.  Our 8 year old boiler is working fine and only needs an annual tune-up.  I personally like cooking with natural gas. I think I am a much better cook for it.  Today, we have limited options for switching to an all-electric boiler.  Most of the market for hydronic baseboard heat (the fancy technical term) is premised on natural gas-powered boilers. There is a small market for electric boilers that do the same, so it will come down to a matter of will and finances.

Our (beloved) Gas Range

With regard to our gas range, the logical side of my brain says that cooking is the same – gas versus electric, and electric can be carbon free. The emotional side of my brain says gas is superior, especially on the burners, especially in the ability to micro-control the heat immediately.  Ultimately, I feel we will surrender to modernity and the planet and switch back to an electric range.  It may take some time as the range is less than a year old.  Rather than taking the step of changing our boiler, we are looking into adding insulation to the attic.  Using less natural gas is one good way to reduce our footprint. 

In the meantime, what we can and should do is to pressure our representatives and our gas companies to fully embrace the monitoring of gas wells and pipelines for leakage and to enforce strict regulations on the production of natural gas.  As I speak, the Pennsylvania Environmental Board is vetting proposed rules restricting methane emissions from existing wells. Even fast tracked (it is not) and with the embrace of the General Assembly (I have my doubts), it will take at least another year for the regulations to take effect.

Of course, it would help if UGI would make some attempt to be truthful regarding the impacts of natural gas consumption on the atmosphere and the warming planet.  At least they could stop gaslighting us.