The EPA is still looking for the exhaust pipe...
There is precedent for this in other countries as well as "worldwide" which seems to be the type of patriotism most bureaucrats have, and a lot of them find exhaust pipes on electric vehicles. I'm a staunch supporter of solar photovoltaic power, and I've bought what I could afford of my typical car use for our roof already (although I'll need to keep adding to it over the decades to reach parity with my actual car use, but I will). But, many paper pushers use outdated formulas for how much tail pipe is on a car by counting up way too much outdated coal, oil, natural gas pollution, and even consider dams that create electricity to be a type of "pollution", and assign a number to your car that far exceeds the amount of pollution put out by an electric vehicle that is charged by solar panels.
Let's look at it this way: the new energy market has added solar panels in order to supply new energy users, like electric cars, and to supplant old energy users that are dirty. Sure, we aren't going fast enough supplanting old dirty users, but we are supplanting them, and as long as we keep up with new users (electric vehicles) and keep speeding up the replacement of dirty energy use, we could therefore consider all electric vehicles to be solar powered, to the extent that batteries exist to offset nighttime charging. Right now, that means we probably still use dirty power to an actual extent. What's the baseline at night for night charging? A quick look at CAISO
http://content.caiso.com/green/renewrpt/DailyRenewablesWatch.pdf shows at 11PM - 5AM is 10GW Hydro (5GW) + Nuclear (2.5GW) + "Renewables" (2.5GW) which is essentially almost all clean (except for some biomass and some of my other concerns about various types of energy), but about half is dirty (imports (mostly dirty but not all, some is cleaner) and "thermal" which is just fossil fuels (which is a stupid government name, considering so much of the other categories have thermal components)). So, at night, it's 50% clean. But, we're fixing that. But you could say that during the early part of the lifetime of a P100 Tesla that its tailpipe includes an increase of pollution when the sun is not shining,
if and only if Tesla doesn't start producing PowerWall 2 and PowerPack for California in sufficient quantity for offsetting this 100%. That's one of the reasons I'm saying PowerWall 2 is vaporware and that is a hugely bad thing. If Elon keeps running around thinking it's ok to
say he's going to do stationary batteries without actually delivering, then he's almost begging for an institution like a bloated government EPA to continue to exist. It's quite sad, actually; instead, Elon could be installing PowerWall 2's everywhere in California, and telling the EPA to shove it. That's what I would have done if I were him, but then, I probably would have ticked off some government worker or other and failed, so there's that. But I still consider it a huge missed opportunity for Tesla from absolutely every angle.
Do Australians buy Tesla vehicles? So we have the EPA come along and say "but wait, Elon! Your 100D causes increased emissions! Solar power only runs in the day time, and most of the USA doesn't even have solar power yet.", thus giving that EPA person a true reason to feel like they ought to exist. If Elon wasn't busy trying to cream-skim Australia and jump-start Hawaiian islands, he could have put 50% of his stationary batteries here in California homes, and even if it is net-net the same amount of solar power advantage worldwide and a bit less of a market advantage for Tesla, it would take away the reason for the EPA person here in USA, at least as far as California is concerned, to say that the EV is some amount dirty when driven compared to an ICE. Yes, it would still be dirty in other states, yes its manufacturing would still be dirty, yes we would need a little oversight somehow or other, and yes, verification is good, but it would give the EPA less reason to question the paperwork on the Tesla cars, less reason to hold it up, less reason for there to be a law that says Elon can't sell his cars yet, etc.. Even if it meant a little bit of better battery recycling into PowerWall 1's, that would have helped. I find that a missed opportunity, too: Elon says it's bad to upgrade cars to get a better battery, but I say it's good: let the car owner upgrade their Tesla battery in-house, and then when Tesla gets the old pack, sell it as PowerWall 1 or PowerWall 1.6 (essentially PW 2 but with old style battery cells), and Tesla could have been creating a new energy market sooner, with more buy-in from the public, less EPA crap, early starts into the home sales and installation models that they need to fix in Solar City anyway, and ... well, there's the rub, they'd sell a few less vehicles, but I think it would have balanced better and had a better outcome. Obviously, they disagreed with this path, or didn't think of it. Meanwhile they advertise vaporware, lumber and stumble around with legacy crap from Solar City with no real vision, and have bad customer service for their car lineup and not much new to be excited about, except that P100D, which apparently, they're already shipping. Of course, if I had that much money to buy a P100D, I'd probably have some competitor's stationary battery already installed with enough solar panels to fully charge my cars and run my home most of the year, anyway, but I'm not a racer, and I see the need for racers to exist even if they don't go out and buy solar panels and stationary batteries (because the utility & some of their neighbors are already doing that for them). (I don't call passing trucks and a few Prius's on I-5 racing.)
Long and short of it, is EPA is going to try to get its pound of meat, and then it will be approved. It's still annoying me, because everything I've been saying for ages seems to
still get skimpy attention, but at least it's crawling forward.