Sunday, 6 March 2016

Electric Vehicles Punished in Singapore's War on Climate Change

Singapore Electric Vehicles Wrongly Penalised By Fossil Fuel-based Rules
Obsolete Regulations & Mindsets Obstruct Singapore’s War on Climate Change

Tesla Model S (2015)

Strange, but true.  A wholly electric vehicle (EV) with dual electric motors that emits no carbon emission has been penalized with a S$15,000 carbon tax surcharge. Singapore Land Transport Authority (LTA) has wrongly determined that the all-electric Tesla Model S vehicle “produced 222g/km of CO2, putting it within the S$15,000 surcharge band under Singapore's Carbon Emission-based Vehicle Scheme”. 

The truth is the Tesla Model S in motion produces zero carbon emission since it is solely propelled by 2 electric motors and has no additional combustion engine or fuel cell on board.  As a pure battery electric vehicle, its electric motors are the sole propulsion source; hence, there is no fuel consumption and zero CO2 exhaust emissions (see far right picture below). 

According to LTA’s own Guidelines, the Tesla Model S vehicle should actually be entitled to the S$30,000 carbon rebates like the Peugeot Ion or the BMW i3 electric hatchback. Ironically, even the BMW i8 plug-in hybrid, which actually emits CO2 on the road managed to qualify for LTA’s S$30,000 carbon rebate, while the zero emission Tesla Model S is penalized.

The LTA further clarifies that it was not the Tesla vehicle that emits CO2 but rather it is the source-generator of its electric power amounting to 444 watt-hour/km produced and charged by the Singapore Grid’s gas-operated power stations. These fossil-fuel based gas-operated power stations are contracted by the Singapore Government to supply electricity exclusively throughout the country.  No other source of electric power beyond 10MW can be legally generated without a power generation license from the Government. 

The LTA had strangely factored in the carbon emissions by the fossil-fuel based gas-operated power station when generating the electricity used for charging the Tesla vehicle, and penalized the Tesla vehicle (as well as other electric vehicle) owner for the carbon emissions produced by the fossil-fuel gas–operated power stations. 

By extending and attributing its carbon tax surcharge to the source electricity generators, the LTA departed from its own guidelines to wrongfully penalise the Tesla S Model and other all-electric vehicles.

The LTA’s own Guidelines refer to the applicable taxable carbon emissions as ”the release of carbon dioxide from the use of a vehicle”.  They further added that “the g CO2 /km is a measure that quantifies the weight of carbon dioxide (CO2) released for every kilometre that the vehicle is driven i.e. the vehicle’s fuel efficiency”.  The LTA Guidelines refer ONLY to CO2 produced by the vehicle in motion.

The LTA's Carbon Emissions-Based Vehicle Scheme (CEVS) actually EXCLUDES and does not apply to pure electric vehicles like the Peugeot Ion, BMW i3, Tesla Model S, which do not emit CO2.

Nowhere in its CEVS Guidelines or Press Release on the subject did the LTA, or the Government, ever affirm that the fossil-fuel based gas-operated power stations could or would be the incidental source for its carbon tax surcharge. 

It is more baffling and even disingenuous when the LTA explained that it was following the United Nations Economic Commission for Europe (UNECE) R101 standards.  Nowhere in any of the tests under the UNECE R101 standards did they mandate the measurement of carbon emission of an all-electric vehicle like the Tesla Model S from a remote power station source.   

Truth is the UNECE R101 standards quoted by the LTA as their decision reference DO NOT apply to pure electric vehicles like the Tesla Model S. They apply ONLY to normal fossil-fuel cars, hybrid (electric+gas/petrol) cars and electric trains. 

COP21 The Paris Agreement Forgotten?
It is barely 3 months after COP21 UN Climate Summit Conference in Paris in Decembr 2015, and where the Paris Agreement (which was also signed by Singapore) essentially defines the key criteria by which to judge sustainability efforts.  Sustainability from hereforth shall mean low or zero carbon emission. It mandates that fossil energy is excluded from all sustainability considerations. The Paris Agreement “also recognises that sustainable lifestyles and sustainable patterns of consumption and production, with developed country Parties taking the lead, play an important role in addressing climate change”. The emphasis on renewables-based sustainability is unmistakable.

The global movement to make fossil fuel history involves the promotion of all-electric vehicles that are truly sustainable.  A new mindset is needed to replace obsolete policies and practices that favour fossil-fuel vehicles.  New policies, infrastructures and practices are needed to roll out the new imperative of a sustainable electric mobility consisting of transportation powered by renewable energy.

A Singapore future reality story demonstrates how one country could enhance her energy security by reducing her fossil fuel dependency by 16%-20% with a 100% electric vehicle population.  This is achieved by a nation-wide effort to harness the  the creative energy of a resourceful people to use solar and urban wind energy to produce carbon-neutral electricity for EV charging as well as daily and commercial living.  

The Tesla Model S case is an unfortunate incident of taking many steps back from COP21 and withdrawn into comfortable policies and practices.  Obsolete regulations and mindsets will obstruct Singapore’s War on Climate Change, and make it harder to fulfill Singapore’s carbon reduction and climate change promises to the world made in Paris last December.


  1. Founder and Chief of US electric car maker Tesla Motors, Mr Elon Musk, has contacted Prime Minister Lee Hsien Loong over the case of the Tesla sedan that was taxed with a carbon surcharge in Singapore.

  2. Excellent blog post, I've shared it to Joe, PM Lee and Elon

  3. Your article is interesting, but I think you are incorrect in several aspects.

    Your key point is "The LTA Guidelines refer ONLY to CO2 produced by the vehicle in motion". I think it is reasonable for the LTA to interpret that as the CO2 released by the use of the fuel. If you burn petrol in a generator to make electricity, and use that to charge your EV, then drive that EV on the road, is that any different than burning the petrol directly in an ICE? The issue, as I see it, is not that the LTA attributes CO2 released during electricity generation to the vehicle, the problem is that LTA doesn't do the same for other fuels (petrol, etc). Anyway, this point is debatable. I think the LTA is trying to do the right thing, because we all know EVs are not ZERO emissions, they are ZERO TAILPIPE emissions. The LTA is just applying it badly and unfairly.

    You are correct in stating that UNECE R101 is not intended to include power generation. But, I don't think that is what LTA is saying. What LTA is doing is using UNECE R101 to measure power usage (wh/km), and then take that figure to convert to CO2 released based on power generation. They are trying to account for the non-tailpipe emissions.

    But the bigger issue is your statement that "UNECE R101 standards quoted by the LTA as their decision reference DO NOT apply to pure electric vehicles like the Tesla Model S", and "They apply ONLY to normal fossil-fuel cars, hybrid (electric+gas/petrol) cars and electric trains". That is simply not correct.

    For the bored, you can read it here
    but the first page synopis is
    "Uniform provisions concerning the approval of passenger cars powered by an internal combustion engine only, or powered by a hybrid electric power train with regard to the
    measurement of the emission of carbon dioxide and fuel consumption and/or the measurement of electric energy consumption and electric range, and of categories M1 and N1 vehicles powered by an electric power train only with regard to the measurement of electric energy consumption and electric range".

    Annex 7 details the test procedure for an EV in great detail.

    But, the biggest issue of all is the figure of 444wh/km. That is the elephant in the room. The UNECE R101 test is an incredibly rigid and repeatable test. Conducted 10 times, in 10 different places, it should yield similar results. When this very same test was conducted on the very same model of car, in other places, a figure of 181Wh/km was the result and that is the official figure published by Tesla. So how did Singapore come up with a result 2.45 times the rest of the world? Either every other test authority (including Europe and Australia) is wrong, or Singapore messed up their test. I leave it as an exercise to the reader to determine which.

  4. The resource that you mentioned here is something that I have been looking from quite a time. And finally it ended with such a nice blog post. Don’t have words to thank you.
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