From Doug: Federal Regs

I was watching TV this morning and, as I was ironing a shirt, a news item came on about the Department of Energy.  It appears that they are or intend to regulate shower heads for household use.  In 1992 Congress passed a law limiting shower heads to 2.5 gpm at 80 psi.  However, recently this was redefined to count each head in a multi-head shower as one shower if the shower was intended to be used by one person at a time under the guise that anything else was an energy waster (i.e., extra water equals extra energy).  Okay, I get it.  I understand.  But really, isn’t there some other means to prod people to engage in water conservation?  Okay, maybe you can make sense of the purpose behind the regulation, but there was no legislative action to include these multi-head showers.  Just the sudden application by some zealous, faceless government bureaucrat of a sudden perceived epiphany 19 years after the law was enacted to create a well intentioned regulation.

How does this relate to parking?  Well it is a bit circuitous, but it does relate.  Another law passed in 1992 has also been recently re-interpreted concerning “state” owned automobile fleets.  Many college campuses operate car rental services for internal use by faculty and staff.  The campus transportation departments  act much like a Hertz, National, Avis, or Alamo and rent vehicles to staff and or departments for University related business.  The employee can charge the vehicle to the department budget and go into the field to conduct research, attend a symposium, teach at another campus, etc., etc.  The systems can run more efficiently than an outsourced vendor and provide a higher level of service.

The DOE’s Alternative Fuel Transportation Program now requires that any “covered” fleet must ensure that at least 75% of the fleet’s annual purchases of light duty vehicles (basically all sedans) are capable of being fueled with an “alternative” fuel.   Special duty vehicles, like police cruisers, are exempt from the regulation.  Here are some interesting bureaucratic twists.  Alternative fuels are E-85 or better, hydrogen, CNG and total electric.  I say total because hybrids don’t count.  They burn gasoline.  I’m not sure of Chevy’s Volt because it has a gasoline motor also.  Bio diesel counts, but there are not many sedans that have bio diesel engines.  Flex Fuel labeled vehicles do count, but so far they only come in 6 cylinder engines.  I have not yet seen a Flex Fuel 4 cylinder.

The bottom line is this.  Hydrogen fueling stations are few and far between.  Ditto for CNG. It takes hours to “refuel” a fully electric vehicle and their range is severely limited.   If the vehicle stayed predominantly on campus, you probably could install a fueling station, albeit  at great cost to provide the alternative fuel, but if the sedans are being used in an environment similar to National, Hertz, Avis, etc., they may be able to reach their destination but not return.  The truly amazing thing is that even for Flex Fuel vehicles, the regulation does not require you to burn E-85.  You can burn regular gasoline.  I could now jump off on a tirade about ethanol fuel and its dubious contribution to the environmental well being of the planet, but that is a discussion for another day.

The bottom line is that you can meet the brand new regulation stemming from a 20 year old law by making sure that 75% of your fleet purchase is Flex Fueled.  Course, you have to buy 6 cylinder engines.  They don’t get quite as good gas mileage as the 4’s, but that’s okay; you comply with the regulation and presumably can let your heart float free because you are now environmentally responsible.

I am very definitely a promoter of rules that actually help the environment.  I think that polluters should be taken to task and that any reasonable action we can take to keep our environment healthy is a good thing.  But I also think that the people crafting our rules and regulations need to be regulated a bit themselves or we wind up with this sort of silliness that protects nothing and costs a lot.  Personally, I think we would be better off if the government spent this money on developing more fuel efficient vehicles and or a cleaner more efficient technology for moving people around the planet, but then, who am I?

Doug Holmes, CAPP

Doncha just love it when that famous law of unintended consequences kicks in.  JVH


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