May 20, 2023

Bill and Martin testified on the ridiculous Colorado Clean Car Rule to the Air Pollution Control Division of the Colorado Department of Public Health & Environment. What this rule would do is follow California’s insanity of basically requiring all cars sold to be electric by 2035 or so. That is obviously impossible and useless as well. 

They scheduled us back to back, so Martin just trimmed the 2 hour long presentation down to just the one clip. Martin didn’t get the name of the slide presenter, who was Garrison Kaufman so he had to reference the slide instead. The home page of the rule is at and they put the actual recording at None of the viewers work, you have to download it.

Here’s our rough scripts, we improvised a bit.


I'm Martin Sandberg, MSEE, and a member of the IEEE power society. I’ve now lived in Colorado for over 20 years. I am now retired and have built a house a bit north of Lyons, just west of the new Chimney Hollow Reservoir. On a clear day we can see almost to Kansas to the east. To the south we can see the skyskrapers in LoDo and Pikes Peak as well, so we really do value clear air! We're not exactly on the beaten path, being 6 miles past the end of the pavement. That means the Tesla Model 3 can't get to the house, since the warranty doesn’t cover damage that occurs on unimproved roads.

Let’s take a look at operating an EV. First, the electricity to charge one, here in Colorado, mostly comes from coal and natural gas powered plants. They’re about 50% efficient, with a few combined cycle plants achieving 60% efficiency. Then you have to transmit the power thru the grid, then the local distribution system has losses, the battery charger isn’t perfect and neither are batteries or electric motors. When you crunch all those numbers you’re really not much different than an ICE vehicle. With electricity prices rising, due to the push toward more expensive solar and wind energy, they're not dramatically cheaper to operate either. As Quinn Antus noted, green energy requires at least TWICE the people that highly productive oil and gas does.

Another problem for us in Colorado is the dramatic decrease in range EVs experience in cold weather. Consumer Reports found that they lose about 40% to 50% of their range at our typical winter temperatures.

As I was watching the introductory slides, The ZEV percentage of sales requirements one brought to mind a phrase from Atlas Shrugged  - "You'll do something Mr. Reardon."

Considering how much EVs cost, and how much driving we do in Colorado, it certainly isn't worth forcing everyone into one.

I would urge the APCD to not follow California's insanity!


And Bill:

My name is William Hembree. I’m a retired software engineer now living in the Front Range in rural Larimer County and I love living here. I’m also fortunate enough to afford a new vehicle every 3 years. I have to drive over 20 miles each way just to go shopping and Denver is an hour and a half’s drive for me. So I’m obviously concerned about what new vehicles will be available not just today but for decades into the future.

I am here today to speak in opposition to the so-called Colorado Clean Cars Rule. 

This is clearly central planning on the old Soviet model, which was an abject failure compared to America’s free market economy. In the US, government supposedly exists to facilitate the lifestyle choices of the public, not to direct and constrain the options of peaceful citizens.

But setting aside my philosophical objections, this proposed rule for the entire state is poorly justified. As a software guy, I’m used to seeing business plans which provide substantive and fairly detailed justifications for proposed new systems.

I have seen none of this for the proposed rules, just what I can only describe as handwaving, coupled with fantasy benefits claims from the usual suspect NGOs.

Since I generally prefer to offer solutions to simply complaining, I have two suggestions to reduce Denver-area pollution. 

First, since it is generally agreed that forest fires in other states are a significant source of Denver’s frequent non-attainment (and I’m looking out my window at some of that smoke right now), sue those states to compel them to stop exporting their forest fire pollution to Colorado.

Second, given that the principle source of in-state VOC’s, which are ozone precursors, is trees, cut down the worst species at least in the Denver area.

Either of those proposals is better than forcing Coloradans, particularly those of us who live outside the Denver metro area, to adopt onerous and wildly expensive but poorly-justified “solutions”

I close with the famous George Santayana quote “Fanaticism consists in redoubling your efforts when you have forgotten your aim.”

Thank you.

Now let’s get to the details of why electric cars aren’t going to help much.

Let's give the electric car a best case scenario by starting from the most efficient power plants. These are the combined cycle plants, with the GE HA turbine achieving 63.08% efficiency Now, combine that with the typical power plant bus bar to wall socket efficiency of about 93%  and you’re down to 58% efficiency.

We’re not done yet. Owners are reporting that charger and battery are about 80% efficient So, we’re now down to about 46% efficiency.

Finally from battery to wheels is only about 85% efficient (which is why the battery has to be cooled during BOTH discharge and charge), so we end up with about 39% efficiency from power plant to wheels.

Many gasoline engines are already better than this and Mazda’s Skyactive-X will beat this by a lot.