More Questions on LTA’s Wrongful Tesla Decision

Mystery Deepens in Singapore’s War on the Tesla All-Electric Vehicle

By Michael Heng@MIKOspace

More questions emerged even as the Singapore Land Transport Authority (LTA) attempted to explain further its decision to impose a S$15,000 carbon tax surcharge on a Tesla pure electric vehicle (EV) which emits no CO2 from its non-existent exhaust. 

The LTA claimed to have relied on the United Nations Economic Commission for Europe (UNECE) R101 standards. UNECE told a Singapore news agency that Singapore is not one of the contracting parties to the 1958 Agreement which ratifies the harmonisation of vehicle regulations.  In any case, the UNECE R101 standards do not have any provisions to measure non-existent carbon emission of all-electric vehicle like the Tesla Model S.   

The news agency quoted Mr Jean Rodriguez the UNECE Information Chief that the “LTA appears to have applied UNECE R101 correctly when assessing the carbon emission of a used Tesla Model S recently”.  Yet, the only R101 protocol pertaining to pure electric vehicles only specifies the way to measure the energy consumption of the vehicle or “tank-to-wheel”.  The alleged statement by Chief Rodrigeuz would thus “appear” disingenuous since it is inconsistent with the capability of his R101 Standards.

At best, the LTA could only apply R101 Annex No: 7 which describes the “Method of measuring the electric energy consumption of (pure battery-operated electric) vehicles”. 

It is however unknown whether VICOM, the Singapore vehicle inspection company, has been assessed to have the necessary equipment and has actually been certified by UNECE to conduct the R101 tests so as to make the relevant valid computations.

Chief Rodrigeuz also further pointed out that Singapore LTA appears to be the only national regulator to have included power grid emission into the evaluation of electric vehicles’ (EVs) carbon footprint.  What this means is that the LTA had acted arbitrarily when factoring in the power grid emission without scientific support from any international authoritative test or quality standards.

From the determination of electric energy consumption to the attribution of carbon emissions by the Tesla EV would require the LTA to adopt a series of assumptions not hitherto supported by any international protocol or quality standards. The results are understandably dubious and questionable.  For example, the LTA claimed to have calculated that the electric energy consumption of the imported used Tesla car to be 444Wh/km, and translated that to the equivalent of 222g/km of CO2 after factoring a grid emission factor of 0.5 CO2/Wh.

Actually, the official Singapore’s Grid Emission Factor is about 0.43g CO2/Wh not 0.5 g.  And the United States Environmental Protection Agency (EPA) had recommended electric energy consumption of almost half of 444Wh/km for city driving.

Now we know a little more how LTA determined and subjected the Tesla EV to the resultant C3 S$15,000 carbon tax surcharge band under its Singapore's Carbon Emission-based Vehicle (CEV) Scheme, thus placing the Tesla all-Electric Vehicle with non-EV car models like the Mazda 8, Land Rover Freelander, Lexus RX270 and Maserati Ghibli. 

In other words, the LTA has deemed the Tesla Model S pure electric vehicle to be as polluting as the other fossil-fuel vehicle addicts.

Seriously, LTA? This would of course make Singapore a laughing stock in the world of sustainable energy and sustainable electric mobility. 

This incident with the Tesla EV severely tested the capability of our fossil-fuel based authorities and the limits of fossil-fuel vehicle regulations.  We are found seriously wanting and in need of fundamental change in our mindsets, policies and practices.

In the final analysis, the LTA has actually made a decision error in the Tesla EV case.  It failed to apply and follow its own definition and policy.  The LTA has already defined carbon emissions explicitly in its CEV Scheme as “the release of carbon dioxide from the use of a vehicle” and it “measures … the weight of carbon dioxide (CO2) released for every kilometre that the vehicle is driven”.   

It is thus disingenuous to compound its error by confusing sustainability-minded motorists with references to irrelevant and non-universal variables and factors.   Singapore’s reputation as a leader and active warrior against climate change by making fossil fuel history has been damaged by this incident.  Let’s restore our reputation for political leadership and hard-headed decision-making.