True Decommissioning: Removing Internal Combustion Engine Light-Duty Vehicles Permanently, Quickly, and Equitably

<p>In this paper, we define True Decommissioning as the removal of internal combustion engine light-duty vehicles from the road permanently, quickly, and equitably. We discuss each interlinked component of True Decommissioning. We then outline the next steps for implementation, including engaging stakeholders, evaluating economic costs and benefits, and understanding policies and programs. Finally, we present a table of unanswered research questions in this area, including those our research group is working on. We welcome discussions on how we can achieve True Decommissioning and work together to facilitate an equitable transition to clean light-duty vehicle mobility for all.</p>

section_content: Light-duty Vehicles Permanently, Quickly, and Equitably

In this paper, we introduce True Decommissioning, which we define as removing internal combustion engine (ICE) light-duty vehicles (LDVs) from the road permanently, quickly, and, equitably. Significant advancements in zero-emissions light-duty vehicles (ZE LDVs), including battery electric vehicles and plug-in electric vehicles, have made it possible to replace ICE LDVs with cleaner alternatives, opening the door to implementing True Decommissioning. In the United States, the transportation sector is mainly focused on encouraging adoption of ZE LDVs as well as banning sales of new ICE LDVs (e. g. Executive Order N-79-20 in California) and not explicitly focused on the removal of the 270 million LDVs operating on US roads today (US Bureau of Transportation Statistics, 2019). Although some programs exist that address removal, they have not succeeded in rapid vehicle removal at scale and benefits offered as part of the programs are not equitably distributed among the population. We must remove ICE LDVs from the road with careful consideration of the stakeholders who will be affected to ensure the transition to clean LDV mobility is done equitably. 

Our True Decommissioning focus is on LDVs in the United States. This category includes passenger vehicles, small SUVs, and pick-up trucks. LDVs are important, if not critical, for employment and participation in society. They also constitute 60% of all US transportation-related greenhouse gas emissions and emit many harmful air pollutants (US Environmental Protection Agency, 2020). The consequences of climate change and air pollution-related health issues are felt by the entire population, but not equally so. We are particularly concerned about the disproportionate burdens from these consequences that people of color, low income, and other underrepresented and underserved communities experience (Robinson and Shine, 2018). In this paper, we will discuss pros and cons and how they might influence strategies for True Decommissioning implementation. For this discussion, we set our geographic boundary conditions as the US new and used LDV markets, with the acknowledgement that any action taken in the US will have implications on the global LDV markets. In this context, we will discuss US local, state, and federal policies. 

Designing equitable policies, programs, and incentives for True Decommissioning is not a straightforward optimization problem. Solving this complex problem involves multiple stakeholders, their many interactions, and possibly contradictory or misaligned objectives. We have identified several components of the multi-objective optimization and address them in this paper. For example, if the goal of True Decommissioning is to reduce emissions, a blanket mandate to remove all ICE LDVs might be considered. However, if multiple stakeholders and their needs are not taken into account, a simple mandate could lead to unintended negative consequences for communities and society as a whole. 

The subsequent sections discuss the following topics: 1) Three interlinked components we use to define True Decommissioning: permanently, quickly, and equitably. 

2) Next steps to implement True Decommissioning: engaging stakeholders, evaluating economic costs and benefits, and understanding current and future policies 3) Research questions needed to fully understand how to achieve True Decommissioning, including the questions our research group is currently working to answer
section_name: True Decommissioning: Removing Internal Combustion Engine

section_content: Permanently Permanently removing ICE LDVs from the road in a way that does not penalize stakeholders who depend on them is fundamental to True Decommissioning. 

Vehicle retirement in the transportation industry refers to the permanent removal of vehicles from the road at the end of its useful life. In the US, the length of a vehicle's useful life has increased due to factors including higher prices for new and used vehicles, improved vehicle quality, and particularly in the COVID-19 pandemic, decreased vehicle miles travelled (Colias, 2021; IHS Markit, 2021). ICE LDVs in an aging fleet continue to emit greenhouse gas (GHG) emissions, such as carbon dioxide (CO 2 ), and transportation-related air pollutants (TRAPs), such as nitrogen oxides and particulate matter, for longer than originally anticipated. IHS Markit (2021) reported the average age of LDVs in operation on US roads is 12. 1 years in 2021 -a 15% increase in the last decade -and is expected to continue to grow. One study that analyzed US vehicle data found that the useful life of an ICE LDV can reach up to 30 years (Keith et al., 2019). Removing ICE LDVs may also introduce unintended negative consequences to the US used LDV market and dependent stakeholders. The supply of used ICE LDVs will be drastically reduced if vehicles are permanently removed instead of extending the useful life. The resulting decreased availability may cause hardships to the communities that rely on used markets. Stakeholders in supporting industries will also be adversely affected by the disruption to the used car markets, including mechanics, dealerships, and car manufacturers. Any strategy that aims to permanently remove ICE LDVs from US roads must consider the stakeholders and markets that depend on these vehicles in conjunction with the emissions reduction potential.
section_name: Interlinked Components of True Decommissioning

section_content: For True Decommissioning to be effective, we must couple the permanent removal of ICE LDVs with a quicker than market rate removal. 2018). ICE LDVs also emit TRAPs that directly cause a significant number of deaths in the US (Thakrar et al., 2020) and other negative health effects. These effects include cardiovascular disease and non-allergy respiratory disease (Kryzanwski, 2005). 

The economics of removing ICE LDVs that still have useful life pose a significant challenge to increasing removal rates. In a thriving used car market, there is little incentive to decommission a vehicle that retains some economic value. Car owners in low to middle income communities may not have the financial means to buy another car without selling their old car in the used market., 2016). Car owners can trade in their end-of-life ICE LDV and receive a financial incentive. The amount of the incentive varies based on the program and is always much smaller than the cost of a replacement LDV. These programs offer benefits to a limited population and do not include incentives for stakeholders in supporting industries, such as mechanics and dealerships. After examining the program results, studies have shown the emissions savings from vehicle retirement programs are not as positive as originally anticipated (Dill, 2004; Lenski et al., 2010). To achieve True Decommissioning, we believe government programs must be carefully redesigned with a better understanding of the economics of rapid ICE LDV removal and the stakeholders who are intended to benefit from these programs. And, if we as a society decide to spend the money required to implement these programs, we must ensure the allocation is done in an equitable fashion.
section_name: Quickly

section_content: When it comes to mobility choices, policies, and emissions impacts, inequity is present almost everywhere. In order to achieve the goals of True Decommissioning in an equitable way, we must elevate equity to be front and center. This elevation must be done throughout the entire research and implementation process, not left to the end as an afterthought. 

We have used the concept of equity throughout the paper thus far. We believe focusing on equity rather than equality is important because burdens weigh on individuals differently and barriers to accessing benefits vary. Factors such as identity, life experiences, and societal pressures can dictate the level of agency one has to improve their life. An equal distribution of resources does not give everyone the same opportunities. Equity is an important motivator for our work and we want to ensure True Decommissioning does not trade one burden for another. 

We have observed that there is no standard definition for equity in this field. Existing definitions often consider burdens and benefits, leaving agency out of the discussion. We define an equitable state for an individual as the balance between the burdens they can handle, the benefits they need for their wellbeing, and the agency to have control over their own life -all of which may differ from person to person based on their life situation and experiences. Figure 2 depicts the interlaced nature of the components needed to achieve equity. Inequities persist in the transition to clean mobility. For example, we have heard stories in interviews where individuals in low income communities carry higher burdens as a result of owning older, more polluting LDVs that are necessary for their livelihood. They cannot access financial incentives and benefits to help purchase a ZE LDV or newer ICE LDV. Furthermore, these individuals often do not have a good credit score and cannot obtain a loan with reasonable interest rates to afford another option, thus taking away agency. 

To better understand equity in True Decommissioning, we discuss the following topics in greater detail:

1. Burdens due to ICE LDV emissions 2. Barriers to ICE LDV alternatives 3. Agency in transitioning to clean LDV mobility 4. Unintended consequences caused by True Decommissioning
section_name: Equitably

section_content: The impacts of climate change, caused in part by ICE LDV-emitted GHG emissions, do not affect all communities equally. The increased risks of extreme weather and temperature, sea-level rise, and threats to biodiversity disproportionately impact poor and marginalized communities (Robinson and Shine, 2018). Many of the hardest hit communities in the US cannot participate in climate adaptation, such as moving away from vulnerable areas, and do not have the means to recover after an extreme event occurs (Morello-Frosch et al., 2009). A well-known example is the destruction and displacement caused by increased wildland fires in the Western region of the US due to warming temperatures (Abatzoglou & Williams, 2016). 

People of color and socioeconomically insecure communities are more vulnerable to the negative effects of wildland fires (Davies et al., 2018). 

On a local scale, TRAPs emitted by our society's current fleet of ICE LDVs disproportionately affect specific communities. The heavy-duty transport sector, including large shipping trucks also contribute to this emissions burden. In the US, people of color and low-income households are more likely to live near major roadways (Pinto de Moura and Reichmuth, 2019). Systemic racism and classism withholds agency from these populations to move elsewhere. These same communities are known to experience higher exposure to TRAPs (Tessum et al., 2021; Di et al., 2017), which leads to exacerbated health effects. Permanently and quickly removing ICE LDVs can help to alleviate these burdens and improve human health and wellbeing.
section_name: Burdens Due to ICE LDV Emissions

section_content: We must also consider that implementing True Decommissioning could increase barriers to mobility access for those who rely on ICE LDVs. LDVs serve an important function in society by allowing people without access to public transportation or other means of transportation to participate in the workforce, education, and other activities. An estimated 45% of Americans do not have access to reliable public transit (American Public Transportation Association, 2021). Micromobility solutions, including e-bikes and scooters, are not practical for large-scale deployment in semi-urban or rural areas. For many communities, barriers exist to accessing ZE LDV alternatives to their ICE LDVs. Through our research and community engagement, we see these barriers emerge in three broad categories: 1) financial, 2) infrastructure, and 3) administrative. 

Financial barriers to ZE LDVs exist in many forms (Rezvani et al., 2015). It is well known that ZE LDVs have a high upfront purchasing cost. Even with rebates or incentives, purchasing a new ZE LDV for tens of thousands of dollars is unrealistic for many. The used ZE LDV market is currently not mature enough to offer cost effective alternatives for those who cannot afford a new vehicle. These vehicles also require charging and individuals may not be able to afford the electricity costs, depending on their geographic location and utility provider. In addition to the high direct cost of ZE LDVs, systemic barriers impede access to financing mechanisms intended to support the purchase of a vehicle for many individuals. As mentioned earlier in the section, individuals who do not have a good credit score can only obtain loans with very high, unreasonable interest rates, putting a ZE LDV purchase out of reach. We have heard stories from individuals in low income communities that to find the right financing option, their credit score had to be pulled multiple times, making their already-low credit score even lower. The structure of our society's financial institutions creates barriers that prevent many people from participating in the transition to clean LDV mobility. 

Charging availability is the primary infrastructure challenge to ZE LDV adoption. A lack of public charging infrastructure can discourage the purchase of ZE LDVs for many people. This lack of infrastructure is especially relevant for those who cannot access their own charger, such as renters, or those whose employers do not offer the benefit of chargers. The public charging infrastructure that does exist is not always available to all populations. One study in California found that public charging access in the state is lower for low income and communities of color (Hsu and Fingerman, 2021). 

Administratively, current government programs intended to remove barriers to ZE LDV adoption may not be accessible to all communities. For example, one study found low income households in the metro Atlanta area were less likely to be eligible for ZE LDV federal tax credits due to factors such as tax bracket and family makeup (Liu et al., 2020). On a state level, researchers at UC Berkeley found California's Clean Vehicle Rebate Project (CVRP) has issued a larger number of ZE LDV rebates per capita to higher-income, whiter communities (Ju et al., 2020). Programs such as CVRP often use rebates, which are difficult for lower income households to take advantage of. Excessive paperwork and multiple steps to apply for incentives renders the benefit inaccessible to those who cannot afford the time or resources. 

Navigating the process online, comprehending the legal wording, and overcoming language barriers can make the process more difficult. Even finding out about available incentives is a barrier for many communities that programs intend to target. It is very likely that there are additional barriers that communities face in purchasing ZE LDVs that we have yet to uncover. 

As an example, California's Clean Cars for All program (California Air Resources Board, 2016) attempts to remove these barriers and equitably provide resources to low income communities to purchase a ZE LDV and trade in their old ICE LDV. A recent evaluation of this program has prompted California's Air Resource Board and the regional Air Quality Management Districts to re-think how the program works and who it serves. We look forward to seeing the changes and how the revised program is implemented throughout the state.
section_name: Barriers to ICE LDV Alternatives

section_content: The agency of an individual to change their distribution of burdens and benefits is deeply interwoven throughout all aspects of the transition to clean LDV mobility. Lack of agency is a crucial barrier to achieving a truly equitable state and is often overlooked. In an equitable society, for example, all individuals should have the agency to move away from areas with poor air pollution or locations sensitive to climate change effects, but many cannot. In another example, individuals without adequate health care and insurance have limited options to alleviate the hardships that come with TRAP-related health effects (i. e. disabilities, chronic diseases, lost days of work). As a third example, discussed throughout this section, individuals do not have options to improve their credit score and cannot obtain a reasonable interest rate on their car loan because of their low credit score. Systemic oppressions remove agency from individuals to improve their life and their family's life. True Decommissioning must focus on empowering individuals to have agency over their mobility choices, rather than removing agency.
section_name: Agency in Transitioning to Clean LDV Mobility

section_content: The path to achieving True Decommissioning without consideration of equity can cause unintended consequences both domestically and internationally. 

Regulations in the US intended to support the transition to clean mobility may engender unforeseen reactions and unknowingly affect many communities. For example, the Executive Order N-70-29 in California banning all new ICE vehicle sales by 2035 (California Office of the Governor, 2020) could cause people to hold onto their ICE LDVs for longer if they cannot afford or do not want to purchase a new ZE LDV. This regulation may end up supporting the continuation of the used ICE LDV market instead of supporting the transition to clean LDV mobility. More ICE LDVs on the road for longer will most likely increase the emissions burden on low-income communities, communities of color, and other disadvantaged communities. 

Beyond US borders, a study conducted by the United Nations found that the US is one of the three largest exporters of used vehicles to other countries (United Nations Environment Programme, 2020). Many of these countries have less stringent emissions regulations than the US. Exporting ICE LDVs allows those vehicles to continue emitting global GHG emissions and shifts the TRAPs to other locations. The useful life of these ICE LDVs will most likely be extended as well. While the exact relationship between economic growth and car ownership is currently unclear, disrupting the supply of ICE LDVs may also have negative impacts on these countries and their growth. We must better understand the global implications of removing ICE LDVs and anticipate unintended consequences of the strategies that are implemented.
section_name: Unintended Consequences Caused by True Decommissioning

section_content: In order to build the complex system required to achieve True Decommissioning, we must understand the individual parts of the multi-objective optimization problem and how they interact with each other. We believe the next steps fall into three main areas, which we discuss in this section.
section_name: Next Steps to Implement True Decommissioning

section_content: Researchers and decision makers must intentionally engage stakeholders from the very beginning to understand their needs and barriers to accessing ZE LDV alternatives and decommissioning ICE LDVs. A stakeholder can be an individual or an entity that is affected by or can affect an action, event, policy, or decision (Freeman, 1984; Volger et al., 2017). The list of stakeholders include: vehicle users, community members indirectly affected by transportation systems, employees of the transportation and manufacturing industry, insurance companies, financial institutions, and federal, state, and local government agencies. We are particularly interested in elevating the voices of stakeholders in underserved communities, as discussed in the previous section.
section_name: Engage Stakeholders

section_content: To make significant and rapid progress toward True Decommissioning, we must better evaluate the economic costs and benefits of removing ICE LDVs. We need to understand the economic value of the current ICE LDV fleet in the US, including outstanding useful life, loan payments, and lease payments. Analyzing used car market data can assist decision makers in understanding the link between car buyer/lessee purchasing decisions and turnover rates in order to determine how those decisions affect ZE LDV penetration. A more thorough understanding of the benefits of removing ICE LDVs is also an important consideration to True
section_name: Evaluate Economics Costs and Benefits

section_content: ϐ We are studying this question in the context of California's Clean Cars for All program. ♤ We are studying this question by analyzing data from California's Clean Cars for All program. Δ We are studying this question through a literature review and in the context of California's Clean Cars for All program. + We are studying this question for Sonoma County through data analysis of records from the DMV. ^ We are studying this question through modeling.

section_name: Research Questions to Achieve True Decommissioning

section_content: Decommissioning, including the averted costs of climate change and reduced health costs due to avoided emissions. 

Understand Current and Future Policies Driving rapid ICE LDV removal at such a large magnitude in the most equitable way is not possible without policies that support clean mobility for all. To make True Decommissioning a reality, we need to understand the relevant policies that are currently in place, as well as policy frameworks that can be used for future action. We also want to understand how to support communities through programs and incentives. Even if policies explicitly call out equity as a priority, this focus may not happen in practice. Governments at all levels -federal, state, and local -must be involved in designing better policies to ensure potential benefits are distributed equitably and populations are not left behind.

section_content: In addressing True Decommissioning, it is clear that a large number of research questions have come up, many of which are unanswered. We have provided a table of questions in the Appendix that is far from exhaustive. If you are working in this space, we invite you to reach out and let us know if you have made progress in the areas we have listed or are working on related research questions that we have not listed. 

We have started to work on some of these outstanding questions that were chosen based on a combination of data availability, expertise, and criticality. The overarching goal of our research group, DIVE (Decommissioning ICE VEhicles), is to develop effective and, above all, equitable policies and incentives to decommission ICE LDVs and ensure true removal of trailing emissions from this source. We are collaborating with partners in the local government and communities in Sonoma County, California for the initial phase of our project. We aim to answer our research questions and test solutions locally with the intent that our insights will be scalable to other communities. 

In summary, we have introduced True Decommissioning as the removal of ICE LDVs from the road permanently, quickly, and, equitably. We discussed the next steps to implementing True Decommissioning, including engaging stakeholders, evaluating economic costs and benefits, and understanding policies and programs. Finally, we presented a table of unanswered research questions, including those our research group is working on. There is much research to be done, and we would like to invite people to connect with us if they are working in this area. We welcome discussions on how we can achieve True Decommissioning and work together to facilitate an equitable transition to clean LDV mobility for all.
section_name: Research Questions to Achieve True Decommissioning

section_name: Appendix