Tesla: new technologies need new ways of thinking


My mind wanders a lot. There have been idle moments when, presented with a slice of birthday cake on a plastic or paper plate, I have wondered about the environmental-friendliness of the plate. Reading about Joe Nguyen’s travails in getting his Tesla model S licensed in Singapore, I started to wonder about cake on disposable plate again. 

Joe Nguyen’s story can be found on Stuff.tv, in their 1 March 2016 article Be prepared for these roadblocks if you want to drive a Tesla in Singapore. It’s further carried on mothership.sg here. The bottom line was that Nguyen ended up not enjoying the $15,000 rebate that eco-friendly cars are expected to receive, but was charged an extra $15,000 as tax for a non-fuel efficient car.

It was found to be non-fuel efficient based on tests conducted in Singapore. It appears that the testing authority first worked out how much electricity the car uses, and then converted it to carbon dioxide emission. The published stories indicate that there are questions to be asked about the methods used in testing; Nguyen did not think the finding of 444 watt hour per kilometre to be correct if the tests had been conducted properly.

I am no expert on these highly technical things, but I thought that the story also highlights some conceptual issues which are worth discussing. Primarily, they should never have taken this approach of looking at energy consumption and converting it backwards to emissions.

An electric car is not just another car

True, even electric cars consume energy. You want to move a hunk of metal or plastic composite from point A to point B, you need energy. It’s not as if a “green car” like the Tesla uses no energy at all. But using energy is not actually the issue when it comes to environmental impact. It is what sort and quantity of emissions are released into the environment when the energy is generated.

For a “normal” car with an internal combustion engine, the energy is generated within the car itself, and so measuring the emissions the car produces is a straightforward and accurate measure of the environmental impact of the car.

(Actually, not quite. The car needs to run on refined petroleum products. The refining process itself can generate emissions, as does the transportation of both the crude and refined petroleum product, well before it is pumped into the car’s gas tank. To be complete, we need to add in the environmental impact of these prior processes. But how do we measure these elements? Much depends on what sort of crude was first used — some are dirtier than others — and how far the petroleum product had to travel before it got to the petrol station.)


Electric cars draw their energy from mains supply. So the question that needs to be considered is this: what sort of emissions were put out by the power plants when they first generated the electricity? Immediately, you’ll realise that it will probably vary greatly from one country to another. Some countries still generate electricity from coal, particularly brown coal (very dirty!). Other countries produce much of their mains electricity from wind or solar power. (Wikipedia page on fossil-fuel power stations).

Nitrogen oxides

Emissions aren’t all of the same kind. There are different substances we must consider. Carbon dioxide is a biggie, but there is also nitrogen oxides among others.

The internal combustion engine (with diesel the worst offender) certainly produces nitrogen oxides; yet I don’t know if in testing Nguyen’s car and denying it eco-friendly status, this was taken into comparative consideration. Power plants produce nitrogen oxide too when generating electricity, but if the source fuel is natural gas — which is the case in Singapore — emissions are relatively low.

If the testing authority only measured (or converted to) carbon dioxide emission without factoring in nitrogen oxides, it would not have been a fair measure of the Tesla’s environmental impact/benefit. At this juncture, I don’t have any information what exactly they did at testing.

The means that the same Tesla, when driven in different countries, will have different environmental impacts. But it’s not the Tesla’s fault. It is entirely due to the upstream power producers.

Tax the source

This leads us to see that taxing the energy-consuming product (e.g. the electric car) for environmental impact is not the smartest thing to do. By the same token, giving rebates to the consuming product is not smart either. The thing to tax is the hydrocarbon fuel itself, based on its carbon (and perhaps nitrogen) content, and the machine that burns it (the energy-producing product), based on its efficiency and output of emissions.

Some countries have implemented a carbon tax. The details vary from one place to another, but generally it is a tax on the fuel based on its carbon content and/or its energy content.

But the same fuel can lead to different levels of emissions depending on the machine that burns it. Properly therefore, there should be a second tax on the machines, calibrated to the “clean-ness” of the burning. For example, machines fitted with catalytic scrubbers release less toxic emission. Thus, a tax on the internal combustion engine, or the boilers in power stations and factories can be justified.


However, in the case of an electric car, or an electric rice cooker or electric fan, asking the appliance what its emissions-equivalent is, and taxing it, is a rather roundabout way of doing things. An across-the-board tax aimed at the source (the fuel and the machines that did the burning) and based on a simple principle is far less distorting than a variable series of different taxes on different end-user appliances. A simple, clearly conceptualised tax is also better able to cope with new inventions coming on stream.

Unable to cope with the new

Readers who have read the original story on stuff.tv and mothership.sg about Joe Nguyen’s tussle with officialdom would have grasped the point: the bureaucracy here does not score well when it comes to coping with anything innovative. This is true as much with objects as with ideas.

I won’t belabour this point too much — it is obvious to most people living here — except to say that a lot of it has to do with with the top-down nature of authority and decision-making in this place. Junior officials don’t feel they have the freedom to be making creative decisions, or don’t have the self-confidence to even propose any. Anything out of the ordinary is thus pushed upwards for direction, but the upper levels — as in anywhere else — have only limited bandwidth to deal with the many issues reaching them.

Worst of all, a suffocating blanket of conservatism sits on the whole state apparatus, resulting in a huge bias towards incremental change rather than being bold and creative. But as this Tesla case shows, when there is presented a conceptually new product, you need a conceptually new approach to grapple with it. You can’t just apply or merely extend old measures and methods to it.


Back to the cake-on-a-plate problem. The prevailing orthodoxy is that plastic is environmentally unsound. We even extend the same negative perception to paper plates. Of course, paper plates have their own problems: the source of pulp can be troubling, and the surface of the plate may still be coated with a thin film of plastic to make it water-resistant.

Both plastic and paper plates create a trash problem, which in turn leads to either a landfill or incineration issue.

The “greener” glow is usually cast on ceramic plates, reusability and washing, but I wonder about that too. Water isn’t free. It takes energy (from fossil fuel mostly) to make clean water and to pump it around. And what about the detergent we use to wash the plates? It takes more energy in the sewage plants (and to make the chemicals injected into the process) to clean the water up again. Every time we use energy, we tend to burn hydrocarbons causing more emission.

So what does the balance sheet really say? Is it so bad to use a disposable plate? I honestly don’t know, but while my hunch remains that disposable plates are greater sinners, I wouldn’t assume that the prevailing orthodoxy is always right.

As with electric cars, it can be difficult to pinpoint how much greener one thing is compared to another.



Addendum, 6 March 2016

I see a report in Channel NewsAsia wherein the Land Transport Authority was quoted for its explanation.

“As for all electric vehicles, a grid emission factor of 0.5 g CO2/Wh was also applied to the electric energy consumption. This is to account for CO2 emissions during the electricity generation process, even if there are no tail-pipe emissions. The equivalent CO2 emission of Mr Nguyen’s car was 222g/km, which is in the CEVS surcharge band,” the spokesperson added.

Under the revised CEVS, Mr Nguyen’s Tesla falls in the C3 band, which accounts for cars with 216 to 230 g/km, and carries with it a S$15,000 surcharge.

— Today, 4 March 2016, LTA on Tesla: CO2 emissions for electric cars start at power grid. Link.

The authorities applied the test finding of 444 watt hour per kilometre (Wh/km) to a grid emission factor of 0.5 grams CO2/Wh to obtain the result of 222g/km.


[The LTA spokesperson] added that the Tesla is not the first fully electric car where grid emission factor was applied. A Peugeot Ion, for instance, was registered in July 2014 and received the maximum CEVS rebates, the spokesperson said.


“This is the first time a Tesla Model S has been tested for emissions,” the spokesperson said.

— ibid

A few things become clearer in the light of this statement, but more questions remain. If the Peugeot Ion managed to get a full rebate, and the same test method was applied to the Tesla, how credible is it that vastly different results were obtained? This supports Nguyen’s contention that the testing itself was questionably done.

Secondly, it is apparent now that only carbon dioxide emission is taken into account. Nitrogen oxides emission, for which petrol and diesel cars are greater culprits than natural-gas burning power stations, were not in consideration. Omitting this angle creates a bias in favour of the internal combustion engine.

Thirdly, and the very point of my article, why apply the tax onto the appliance? If we apply it on an electricity-using car, why not on the electric kettle or on every installed air-conditioner? Applying it at source (i.e. on the electricity generator) is so much less distorting.


10 Responses to “Tesla: new technologies need new ways of thinking”

  1. 1 ape@kinjioleaf 5 March 2016 at 23:12

    I’m no expert in this either but I read in Straits Time online that Peugeot Ion and BMW i3 were given rebates of $20000 and $30000 respectively based on the same standard of tests.
    Does this mean the car owner should’ve checked before he commit to purchase?

  2. 2 Jason 6 March 2016 at 00:42

    I think this isn’t the best case to describe government red tape. First, the authorities were probably unhappy to see that an individual (as opposed to an established dealer like Borneo Motors) has imported large electric equipment that poses a potential fire hazard without first receiving some form of certification. I think a precautionary approach is well warranted.

    Second, if petrol cars are being regulated based on fuel economy due to concern over emissions, then electric cars held to the same standard should certainly have the power stations’ emissions taken into account. The Tesla should not be considered a zero emissions car. So again the authorities are on the right track.

    What is surprising is that the Tesla used much more power in the tests than expected.

  3. 3 yuenchungkwong 6 March 2016 at 00:44

    EPA rating for the Nissan LEAF is 30 kWh per 100 miles. A Tesla Model S 60 is rated at 35 kWh per 100 miles. So an environmentally conscious person should go for the Nissan. Of course, Tesla is more expensive and prestigious.

    • 4 Tim Walton 8 March 2016 at 03:47

      According to my calculator, 35 kWh/100 miles (from the EPA rating above) equates to approx. 218 Wh/km. This is just less than half the figure used by the LTA.

      Converted to CO2 emissions, this would then become 109 g/km, which would put the car into the A3 band and qualify it for a S$10,000 rebate.

      The big question which needs answering is why is there such a huge difference between the EPA and LTA figures.

  4. 5 an0n 6 March 2016 at 10:07

    … the bureaucracy here does not score well when it comes to coping with anything innovative.

    Hopefully we may yet improve. GPS-based Electronic Road Pricing, probably a first-in-the-world implementation, is coming on-line in the near future.

    I’m sure it will be a spectacular success.

  5. 6 Coern 8 March 2016 at 10:26

    “A few things become clearer in the light of this statement, but more questions remain. If the Peugeot Ion managed to get a full rebate, and the same test method was applied to the Tesla, how credible is it that vastly different results were obtained? This supports Nguyen’s contention that the testing itself was questionably done.”

    Not really.

    The Peugoet Ion is about half the weight of a Tesla. It’s like comparing the consumption of a VW Polo with that of a BMW 7 series. Conceptually no one would expect the BMW 7 series to be as carbon efficient as a VW Polo.

  6. 7 heex 9 March 2016 at 15:00

    A brief look at Mr Joe Nguyen’s Facebook suggests a man living quite the high life and being pretty promiscuous about that. As such, I have my doubts about why he wants to make life hard for himself by trying to import the Tesla that was bought in Hong Kong and then blowing the whole thing up on social media. The main bulk of the $380k cost of him buying this Tesla wasn’t due to the carbon emissions tax anyway, so a lot of non-official sources are perhaps over-sensationalizing this issue. I have read somewhere that the Tesla consumes electricity equivalent to the monthly household consumption (also, I suspect the weather in Singapore might play a part in reduced efficiency of the Tesla) – which is not that environmentally friendly after all.

    Also, there is a difference with taxing a trophy toy like Mr Nguyen’s Tesla and your regular man’s rice cooker, hence taxing at the source will be a very regressive tax, which I am sure you would not actually support. (P.S. rich men can go eat at restaurants and not use kettles or rice cookers!)

  7. 8 SIN Pariah 9 March 2016 at 15:09

    To me, it is perfectly logical to apply the tax on the equipment itself – such as a car as the environmental impact could be due to its manufacturer’s technical specs of fuel efficiency or due to the vehicle owner’s sub-par maintenance of the equipment.

    The equipment tax is the 2nd level of tax as the 1st level of tax is already on the fuel itself (eg, the petrol duty).

    For other equipment such as household appliances – I reckon that due to enforcement obstacles, the “pain” is levied at the 1st level of electricity tariffs (so if one buys a non-energy efficient air-con or doesn’t maintain the air-con for years, it will be reflected in the higher electricity billings).

    The sticky question is why isn’t a surcharge imposed on household appliances with 3 or less ticks under NEA’s energy rating scheme? Probably it is to help the companies clear their old inventory and allow consumers to buy such old-model appliance at cheaper outlay cost despite having to pay more for water/electricity usage during the equipment life span.

  8. 9 Rajiv Chaudhry 9 March 2016 at 21:30

    “If the Peugeot Ion managed to get a full rebate, and the same test method was applied to the Tesla, how credible is it that vastly different results were obtained?”

    The Peugot and the Tesla could be of different weights and have different power consumption. Bit like a 1.5 litre car versus a 3 litre one.

  9. 10 cy 11 March 2016 at 16:42

    “TEV Project highways would have an electrified metal strip embedded into the middle of the road which provides a constant source of power to the vehicle. Just like streetcars and subway trains do in today’s cities, cars on a TEV highway could charge as they drive”

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