warm thoughts


Written on: April 17, 2023

Opinion by NPGA President & CEO, Stephen Kaminski

On April 12, the U.S. Environmental Protection Agency proposed tailpipe emissions rules designed to exponentially increase the number of electric vehicles on the nation’s roads within a decade. EPA EV Rulemaking / EPA Proposed Rule / EPA Press Release

The greenhouse gas emissions-based regulations would phase-in starting with model year 2027 and aim to make up to 67% of new passenger vehicles sold in the U.S. “carbon-free” by 2032. The plan would also electrify roughly 50% of new medium-duty vehicles and between 25-35% of heavy-duty trucks by 2032. The EPA proposes to use tailpipe emissions methodology, but—as we’ve seen time and again from the Biden Administration—ignore source emissions and transmission losses. And to further stack the deck, most new and used EVs are eligible for hefty tax credits. That’s on top of billions in EV infrastructure giveaways at the expense of American taxpayers.

Yet, even those egregious forced-choice tactics—and the relentlessly increasing strain on an already overtaxed electric grid—in my opinion, pale in comparison to the abject human rights abuses that this misguided policy promotes. It is simply appalling.

EV batteries depend heavily on cobalt and lithium. Child labor for cobalt mining is well documented (see, e.g., Amnesty International, Fortune, Cobalt Red) and the left-leaning, nonprofit Business and Human Rights Resource Centre has uncovered human rights violations in the lithium mining industry as well (BHRCC EV Mineral Study).

The Business and Human Rights Resource Centre tracks company-by-company human rights violations. It’s tracking the largest cobalt and lithium mining companies in the world and what it has found is astonishing. Of the top cobalt mining companies, 80% have human rights allegations lodged against them. And that number rises to 100% of the top lithium mining companies, including two American-based companies operating overseas. BHRCC EV Mineral Study

And these human rights violations are poised to get even worse as the World Bank estimates a 1,000% increase in these minerals will be needed to meet the battery-first policies of Western nations. On NPGA’s initial pass of the 750+ page EPA rulemaking, we saw no requirements that minerals be mined domestically.

Rather, the EPA flippantly states: It is also our assessment that widespread automotive electrification in the U.S. will not lead to a critical long-term dependence on foreign imports of minerals or components, nor that increased demand for these products will become a vulnerability to national security. [T]he reason that these products are often sourced from outside of the U.S. is not because the products cannot be produced in the U.S., but because other countries have already invested in developing a supply chain for their production. (EPA Rulemaking, p. 382).

In my humble opinion, the Administration has barely given lip service to the mineral supply chain and is knowingly sticking its head in the sand on human rights implications, not to mention the risk of an OPEC-style embargo. This policy has the potential to give the blood diamond business a run for its money.

NPGA will, of course, be vigorously commenting on the rulemaking for the propane industry.

Stephen Kaminski

NPGA President & CEO