RE: History Predicts “Buckle Up”

My wife started volunteering to work festivals for local wineries, including one where the wine maker is a scientist for the US Geological Service. She got interested in government work and eventually found her way into the USGS in 2008.That same winery was where Chatham Street kicked off (we thought well heck, rather than buying wine why don’t we play for free wine AND a check? But I digress).

Around that time I’d started to grow weary of the international DC/NYC/Sweden regulatory party circuit. Somewhere along the way my wife found a job opening with NHTSA working on adapting light duty CAFE regs to heavy duty trucks that had been mandated in some obscure page of some omnibus spending bill in 2008 -ish.. The opening couldn’t have been written more for me if it had had my name in the headline. And it was a GS-14 (the General Services grade scale goes to 15) And this job didn’t involve managing anyone.

So now I should take a moment to clarify some DC things. First, once you get a year under your belt in the bureaucracy you literally almost can’t be fired (the EPA guy who told everyone he was taking a top secret assignment overseas and then didn’t show up for work for 3 or 4 years was fired. That’s the bar) Government benefits are the best, hands down. And you get so much vacation time much of it’s donated when you hit use it or lose it levels after about 3 years. And speaking of 3 years, that much seniority allows you to quit and come back with exactly what you left with at will. This will matter in the details later.

And finally, I should take some time to clarify the technical details of EPA’s emissions regulatory scheme and NHTSA’s CAFE fuel economy scheme.

EPA’s authority is known as a “Type” scheme. You have to submit boatloads of data before they will let you sell your product in this country. Period. Screw it up at any point and it’s illegal to move a car from the plant parking lot to the railway tracks for shipping. Period. At a production rate of sometimes up to a unit every 30 seconds or so a plant manager of a high margin product will have the Engineering Vice President’s personal phone on speed dial and the mobilization of engineers will be akin to D-Day. And the limits are hard limits. “X” grams/mile, no more. Period. And the fines for violations are set by statute at up do $32,500 per day per vehicle. Actual fines are usually negotiated with the discretion of the agency, but only with the understanding that pissing off EPA can be arbitrarily fatal to even the biggest corporations in the world. This is all because you’re dealing with actual pollutants by definition.

CAFE is a fleet average scheme. Average up all the vehicles you sell in a year and report it to the agency at the end of the year. Fines are again set by statute at about $5 per vehicle per tenth of a mile per gallon over the allowable limit. Europeans generally don’t give a shit and just pay the fine (hell, what’s an extra $50 on the price of a Mercedes in the grand scheme of things?). The Japanese pride themselves on meeting the letter of the law and since they generally don’t have the breadth of product that US manufacturers do usually just make the numbers without complaint. US manufacturers work hard to game the system (move manufacture of the Crown Victoria to Canada so it qualifies as an import averaged against the Probe built in Flat Rock outside of Detroit). This is all because you’re dealing with fuzzy policy goals and not pollutants.

Another thing to understand in the math is that if EPA regulates CO2 because of the hard cap, fuel economy is given. You literally cannot violate CAFE if you’re meeting EPA CO2 regs. A small division of NHTSA becomes a rubber stamp functional paperweight (their existence is dictated in statute. They simply can’t go away).

So I went for it thinking, perhaps naively, that maybe at least I might be able to find a way to further Dingell’s vision and build in some loopholes that would help my compadres in industry.

Meanwhile, the Bush administration punted the resolution of EPA v. Massachusetts to the next administration where Obama jumped on it like a starving dog on a Porterhouse and made EPA regulation of CO2 the law of the land.

I started with Obama’s NHTSA on August 3, 2009 at the same time as another guy named Jim Tamm who came from Chrysler in Detroit.. Took advantage of the transportation stipend offered to Feds that basically completely covered a van pool/bus ride in to Le Enfant plaza and a metro ride to the Navy Yard (next to National’s stadium) every day. Day started by catching the ride out of Front Royal at 4 am and returning around 7 pm every night. Put my Honda into semi-retirement with about 120,000 miles on it. Generally pleasant work like all government work without a real world incentive for heroics. Flew a few places and spoke at several conferences and met with manufacturers across the country (went to Seattle once to visit the Kenworth plant).

My supervisor, the woman who hired me, accepted a rotation to the Middle East about 6 weeks in and I never saw her again. After that we just reported directly to the Administrator, Steve something. The supervisor was never replaced.

Mid-year I got the standard performance review from Steve which gave me perfect marks with no concerns. Still got that form somewhere.

In about May there was a big meeting between us and EPA to resolve our agency’s inherent competitive differences. The very logical idea of harmonizing standards was raised and generally agreed to. I remember thinking at the time that that would free me up to move to another agency when my position was rendered redundant.

Friday July 30, 2010 started like every day. Some kind of meeting in the morning. Steve retired the day before and wasn’t around. About noon I got a call to come to HR and only Jim Tamm was there and gave me notice that I was being terminated effective immediately. The reason was that I had failed to contract a study that he had asked me to do once in a meeting a year ago. Never mind that spending Federal money without authorization is a felony. It was all there on the form. Still got that form somewhere, too.

He asked me if I preferred to be fired or quit voluntarily. Through the fog and cursing of the moment, I opted to quit. Turns out that cost me any unemployment benefits.

They gave me a box and plenty of time to clear out my desk (about 45 minutes), and then did the perp walk to the door.

Called my wife at work since I was stranded in the city and she left work to meet me at the Vienna metro station.

Took my box and crossed the street and boarded the metro for the last time in my life.

Got to Vienna and it was miserable and raining. Sat in the commuter shelter and waited until my wife picked me up and drove me home.

Next up, Epilog- Star date 01/06/2021.



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