It will cost a huge sum, likely billions of dollars, to make Volkswagen fix all of the 482,000 TDI diesel vehicles it has admitted use "defeat device" software to ignore emission laws.

Indeed, it may not be practically possible for VW to modify 325,000 of those cars--and it would cost the company less simply to buy them back and scrap them instead.

That's a huge waste of money, say 45 environmental leaders and Silicon Valley executives.

DON'T MISS: How VW Can Atone For Diesel Deception: Electric-Car Advocate's Thoughts

Why not use those funds instead to force VW to build zero-emission vehicles?

That's the gist of a letter the group sent yesterday to Mary Nichols, chair of the influential California Air Resources Board, releasing it to the media at the same time.

CARB has to sign off on any fixes for all 482,000 cheating diesels that's proposed by Volkswagen to the U.S. Environmental Protection Agency.

2015 Volkswagen Golf TDI SE

2015 Volkswagen Golf TDI SE

Among the signatories: Elon Musk (CEO of electric-car maker Tesla Motors), Lawrence Bender (producer of climate-change movie An Inconvenient Truth), and Michael Brune (executive director of the Sierra Club).

"For a significant fraction of the non-compliant diesel cars already in the hands of drivers, there is no real solution," says the letter.

And it notes that "drivers won’t come in for a fix that compromises performance."

ALSO SEE: How Will VW Fix My Diesel Car, And When? A List Of All Models

It calls the idea of retrofitting selective catalytic reduction (SCR, or "urea") aftertreatment systems "costly and impractical," and suggests that while some cars may be fixed, "many won't--and will be crushed" instead.

The proposal suggests that in California, Volkswagen be released from its obligation to fix those non-compliant TDI diesel cars already on the roads.

Instead, use the state's existing zero-emission vehicle credits program to "direct VW to accelerate greatly its rollout" of cars with no emissions at all.

2009 Volkswagen Jetta TDI

2009 Volkswagen Jetta TDI

It suggests that the appropriate ratio would be a 10-for-1 reduction in emissions, over five years, compared to the excess emissions associated with the diesel cheating.

That, presumably, would mean that Volkswagen would be required to sell tens of thousands of Volkswagen e-Golf battery-electric cars, or other VW Group electric vehicles, from 2016 through 2020.

In some ways, the proposal is analogous to an article published by Green Car Reports in September, just a week after the EPA revealed Volkswagen's admission of cheating.

Electric-car advocate Tom Moloughney wrote that some portion of the fines VW will ultimately have to pay should be used to create a nationwide DC fast-charging network that would allow plug-in car owners to travel longer distances.

The fate of the proposal is unclear, but it adds a new dimension to the very public discussion over the Volkswagen diesel cheating.

2016 Volkswagen e-Golf

2016 Volkswagen e-Golf

It begs the question: Is the goal simply to modify cars that emit too much, to bring them within legal limits?

Or can more innovative remedies be implemented, to achieve a greater good of more significant reductions in vehicular emissions?

The full letter is published on the next page.

Tesla Motors CEO Elon Musk at Tesla Store opening in Westfield Mall, London, Oct 2013

Tesla Motors CEO Elon Musk at Tesla Store opening in Westfield Mall, London, Oct 2013

An Open Letter to California Air Resources Board Chairman Mary Nichols

The VW emissions scandal is mainly the result of physics meeting fiction. In the simplest terms, we have reached the point of de miminis returns in extracting performance from a gallon of diesel while reducing pollutants, at least at reasonable cost. Unsurprisingly, and despite having the greatest research and development program in diesel engines, VW had to cheat to meet current European and U.S. standards. Meeting future tighter diesel standards will prove even more fruitless.

For a significant fraction of the non-compliant diesel cars already in the hands of drivers, there is no real solution. Drivers won’t come in for a fix that compromises performance.

Further, solutions which result in net greater CO2 emissions, a regulated pollutant, are inappropriate for CARB to endorse. Retrofitting urea tank systems to small cars is costly and impractical. Some cars may be fixed, but many won’t and will be crushed before they are fixed.

A giant sum of money thus will be wasted in attempting to fix cars that cannot all be fixed, and where the fix may be worse than the problem if the cars are crushed well before the end of their useful lives. We, the undersigned, instead encourage the CARB to show leadership in directing VW to “cure the air, not the cars” and reap multiples of what damage has been caused while strongly advancing California’s interests in transitioning to zero emission vehicles.

The solution we propose for VW and the CARB is to, in a legally enforceable form:

1./ Release VW from its obligation to fix diesel cars already on the road in California, which represent an insignificant portion of total vehicles emissions in the State, and which cars do not, individually, present any emissions-related risk to their owners or occupants

2./ Instead, direct VW to accelerate greatly its rollout of zero emission vehicles, which by their very nature, have zero emissions and thus present zero opportunities for cheating, and also do not require any enforcement dollars to verify

3./ Require that this acceleration of the rollout of zero emissions vehicles by VW result in a 10 for 1 or greater reduction in pollutant emissions as compared to the pollution associated with the diesel fleet cheating, and achieve this over the next 5 years

4./ Require that VW invest in new manufacturing plants and/or research and development, in the amounts that they otherwise would have been fined, and do so in California to the extent that California would have been allocated its share of the fines

5./ Allow VW some flexibility in the execution and timing of this plan by allowing it to be implemented via zero emission vehicle credits.

In contrast to the punishments and recalls being considered, this proposal would be a real win for California emissions, a big win for California jobs, and a historic action to help derail climate change.

The bottleneck to the greater availability of zero emissions vehicles is the availability of batteries. There is an urgent need to build more battery factories to increase battery supply, and this proposal would ensure that large battery plant and related investments, with their ensuing local jobs, would be made in the U.S. by VW.

A satisfactory way to fix all the diesel cars does not likely exist, so this solution side steps the great injury and uncertainty that imposing an ineffective fix would place on individual diesel car owners. A drawn out and partial failure of the process will only exacerbate the public’s lack of trust in the industry and its regulators. By explicit design, this proposal would achieve, in contrast, a minimum of a 10X reduction in pollutant emissions as compared to a complete fix.

There is a precedent for this type of resolution. In the industry-wide 1990 diesel truck cheating scandal, the EPA chose not to require an interim recall but instead moved up the deadline for tougher standards to make up the difference. This proposal does the same for VW and ties the solution to a transition to zero emissions vehicles.

We strongly urge CARB to consider this proposal in resolving the VW cheating scandal.

  • Ion Yadigaroglu, Partner, Capricorn Investment Group
  • Elon Musk, CEO, Tesla and SpaceX
  • Jeff Skoll, CEO, Jeff Skoll Group
  • Dipender Saluja, Inside Straight Strategies
  • Carl Pope, Partner, Capricorn Investment Group
  • Chamath Palihapitiya, CEO, Social Capital
  • Ira Ehrenpreis, Partner, DBL Partners
  • Hal Harvey, CEO, Energy Innovation
  • Antonio Gracias, CEO, Valor Equity Partners
  • Lyndon Rive, CEO, SolarCity
  • Michael Brune, Executive Director, Sierra Club
  • Cole Frates, Renewable Resources Group
  • Ari Swiller, Renewable Resources Group
  • Lawrence Bender, Producer, An Inconvenient Truth
  • Reuben Munger, Partner, Vision Ridge
  • Jigar Shah, President, Generate Capital
  • Jason Calacanis, Angel, Launch Fund
  • Gregory Manuel, Partner, MNL Partners
  • Adam Wolfensohn, Partner, Encourage Capital
  • Jason Scott, Partner, Encourage Capital
  • Martin Roscheisen, CEO, Diamond Foundry
  • Steve Westly, Former California State Controller
  • Jules Kortenhorst, CEO, Rocky Mountain Institute
  • Steven Dietz, Partner, Upfront Ventures
  • Kevin Parker, CEO, Sustainable Insight Capital 
  • Anja Manuel, Partner, RiceHadleyGates
  • Larry Lunt, CEO, Armonia
  • Mindy Lubber, President, Ceres
  • Tom Darden, Partner, Cherokee Fund
  • Panos Ninios, Partner, True Green Capital
  • Jesse Fink, Chairman, MissionPoint 
  • Matt Breidert, Senior Portfolio Manager, Ecofin
  • Suhail Rizvi, CEO, Rizvi Traverse
  • Jeffrey Tannenbaum, Chairman, sPower
  • Rob Davenport, Managing Partner, Brightpath Capital
  • Stuart Davidson, Chairman, Sonen
  • Laurence Levi, Partner, VO2 Partners
  • Rob Day, Partner, Black Coral Capital
  • Dan Fuller, CIO, Fuller Smith
  • Nicholas Eisenberger, Partner, Pure Energy
  • Marc Stuart, CEO, Allotrope Partners
  • Justin Kamine, Kamine Development
  • Peter R. Stein, Managing Director, Lyme Timber
  • Bruce Kahn, PM, Sustainable Insight Capital
  • Raúl Pomares, Managing Director, Sonen

[hat tip: Joseph Dubeau]

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