I'm still noticing a lot of hand-wringing about the EV credit on Twitter, so I think some examples are in order (made-up numbers on all, just as examples).

EXAMPLE 1:

Q: Tesla sells 1/3rd of its cars in the US. Of them, 70% meet the price limits. Tesla buys its nickel from...
free trade (such as Canada) and non-free trade (such as Indonesia) countries. How much of its nickel must come from the former for *100%* of what qualifying cars need to be free-trade-deal sourced?

A: 23%.

EXAMPLE 1B:

Q: What about for 40% to be free-trade-deal sourced?

A: 9%
EXAMPLE 2:

Q: Tesla's cells use $3k of critical materials. Tesla buys abundant >99% pure alumina (smelting grade: >=99,5%) from a free-trade nation, making it a critical mineral, and supplies it to a smelter for making aluminum parts for their pack.
If literally *every gram* of *every other* critical mineral was non-free-trade sourced, how much would Tesla need to pay for the bauxite to hit the 40% limit?

A: $2000

Example 2B:

Q: Name some examples of what else could Tesla do this with for things already in packs.
A: Ferrochromium for stainless steel - 60% purity; fluorspar for fluoropolymers, electrode binders, electrolyte additives, etc - 97% calcium fluoride or 99% fluorspar; manganese, for cathodes or steel alloying - manganese sulphate (any purity) or 99,7% purity; magnesium...
.. for alloys and metals - 99% purity; zinc for galvanizing, 99% purity.

Example 2C:

Q: What in the pack can you NOT have as a "critical mineral"?

A: "Not much". Iron and some alloying agents. Organic carbonate electrolytes. Copper (weirdly). Separator membranes.
Example 3:

Q: If Tesla buys $3k of foreign parts for their packs, how much do they need to sell packs for to justify an argument that at least 50% of their components' value is North America-sourced?

A: $6k, possibly plus profit, amortized capital, and/or labour.
Example 4:

Q: If Tesla's pack components are 25% North American and the total component cost is $4k, how expensive of *any* North American part *of any kind* do they have to stick in there for no good reason?

A: $1,3k.
Example 5:

Q: If Tesla 4680s use <99% purity metallic nickel or cobalt rather than battery-grade sulphates, are those critical battery minerals?

A: No.

Example 5B:

Q: If Tesla 4680s need 99,5% purity nickel, what % needs to be a critical mineral?

A: Only half.
Example 6:

Q: How could Tesla move things around lower their critical mineral count?

A: Cast/stamp a separate box. Call it all or part the BMS or thermal system. Put all your non-cell foreign components and critical minerals in it. Connect it to the pack.
Example 7:

Q: If Tesla imports critical minerals from non-free-trade countries, makes cells out of them, 20% of them fail testing, and they recycle the minerals into new cells in the US, where are those minerals considered to have come from?

A: America.
Example 7B:

Q: If Redwood imports waste cells from all over the world made from non-free-trade minerals and recycles them, where are those counted as coming from?

A: America.

Example 7C:

Q) If a smelting process that normally takes a 1% grade ore is instead fed a feedstock...
... of shredded battery packs containing 10% of the mineral, what will this do to the process's production capacity?

A: Hard to generalize, but in most cases, a roughly 10x increase would be expected.
In short... this bill is a sieve. Partly due to oversights, but partly *by design*. It's *by design* that recycled cells turn into domestic sourced materials. It's *by design* that a lot of minerals not normally associated with foreign dominance are on the list. And the even...
... if it didn't cross the authors' minds that what defines a "battery pack" is a flexbile concept, I seriously doubt they didn't consider that manufacturers would juggle their supplies to ensure that only US-market price-qualifying vehicles get the compliant-sourced supplies.
And if there's any company out there best prepared to meet this, it's obsessed-with-local-sourcing, obsessed-with-vertical-integration, critical-mineral-reducing, rapidly-iterating Tesla.

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More from @enn_nafnlaus

Aug 11
🧵1/XX
-= H.R. 5376 Dive #4: Electricity, Part 2 =-

Continuing our series...



...today we go into the remainder of the sections in the bill that cover electricity and grids. Note that there's still sections on funding, efficiency, natural resources, ...
🧵2/XX
...farming... heck, ~40% of the bill is about medical coverage :Þ But let's hit things in order of relevance! As always, the full text can be found here:

s3.documentcloud.org/documents/2212…

Let's begin with Sec. 22001, which tacks a new section into the Farm Security and Rural...
🧵3/XX
Investment Act, Sec. 9003, for funding for electric loans for renewable energy. This allocates $1B for loans for rural clean energy projects, and specifically brings up "including projects that store electricity", and allows up to 50% loan forgiveness.
Read 32 tweets
Aug 10
🧵1/25
-= H.R. 5376 Dive #3: Electricity, Part 1 =-

As the next part in our series of going into the new sprawling EV credit-including bill passed by the US Senate...



... today we'll look at the sections covering electricity generation and transmission.
🧵2/25
As this is such a massive topic, it will be a two-parter.

We begin with Sec. 13101, which extends the Sec. 45D renewables PTC (Production Tax Credit).

* It allows construction on new qualified facilities to begin up to the end of 2024 (was: end of 2021)
🧵3/25
* The base rate is reduced from 1,5c to 0,3, but then re-multipled by 5 (back to 1,5c) if the project meets "prevailing wage" and apprenticeship requirements.
* An additional 10% bonus is added (so up to 1,65c max PTC) if 100% of steel, 100% of iron, and 40% (20% in the...
Read 26 tweets
Aug 9
🧵1/25
-= What Else Is In H.R. 5376 Right Now? Dive #2 =-

The other day, I went into the EV credit in H.R. 5376, the Inflation Reduction Act of 2022.



Specifically, I only dove into one section: sec. 13401, which amended the current credit, Section 30D.
🧵2/25
But this only covers the content in pages 381 to 400 (out of 755) in the bill passed by the senate:

s3.documentcloud.org/documents/2212…

Indeed, it doesn't even cover everything related to electric vehicles! So let's go into *those* sections in this thread.
🧵3/25
I got a lot of questions about the used car credit. That's Sec. 13402 (p.403-308), which amends the Internal Revenue Code to add a nonrefundable personal credit. It is:

* $4k or 30% of the sale price (whichever is less).
* The buyer's gross income in 2yrs hasn't exceeded:
Read 30 tweets
Aug 8
As an addendum to this thread:



I'd like to call attention to the fact that minerals "recycled in North America" (A) do not need to have been originally from North America, and (B) do not have to be post-consumer waste, but may be manufacturing waste.
This is important for several reasons:

1) Manufacturing waste is FAR greater than post-consumer waste when it comes to battery packs, since so few EVs get scrapped per year. But manufacturing waste is 10-30% - huge volumes.
2) Manufacturing scrap + North American recycling effectively allows one to "launder" minerals from anywhere into the US percentage requirements. Companies could buy up scrap from around the world, ship it to North America, recycle it, and claim the credit - regardless of origin.
Read 7 tweets
Aug 8
🧵1/31
-= Breaking Down The Clean Vehicle credit =-

Many claims have circled about the amended credit:

s3.documentcloud.org/documents/2212…

Does it reward hybrids? Does it favor H2? Does it benefit dealerships? Is it impossible to meet? Is Tesla at a disadvantage? Let's break it down.
🧵2/31
To start, we need to look at the existing code that is amended, 26 U.S. Code § 30D:

law.cornell.edu/uscode/text/26…

I'll also add that I am not a lawyer (or even a US citizen), so if an attorney chimes in, please listen to their take above mine.
🧵3/31

I merged in the amendments by hand and establish a "diff" to compare between versions.

diffchecker.com/KDS4AuHk

Note that I only did this for 26 U.S. Code § 30D, and not the entire bill.
Read 35 tweets
Jul 23
-=General Rule: If Machine Learning Can Cheat, It Will Cheat=-

A paper of examples of genetic algorithms and neural nets cheating at their tasks, plus some personal experience.

arxiv.org/pdf/1803.03453…

1) One of the seminal Alife programs was Framsticks:
(Indeed, the only "game" I ever hacked the copy protection on as a teenager ;) ). In it you lay out settings and a reward system for artificially-evolved creatures with primitive neural nets to evolve in to try to achieve some goal.

It was inspired by the seminal work of Karl Sims...

en.wikipedia.org/wiki/Karl_Sims

... and like Sims found, anyone who's played around with Framsticks quickly learns how much evolution likes to cheat. Sims started off trying to evolve creatures to walk the furthest in 10 seconds.
Read 35 tweets

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