| Comment | ICCT strongly supports CARB's proposed update to the Zero Emission
Vehicle (ZEV), Low Emission Vehicle (LEV), and Clean Fuels Outlet
(CFO) programs and we commend CARB for its national and
international leadership on advanced technology development,
conventional pollutant control and greenhouse gas reduction.
We agree with CARB’s ZEV upstream emissions accounting proposal in
the LEV III greenhouse gas standards, and staff efforts to explore
regulatory and non-regulatory options for hydrogen infrastructure
deployment. We encourage CARB to cap the potential reduction of ZEV
targets through automakers’ “overcompliance” with federal GHG
standards and to require earlier notifications when they choose
this option. We also encourage CARB to end “Neighborhood Electric
Vehicles” credit issuance and revise proposed “BEVx” credits.
We support CARBs proposal to lower PM emission rates. We encourage
CARB to accelerate fine particulate emission standards to achieve
greater and more rapid public health benefits. We also encourage
CARB staff to adjust the proposed ozone precursor limits for
aggressive driving and air conditioning scenarios.
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