First Name | Jennifer |
---|---|
Last Name | Krill |
Email Address | jenniferkrill@ran.org |
Affiliation | Rainforest Action Network |
Subject | RAN Response to CARB's Staff Proposal for the ZEV Program |
Comment | RAN Response to the California Air Resource Board’s “Staff Proposal: Initial Statement of Reasons” for the Zero Emission Vehicle Program Rainforest Action Network (RAN) has reviewed the "Staff Proposal- Initial Statement of Reasons" and while it contains some improvements to the Zero Emission Vehicle (ZEV) Program, we find that the Proposal undermines the opportunity for ZEV regulation in the state of California to bring the highest standard of pollution and petroleum-free vehicles into the marketplace. First and foremost, RAN would like to see ZEVs prioritized above Enhanced AT-PZEVs, and our recommendations are made in the spirit of getting ZEVs into consumers' hands as soon as possible. Based on our extensive conversations with automakers, we believe that they are indeed capable of meeting strong regulations and the highest bar for ZEVs in California. Given the escalating threats of global warming, air pollution, and our dependence on oil, we simply don't have time to wait. 1) INCREASE “GOLD” ZEV NUMBERS - Staff’s proposal notes that the 18-year history of the ZEV Program has yet to make ZEVs commercially available, and thus the current proposal calls for a reduction in numbers of ZEVs required. Reducing the number will reverse the likelihood that ZEVs will become commercially available. The current proposal would require fewer an average of 140 ZEVs per year from any individual automaker until 2015- few enough that several automakers can use banked credits for the next decade to meet this requirement. Those with fewer banked credits can easily accomplish these numbers through credit trading with small automakers, such as Tesla. Worse, the lower numbers reduce the likelihood that ZEVs will reach mass production and a viable economy of scale. Or, if they do, it will occur outside of California and may have no benefit for Californians, costing us a priceless opportunity to lead the way into the new generation of transportation technology. We therefore recommend that California does not decrease, but in fact increases the numbers of ZEVs required from the industry under the Alternative Path for Compliance from 2,500 to 10,000 in Phase II (2009-2011) and from 25,000 to 100,000 in Phase III (2012-2014). 2) RAISE THE FLOOR, NOT THE CEILING- To the extent that allocation is taken from another category to make room for Enhanced AT-PZEVs, it should be taken from the dirtiest category in the ZEV Program, not the cleanest. While PZEVs have served as an air-quality victory for the Program, they no longer need commercialization support, and lend no ZEV-enabling value. Therefore, we propose that the percentage of the Program requirements allowed to be met by PZEVs be reduced to 4% in Phase III, 2% in Phase IV, and phase out completely after 2018. In each Phase, the reduced PZEV requirement would be transferred up to the Enhanced AT-PZEV category, creating a stand-alone requirement for these vehicles without distracting from commercialization efforts of true ZEVs. RAN agrees that PZEVs play an important role in achieving California’s air quality goals. However, they don’t support the specific goals of the ZEV Program; our proposal provides adequate time for a PZEV requirement to be shifted to a more appropriate program such as LEV III. 3) DEFINING PHEV CREDITS- We strongly encourage the Board to reconsider defining and crediting Plug-in Hybrid Vehicles (PHEV) by kWh (either onboard or net usable) rather than miles. Using kWh provides more flexibility to the automakers to build PHEVs according to what they think will sell in the marketplace and will result in more overall cars on the road. Defining by miles biases toward small PHEVs, while defining by kWh will still encourage smaller, more efficient vehicles because they are more cost-effective to build, but also reward manufacturers who choose to electrify larger vehicles. 3) BACKFILLING- RAN opposes the use of Enhanced AT-PZEVs to backfill for any portion of the ZEV requirement and prefers to see separate, appropriate requirements created for ZEVs and Enhanced AT-PZEVs. 4) PUBLIC FLEET OPPORTUNITIES- While there is certainly retail demand for ZEV and near-ZEV cars, fleets can play a significant role in assuring a market for automakers compelled to build them, as well as in producing air-quality results for the areas in which they’re deployed. We therefore encourage CARB to consider requiring public fleets to purchase ZEVs and Enhanced AT-PZEVs when available and where practical for their intended use. However, because these vehicles are purchased with public funds, we propose that fleets must choose the most economical vehicle technology (lifetime cost) for a given air-quality benefit. 5) CREATIVE ZEV ECONOMICS- It makes sense for staff to consider the economic impact of the regulation on the automaker, however, citing 2003 battery cost estimates and projected 2012-2014 fuel cell costs to determine the incremental cost of each technology (ISOR, pg. 33) paints an inaccurate economic scenario that biases against plug-in vehicles. The two technologies need to be evaluated on an even economic playing field. 6) TRAVEL PROVISION – RAN opposes any travel provision in combination with decreasing the number of ZEVs required in any phase. We are very aware of how this issue has been “gamed” in the past, with vehicles being removed from service after a few years and placed in another state for credit. However, sanctioning the idea of building fewer ZEVs not only for one state, but eleven, will not lead to the market-building volume that we need. 7) EFFICIENCY MATTERS – California should incentivize ZEVs based on their overall energy efficiencies on a well-to-wheels or lifecycle basis, and not consider vehicles alone, divorced from energy production. Incorporating overall efficiency into considerations today will prepare us for the time when both vehicles and some energy sources will be zero-emission, and ZEV choices will be based on efficiency, economics, and other considerations. __________ Founded in 1985, Rainforest Action Network campaigns for the forests, their inhabitants and the natural systems that sustain life by transforming the global marketplace through education, grassroots organizing, and non-violent direct action. For more information visit www.ran.org. |
Attachment | www.arb.ca.gov/lists/zev2008/1485-ran_zev_carb_response_032008.doc |
Original File Name | RAN ZEV CARB Response 032008.doc |
Date and Time Comment Was Submitted | 2008-03-25 17:37:24 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.