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Comment 3 for Advanced Clean Cars II Rulemaking (accii-comments-w3-ws) - 3rd Workshop.
First Name: Vanessa
Last Name: Warheit
Email Address: vwarheit@gmail.com
Affiliation: EV Charging Access for All coalition
Subject: Additional Comments
Comment:
Here are some additional comments based on today's workshop: 1) Do not wait until 2026 to begin the EJ credits programs. Put these in place ASAP. 2) Do not use EJ credits to lower standards - this pits the climate issue against the imperative to address structural inequities. Maintain strict standards! Use some other incentive for EJ. 3) Include fleets in your incentive structure. Rental car fleets in particular need to be incentivized to electrify. 4) If NEVs no longer count toward OEM compliance, how will CARB ensure that NEVs continue to be electrified? This is particularly important for city 'meter maid' parking vehicles. 5) Lower the minimum range for compliance to 100 miles EPA rating. (As one example: our family has a long-range EV that we purchased new, and we are now in the market for a cheaper, short-range used EV as a second car, for which a 100-mile range is plenty.) If the mass market is pushing OEMs to create longer-range vehicles, it's extra important for CARB to ensure cheaper/lower range vehicles continue to be manufactured to serve lower-income drivers. 6) Mimicking the EU's limit of 150 GWP for refrigerants is not aggressive enough and based on out of date data. That EU law has been in effect since 2017; today there are many refrigerants on the market with GWP below 10. Thank you for taking these comments!
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Date and Time Comment Was Submitted: 2021-08-11 17:54:29
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