Comment Log Display

Clerk of the Board
California Air Resources Board 
1001 I Street, 23rd Floor
Sacramento, CA 95814

Re: 	Agenda Item 7-5-5, May 24, 2007
	PUBLIC MEETING TO CONSIDER A STATUS REPORT 
ON THE ZERO EMISSION VEHICLE (ZEV) PROGRAM


Board Members:

ZENN Motor Company would like to add its support to the staff
recommendations “to adjust the credit value appropriately to
reflect the value of NEVs for emission reduction”. We believe that
this more equitable treatment of technologies is in the best
interest of consumers, and indeed in the best interest of the
global environment. As the Expert Panel found (Staff Report, p 9),
NEVs are helpful in that they:

•	reduce harmful emissions 
•	reduce greenhouse gas buildup
•	help with energy independence issues
•	are commercially viable

The Panel was asked to examine “the prospects for technology
advancement in both the near- and long-term” and “to project mass
marketability of vehicles using these technologies”.
The panel rightly recognizes that the NEV offers a true
zero-emission solution to climate and air quality issues. However,
many of the obstacles to greater use of the NEV have been, and
continue to be social, not technological.
-	It has taken 10 years to gain access through legislation to
public roads. A few states still resist (46 of the 50 States allow
NEVs)
-	municipal ordinances are a pre-condition of legal operation and
this continues to be a significant obstacle and source of
confusion
-	the existing patchwork of municipal by-laws is widely variable,
too scattered, and sometimes overly restrictive 
Because of these factors, we applaud the proposed initiatives of
the Board to educate, inform and motivate the pubic to consider
new alternatives that challenge common assumptions about urban
transportation. (As outlined in California Consumer and Fleet
Manager Reactions
To Clean Vehicle Technologies,  p 3)
According to the Panel and Staff Report, the issues with NEVs are
thought to be:
“Market potential for the technology is relatively small due to
limited applicability” (Staff Report,  p 9)

-	The cliché image of the NEV is that it is driven by a senior
citizen in a gated community. Our real world experience does not
support this misconception. Hundreds of average Americans from all
parts of the United States contact ZENN every month. They tell us
that they would like to drive the ZENN in their public urban
environment, not a restricted private road network. A significant
proportion would like to use a NEV for business purposes.
-	Most American households today have more than one vehicle. In
fact, 41% have two and 47% have three or more.  From our
perspective, replacing just one of those secondary ICE vehicles
with a NEV would have a substantial positive impact on air quality
and climate change. This is an enormous market and remedial
opportunity but without leadership it is more likely to be induced
by a relentless increase in oil prices.
-	It’s not inconceivable that the NEV may have “limited
applicability” in an environment designed for sprawl and habitual
commuting. However, the fastest growing trend in urban planning is
the New Urbanism movement which promotes compact urban design and
mixed use of space. The NEV is a natural complement which shares
many of the same ideals about sustainable communities. As more New
Urbanist communities are developed, the market for NEVs is likely
to expand accordingly. 

“performance limitations”
The common misconception is that the public will not accept
alternative forms of transportation that diverge from the existing
‘norm’ of high speed and long range. Yet consider the current
experience with some ‘low speed’ forms of transportation: 
-	Neighborhood Electric Vehicles evolved from the public
acceptance of golf carts which established a market beyond the
golf course despite a deficiency in speed, comfort and safety. 
-	US sales of electric bicycles, for instance, are projected to
double to about 200,000 units by 2009 regardless of limited speed
and range, and lack of comfort or safety features.

-	The very low average speeds in cities and neighborhoods
throughout the USA must also be considered.

The panel concluded that NEVs “provide no significant benefits to
future mass market ZEVs due to simple technology…”.  This bias
toward finding a more exotic and undoubtedly expensive new
technology for future mass commercialization does not fit with the
market experience to date.  The Board should continue to support
successful ventures which use currently available technology while
encouraging the introduction of newer innovations. This is the path
that the ZENN Motor Company currently follows:
-	ZENN has developed a quality product for personal mobility which
is an environmentally responsible choice, technologically feasible,
economically viable and appealing to consumers.  ZENN will continue
to fill the demand in the NEV market which we perceive to be a
permanent and expanding market niche.
-	At the same time, ZENN has invested in, and holds rights to, a
potentially ‘game-changing’ energy storage technology (EEStor Inc.
based in Austin Texas) so that we are positioned to be a leader in
zero emission transportation if and when the new technology
becomes commercially available early in 2008.

Let me close by emphasizing that the Panel’s conclusions tend to
distort the potential of Neighborhood Electric Vehicles by:
-	greatly underestimating their market potential
-	exaggerating the role of ‘performance’ in consumer choice 

As I have described above, the significant obstacles which prevent
the wider use of NEVs are primarily administrative barriers built
around old attitudes and perceptions. The public has indicated to
us that it is ready and eager to adopt new behaviors that have a
visible impact on the challenges of air quality, climate change
and oil dependence. I encourage the Board to pursue those policies
that will accelerate the current trend toward responsible social
change.


Ian Clifford
Chief Executive Officer
ZENN Motor Company