Comment Log Display

Yuli Chew
38 Rocha Ct
Hammonton, NJ 08037
(609)-561-0698
Email: yulichew@yahoo.com

January 25, 2012


California Air Resource Board
101 I Street
Sacramento, CA 95814

Dear Sir or Madam:

Re: 2012 Amendments to the California ZEV Regulations

I am writing to strongly support the goals of the ZEV Program to
achieve the health base air quality standards and the greenhouse
gas emission goals. 

Here are some of my comments regarding certain sections of the
proposed rule.

1962.1(b)(1)
The ZEV requirement is clarified based on the annual NMOG
production report. However, it would be useful also to clarify if
the exempted vehicles such as emergency and law enforcement
vehicles should be included, even if they are certified according
to the California certification. To allow for any exemption will
encourage these vehicles from properly accounted for.

1962.1(b)(1)(B)(1)(g)
Carry-over of Excess Credits
The clause did not explain explicitly that the elimination of
carry-over limitations for MY2011 and later as explained in the
ISOR.

1962.1(b)(2)(D)(4)
Use of Additional Credits for Transportation Systems
I would propose add additional ZEV types to minimize confusion:
‘Any additional credits for transportation systems generated from
different categories of ZEVs in accordance with subdivision
1962.1(g)(5)....”

1962.1(b)(4)
Requirements for Small Manufacturers and Independent Low Volume
Manufacturers
Additional language may be added to clarify that they are only
entitled to earn delivery for sale and place in service credit in
each state, and not traveling credits in the 177 States. 

1962.1(d)(5)(C)
A vehicle is not eligible to receive credits if it is placed in
service after December 31, five years after the model year.

Allowing five years to place a ZEV may be too long and undermined
the compliance efforts by the regulators. Most of the placed in
service ZEV can be traced 9 months after the end of the model year
(as in the current regulation allows) from the state motor vehicle
registration agencies. If they are not sold by the next three
years, it would be difficult to imagine that the customers would
prefer the older models.

Concerns should be taken to prevent any stakeholders who deliberate
do not submit on time. To allow for this length of time will
disrupt the smooth flow of data collection and undue disruptions
for late data later on.

I would suggest that for those ZEV that had been placed in the
model year, they should continue to submit the credits nine months
after the model year ended. For those ZEV that are yet to be
placed, a 3 years extension would be sufficient.

For a multiple state dealership that may sell across different
states with or without the ZEV mandate, awarding “deliver for sale”
credits to all ZEV vehicles placed through the chain can be
misused. The only evidence may be from the delivery receipts or
from that evidences from the Manufacturers Source of Origin. There
may be only a portion of them that will eventually sold to the
residents in the state and earn the “place in service” credits. The
ratio of “deliver for sale” to “place in service” may have to be
capped, e.g. at 1.2 before this provision is being abused.

Increased Type V credits in 2015 – 2017 from 7 to 9
The reason for this, according to the ISOR, was that an OEM would
have to sell 3 BEVs (average 9 ZEV credits) to be of the same value
as 1 FCV. However, BEVs are proposed to travel until 2017. The
section 177 States would also like to set a reasonable and
achievable level of pool for the compliance, with the acceptance
from the OEMs. As such, there is no urgency for this argument. The
Type V FCV will stay as it is to get 7 credits, with 1 credit per
50 mile range.

Toyota even predicts that the price for the FCV vehicles may drop
to $100,000 range by 2015.
 http://www.bloomberg.com/news/2011-01-13/toyota-advances-hydrogen-plans-amid-industry-s-battery-car-push.html

2015 Toyota Hydrogen Car Will Cost $50,000
http://www.insideline.com/toyota/2015-toyota-hydrogen-car-will-cost-50000.html

Toyota says cost of FCHV-adv fuel cell protoytpe is $129,270
http://green.autoblog.com/2011/08/03/toyota-says-cost-of-fchv-adv-fuel-cell-protoytpe-is-129-270/

1962.1(g)(2)
Converting PZEV and AT PZEV Credits after Model Year 2017
I would support that same discount factor be applied for both LVM
and IVM. How can you prevent a transfer of PZEV balance credit from
a LVM to a IVM and get a better value and then trade the credit
back to LVM?

1962.1(g)(5)(A)
ZEV credits for Transportation Systems

I would suggest the elimination of additional credits for the
transportation project obtained from AT PZEV and PZEV from 2012 and
later, since it seems that no OEMs have participate directly for
these vehicles. These vehicle technologies have been in the market
for a long time and should be phrased-out.

1962.1(g)(6)(A)
Use of NEV credits
Allow up to 50% NEV credits to meet TZEVs and AT PZEV credits for
2012 – 2017.
I think that allowing NEV credits to meet up to 50% of TZEV credit
requirements is too high, it should be reduced to just at 25% level
to encourage the growth of this TZEV technology sector.

1962.1(g)(6)(B)
Carry forward provisions for LVMs for 2009 – 2011 Model Years
There may have to be clearer language to indicate that this
provision sunset after 2011 Model Year.
 
1962.2(d)(5)(A)1.
A ZEV with less than 50 miles UDDS range will receive zero
credits.
A NEV with 25 mile range can receive 0.15 ZEV credit. However, for
another BEV that travels between 26 miles to 49 miles will receive
no credit at all? Shouldn’t it be fair that this BEV receive some
credit above what a NEV would get? 

1962.2(d)(5)(E)
Counting Specified ZEVs Placed in Service in a Section 177 State
and in California
CARB should encourage the early deployment of FCVs by encouraging
that only after a minimum level of FCV in the North East Region /
177 State before any excess credits can be traveled. The minimum
level should also account for the placement of the battery electric
vehicles. In short, only after the minimum quantities of BEVs and
FCVs, that any excess FCV credits can be traveled.

Capping maximum aggregate reduction of required mandate to ensure
no blackout period
Proposed reduction sources:
•	up to one-tenth from transportation credits
•	up to 50% from Type 1.5X & Type IIX
•	up to 50% reduction from GHG Overcompliance
•	Allow usage of banked credits - up to 50%?
•	allow usage of converted credits from PZEV, AT PZEV or NEV - up
to 25% for the TZEV portion;

I would suggest that all mitigation credits should not reduce the
current mandate by an aggregate to a maximum of  50%, both for the
ZEV and TZEV portions.

Yours truly,

Yuli Chew
A Member of CHMM (Certified Hazardous Material Manager)