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Comment 4 for Comments associated with the 2010 ZEV Regulatory Changes (2010zev-reg-ws) - 1st Workshop.


First Name: Sigmund
Last Name: Gronich
Email Address: sigmundgronich@aol.com
Affiliation:

Subject: Revised ZEV mandate
Comment:
For years the ZEV mandate was ahead of the technology.  Now it is
in concert with industry plans to deploy tens of thousands of
vehicles by 2015 to 2017.  Yet the plan is not to change the
current ZEV mandate from 2015 to 2017 which allows for 25,000 ZEVs
to be substituted by some 85,000 PHEVs.  It is critical to get to
50,000 ZEVs with potentially 30,000 to 40,000 HFCVs so that there
is a robust infrastructure in place (i.e., 30 to 40 1000kg/day to
1500kg/day stations).  Just the uncertainty of how many HFCVs will
be deployed can have a negative impact on station commitments. 
This is the MOST CRITICAL ZEV mandate time as it allows the
industry to begin to think about volume production and quite
frankly subsequent vehicle deployments will be quite dependent on
market conditions that are difficult to project at this time. So If
the staff is unwilling to open up this critical time period,then at
least require more PHEVs to offset the true ZEVs or increase the
25,000 minimum to 40,000.

While I agree that it is important to then mandate another
increase in the number of vehicles there has to be a rational limit
to a mandate that can potentially violate market conditions.  These
vehicles will be reliable and performance stars, but they are going
to be more expensive than gasoline vehicles and as such the price
of gasoline needs to be greater than today. Japan, Europe and Korea
may be better places for the technology to be deployed because of
their greater fuel prices.  All of this will impact the cost of the
vehicle.  I don't believe it is fair for government to edict what
is not market ready when we get to very large production numbers. 
So that is why the 2015 to 2017 period is so critical to do at a
level of ZEVs that can show where both the infrastructure and
vehicle really are and have a policy to go from there as part of an
international program and compatible with market conditions.

I recently presented a paper on this subject at the NHA meeting
and am attaching both the paper and the presentation for your
consideration.    

Attachment: www.arb.ca.gov/lists/2010zev-reg-ws/4-are_battery_electric_vehicles_more_cost_effective.doc

Original File Name: Are battery electric vehicles more cost effective.doc

Date and Time Comment Was Submitted: 2010-05-11 10:24:34



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