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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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