Comment Log Display

The ACC II
regulations will be a major component of the CARB’s Scoping
Plan which was
released for public comment on May
10.   
 
Unfortunately, the ACC II rules as proposed will not
enable California to achieve its climate goals as proposed in its
draft Scoping Plan. 
 
To its
credit, the Scoping Plan does provide numbers showing what
reductions must be reached to achieve these goals.  However,
the Scoping Plan must rely on regulations like ACC II to achieve
its numbers.
 
The draft
Scoping Plan includes a  spreadsheet, based on the PATHWAYS
model, which includes numerous tabs showing numbers projected by
year through 2045 for numbers of electric vehicles, gasoline and
diesel emissions, Vehicle Miles Traveled, and
more.  
 
The Scoping
Plan/PATHWAYS spreadsheet’s ambitious aim is to reduce
Transportation emissions from 152 Million Metric Tons (MMT) to 86
MMT by 2030, ie. a cut of 77 MMT.  However, based on the
calculations shown in this letter, the assumptions of the Scoping
Plan and the proposed ACC are only likely to achieve 47 MMT
reductions for a likely total of 116 MMT emissions, i.e. 30 MMT
short of the goal of 86 MMT.  
 
How many
EVs is CARB predicting for 2030?
 
This is an
important question.  The ability of CARB to reach its climate
goals depends on getting this right.  
 
The
Mobile Source
Strategy dated October
28, 2021 estimated that there would be 8 million EVs on the road in
2030.  (page 95)   This number is also shown in the
slides prepared for CARB’s
presentation on June 10, 2021.  I’m not aware that CARB has
backed off from that number in any written document.
 
However,
the PATHWAYS spreadsheet for the Scoping Plan is only showing 4.8
million Battery EV (BEV)  + Plug in Hybrid EV (PHEV0 + Fuel
Cell EV (FCEV).  And the Scoping Plan itself references the 5
million EVs (page 29), but doesn’t specify any
goal.
Based on
the calculations shown below, California cannot reach it’s climate goals without
reaching 8 million EVs on the road in 2030.   
 
 

How can the
necessary reduction be achieved?   
 
The four
ways the 77 MMT reduction could be achieved are 


Conversion to Electric Vehicles (EVs) and
Zero Emission Vehicles (ZEVs)


Reduction in Vehicle Miles Traveled
(VMT), 


Biofuels (diesel only)


Fuel Efficiency

 

Conversion to EVs/ZEVs
 
The PATHWAYS spreadsheet shows a drop in Internal
Combustion Engine Vehicles (ICEVs) by 3 million by 2030 (LDV
tab).  This would reduce about 13 MMT of GHGs
(calculation:  3 million cars x 13000 miles each / 25
mpg  x 19lbs CO2/gal / 2200 lbs/MT = 13 MMT)
The MDV and HDV stocks tabs (Medium and Heavy Duty
Vehicles) show about 200,000 fewer ICEV trucks.  This is about
10% of the 2 million trucks.  10% x 28 MMT emitted by trucks
(from the spreadsheet) = 3 MMT reduction.  
 
Total =
16
MMT
 
This number could be increased significantly by
increasing adoption of EVs, including required phase out of ICEV
sales by 2030.  CARB’s Mobile Source Strategy estimated
8 million EVs by 2030 compared to the PATHWAYS spreadsheet total of
4.8 million.  An extra 3 million EVs replacing ICEVs would add
another 13 MMT reduction.  This is discussed more
below.
 
Vehicle Miles Traveled (VMT)–The
Scoping Plan assumes, “VMT per capita reduced 12% below 2019
levels by 2030” –page 58.  If we assume a slow
0.5% per year population growth, (I don’t see a number in the
Scoping Plan or the PATHWAYS spreadsheet for their estimate of
population growth), a 12% per capita VMT reduction over 11 years
results in about 6% decrease in total VMT, i.e 6%
x 165MMT =  10MMT.   
The PATHWAYS preadsheet shows a more aggressive
reduction in VMT for Alternative 3–17% for light duty
vehicles from 2021 - 2030.  Again, if we assume about 0.5%
population growth for 2021- 2030 , then the actual VMT reduction
would be 17-5=12%.  This would give a total reduction in GHGs
of 165 x 12% = 20 MMT.  
 
What about fuel efficiency? 
The Scoping Plan
is silent on this topic.   However, the federal CAFE
standards are proposing that new cars improve MPG by about 10 mpg
by 2026.  This
would bring the average for new cars up to about 36 mpg, but
doesn’t affect all the existing cars on the road.  In
other words, even if all new cars average about 36 mpg from now to
2030, that only improves the overall average by about 5
mpg.  
If half of the cars average 36 mpg (.028 gal/mile) and
the other half average 25 mpg (.04 gal/mi), the overall average
would be .034 gal/mi = 29 mpg.  This would be a fuel reduction
of (.04 - .034)/.038 = 16%.   16% x 112 = 18MMT  
If California is able to adopt stronger fuel efficiency
regulations, this number could be improved.
 
Biofuels--These only apply to MDV and HDV. 
According to the Mobile Source
Strategy,(page 137),
the Low Carbon Fuel Standard program aims for 20% reduction in
Carbon Intensity of truck fuels. Using 28MMT for diesel emissions,
this would be 6 MMT reduction, but this includes 3 MMT from the ZEV
trucks discussed above, so the biofuels actually contribute
3 MMT reduction. 
Also, critics have pointed out that such large scale biofuel
production will seriously strain production of soybeans–is it
realistic?  And bio-diesel is still a pollution
problem–both in production and combustion.
 
Here is a summary of these reductions, which are shown
in Table 2 above:


Fewer ICEVs (including cars & trucks)


16
MMT


VMT reductions  





10
MMT 


Fuel efficiency






18
MMT


Biofuels        3 MMT


Total








 
47
MMT
 
47 MMT in
likely reductions is 30 MMT short of the 77 MMT shown in Table 1
for reductions from Transportation.  Note that the VMT
reduction is based on numbers in the Scoping Plan; the PATHWAYS
spreadsheet number is 10MMT more aggressive than the number in the
Scoping Plan.
 
What needs
to be done?   
 
The intent
of this comment is not to say that it is impossible for California
to achieve its necessary GHG reductions.  Rather, the intent
is to urge adoption of concrete plans to achieve the
reductions.  CARB’s ACCII regulations can do just
that.
Here are
some of the actions needed in the Transportation
sector:
 


Phase out the sale of ICEVs by 2030. This
would mean 8 million EVs on the road in 2030 and would add another
13 MMT in GHG reductions.


Support individuals and companies in
working from home, including subsidies for home offices or
workspaces near home.  2020 showed that VMT could be seriously
reduced if people work from home.  This calculation–
https://docs.google.com/document/d/1IVM6lpiJ13D2-PVgMJm15R9L2vnDRmvPfX3RWWC3cEk/edit–shows
that a 10% per capita VMT reduction is possible with continued
working from home. Combined with funding for transit and active
transportation, this could make the high VMT reduction estimate
from the spreadsheet valid–i.e. 20 MMT reduction instead of
10 MMT as projected by the Scoping Plan..   


Incentivize heavy gasoline users to convert
to EVs (e.g. AB 2816).  This calculation
–https://docs.google.com/document/d/1ddP2AoVFNN9nz-IArfwUtAIRnWU-jiWT3BOmKhXcFFM/edit–shows 
that making sure that heavy users receive priority in subsidies to
convert to EVs could be the equivalent of 2 million more EVs, i.e.
another 9 MMT reduction.  Even though AB 2816 stalled this
year, CARB could make this regulatory change without
legislation.


Make sure that high speed chargers are
plentiful along all major highways and in older urban areas near
housing without off-street parking.  This will eliminate one
of the main concerns that deters EV purchases.  Caltrans
should consider such installations as part of infrastructure
improvements, i.e. part of the its $17 billion budget.


Provide low cost loans, financed by revenue
bonds, using Tariff-on-bill-financing (SB 1112) to ensure that
anyone buying an EV will have a place to charge at their home,
including multi-family dwellings.


Simplify subsidy and incentives delivery
(SB 1230) and generally promote EVs in a very public
way.


Steps 1 - 3
would add 13 + 10 + 9 = 32 MMT reductions bringing the total for EV
plus VMT  reductions to 45 MMT
Steps 4 - 6
and more like them will help spur the market to achieve rapid
adoption of EVs, potentially increasing the reductions from steps 1
- 3.   
 
These steps
would overcome the 30 MMT shortfall in reductions shown in Table
2.     
 
The
scientific reality is that the 40% reduction by 2030 is too slow to
avoid catastrophic climate disruption.  The IPCC estimates
that we need at least 50% reduction by 2030.  And many
scientists are calling for 80% reduction by 2030.  With this
in mind, achieving the 40% goal in the Scoping Plan is only a step
in the right direction, not a complete solution.
 
Conclusion
 
Calculations based on assumptions from the Scoping Plan
and PATHWAYS show that the Transportation sector will not achieve
the reductions needed to achieve California’s climate goals.
However, accelerating the transition to EVs, along with other
measures to reduce Vehicle Miles Traveled can overcome this
shortcoming.   
 
The Scoping
Plan is an ambitious and important document.  It lays out what
California would need to achieve in terms of GHG reductions to meet
State goals.  What is missing is a concrete plan with
calculated projections to achieve the goals.  This is where
the ACC II regulations need to step up to fill that
need. 
 
The
attached file includes graphics and tables that could not be
included in this comment form.