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Please refrain from using the term "ZEV" or, at the very least,
refrain from blanketly including electric vehicles in your
definition.  The California Low Carbon Fuel Standard is a complete
well to wheel GHG emission program.  The California power grid is
far from zero emissions (even if you exclude all the uncontrolled
burn emissions from forest fires caused by downed power lines). 
Electricity from the California power grid is the baseline source
of fuel for most electric vehicles and thus, they are not "zero
emission vehicles" per the very foundations of your policy.  

If CARB wishes to include some electric vehicles in this
definition, it should limit the vehicles to only those using
hard-wired renewable power to refuel their vehicles as per CARB
guidance on the use of renewable electricity.  

I have doubts that even the vehicles mentioned above should qualify
as a ZEV as GHG emissions from battery production and the
production of solar panels are also not "zero emission" but I will
concede that one could interpret those as outside the scope for
"fuel" within LCFS policy but CARB should further give guidance
that the materials used to generate, store, or utilize fuel are
outside the scope of the AB 32 policy.

CARB could choose to change this definition to zero tailpipe
emission vehicles but it should refrain from using the "ZEV"
acronym which is marketing tool for electric vehicle manufacturers
and irrelevant to a well to wheel GHG emission policy.  It is
confusing to LCFS stakeholders and general population.