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Comment 129 for Proposed Advanced Clean Cars II Regulations (accii2022) - 45 Day.

First NameMichael
Last NameChiacos
Email Addressmchiacos@cecmail.org
AffiliationCommunity Environmental Council
Subject100% ZEVs by 2030 needed to meet our climate goals and provide ZEV equity
Comment
Dear Chair Randolph and CARB Board Members,
 
Community Environmental Council is generally supportive of the Advanced Clean Cars II proposalHowever, the Clean Cars II staff proposal does not sufficiently accelerate the ZEV market in California. Please review our attached analysis that provides evidence for the following points: 
 
  • CARB should set a standard of 100% ZEVs by 2030. This is needed to reach 8 million ZEVs, which are needed to achieve California’s 40% reduction in GHGs by 2030 goal. 

     
  • The staff proposal of 68% ZEVs by 2030 leads to only 5 million ZEVs. This jeopardizes California reaching our climate goals, and may trail automaker ZEV commitments, risking oversupply of credits, as is occurring now. This could reward ZEV laggards and punish ZEV leaders.   
  • Accelerated ZEV targets would yield higher equity results for low-moderate income Californians, who are severely burdened by the high cost of gasoline. They would also more quickly reduce air pollution in Disadvantaged Communities. Lower income Californians need higher ZEV targets so affordable used and leased ZEVs are more quickly available, giving them an alternative to high gasoline prices. 
CARB has the power to set ZEV targets beyond what the market is already doing. California is trailing Europe and China in ZEV adoption, and many automakers have already set 100% ZEVs by 2030 goals. Tesla and other ZEV-only automakers are already there. Norway has gone from 5.6% ZEV sales in 2013 to 92% ZEV sales in 2022. 
 
California has 34-ZEV related manufacturers and 360 ZEV-related companies ZEVs have grown from zero exports to in eight years being California’s largest export, according to the Governor’s Office at $5.6 billion in value in 2020. California should take a leading stance and set a 100% ZEV by 2030 goal.
 
Sincerely,
 
Michael Chiacos
Director of Climate Policy
Community Environmental Council
Santa Barbara, CA

Attachment www.arb.ca.gov/lists/com-attach/439-accii2022-AGNVNgRmV1sKb1U6.pdf
Original File NameCEC comments on Advanced Clean Cars II Final.pdf
Date and Time Comment Was Submitted 2022-05-31 16:19:12

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