Dear Board,
First, let me say thank you
for your much appreciated efforts to minimize both greenhouse gas
(GHG) and criteria pollutant emissions from the transportation
sector. Future generations stand to reap ample benefit from
your work.
I am aligned with your
mission to attain net zero / near net zero emissions from the
transportation sector. I however strongly encourage you to
include renewable fuel internal combustion engine vehicle (ICEV)
technology as an important enabler for your goals. In my own
personal and professional studies of the last 15 years, I continue
to come across increasing evidence that pursuing a mix of clean
transportation solutions and not just battery-electric alone will
lead to greatest environmental, economic, and geopolitical
sustainability. I am concerned that mandating
battery-electric vehicles (BEV) sales to a near all-encompassing
extent will create a host of issues, which include:
- Increase in adverse
environmental impact during vehicle manufacturing, especially for
battery manufacturing
- Stressing beyond capacity
aspects of the environment which are adversely impacted by battery
raw materials extraction
- Political conflict which
may arise from overreliance on battery raw materials which can only
be sourced from certain world regions
- Permanent reduction in the
portion of the workforce which depends on automobile production and
servicing; here I will note that because BEVs do not use as many
parts as ICEVs, and because these parts power jobs, a net reduction
in jobs tied to the auto industry will prove inevitable if a near
full transition to BEV is mandated
- The decimation of the U.S.
biofuels industry, an industry which would otherwise be poised to
greatly assist in bringing to fruition your net zero GHG emissions
goals
- Exacerbation of personal
financial hardship due to BEV battery degradation and this leading
to lower BEV resale value than that of a comparable
ICEV
As a means to help protect
against some of these issues, I strongly encourage you to adopt
regulations guided by life cycle assessment (LCA) emissions
analysis. Unlike regulations which only consider tailpipe
emissions, LCA based regulations account for the full scope of
vehicle environmental impact. To only focus on tailpipe
emissions is to discount very important big picture environmental
factors such as the carbon net negativity offered by ICE renewable
fuels production, adverse environmental impact of BEV and battery
production, and adverse environmental impact of electricity
production for BEV propulsion.
In considering the net carbon
neutrality capabilities offered by the utilization of ICE renewable
fuels, the ability of modern ICE emissions controls to attain near
zero emittance of criteria pollutants, and the likely
underestimated adverse environmental impact of BEV manufacturing
and electricity generation required for BEV propulsion, I strongly
recommend against broad sweeping BEV mandates which may not
adequately anticipate certain consequences of such mandates.
I again strongly encourage the Board to empower of the use of
modern renewable fuel ICE technology for the benefit of our
communities.
Thank you for considering my
message, and thank you for your continued commitment to protecting
so much of what the people of California, CARB states, and the U.S.
have come to cherish.
Kind regards,
Brian Kalina