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Comment 42 for Proposed Advanced Clean Cars II Regulations (accii2022) - 45 Day.

First NameEllie
Last NamePeichel
Email Addressepeichel@pluginamerica.org
AffiliationPlug in America
SubjectACC II
Comment
  • Hello all. My name is Ellie Peichel, and I am a representative for Plug In America, a nonprofit organization that represents the voice of the EV consumer. Thank you for the opportunity to comment today on the proposed Advanced Clean Cars II program. 

  • As a key mechanism to increase EV uptake, address the climate crisis, and improve air quality, especially in historically underserved communities, it is imperative that ACC II be as strong as possible and designed with overburdened communities in mind. In pursuit of the most effective program possible, Plug In America offers three recommendations. 

  • We recommend that the Board raise the interim sales target for electric cars from 68 to 75% in 2030. Raising the ZEV requirement to 75% in 2030 is consistent with CARB’s own Mobile Source Strategy. 

  • Strong, interim sales requirements are critical to achieving Governor Newsom’s target of 100% electric car sales by 2035 and key emissions reductions goals.

  • We also recommend that the board include mandatory equity provisions that ensure automakers increase affordability and access to pollution-free cars in frontline communities. If equity provisions are optional, it can result in less EVs on the road specifically in frontline communities that bear the burden of climate and poor air quality impacts.

  • Our last recommendation is to direct staff in the Board Resolution to return in 2-3 years with a technical review and recommendations on the regulation for BEVs, strong plug-in hybrids and bidirectional charging in accordance with overall industry growth.

  • We thank the board for considering our recommendations to help create the most effective rule possible. We have the opportunity to make a huge impact in our local and global communities.. We have to take advantage of it.


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Date and Time Comment Was Submitted 2022-06-09 15:30:52

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