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Comment 144 for Draft 2022 Climate Change Scoping Plan (scopingplan2022) - Non-Reg.

First NamePaul
Last NameBroadway
Email Addresspjb92104@gmail.com
AffiliationIndependent
SubjectAssistance with a Neighborhood Electric Vehicle Registration
Comment

Greetings to the California Air Resources Board, I recently requested a waiver or variance to satisfy the requirement that the Neighborhood Electric Vehicle as defined by 2009 California Vehicle Code - Section 21250-21266 that I purchased was permitted by the California Air Resources Board as a Neighborhood Electric Vehicle.  The purpose of this waiver or variance is to satisfy the California Department of Motor Vehicle’s requirement for registration and licensing.  I have submitted many files, documents and photos regarding the purchase of this vehicle through the helpline@arb.ca.gov email address.  I spoke with Mr. John Swanton via telephone about my issue.  Mr. Swanton appeared to steer me away from owning my Neighborhood Electric Vehicle any longer.  He suggested that I stick the seller of this vehicle with a Neighborhood Electric Vehicle that has degraded absorbed glass matting batteries, due to sitting in my driveway for last 6 months.  I feel that this is a self-serving solution that is not fair.

 

 I have read Governor Newsom’s Executive Order N-79-20 in its entirety.  I believe that I understand it.  In that document, it does not state that I cannot order a Neighborhood Electric Vehicle online and have it delivered to my residence like any other consumer item.  The California Department of Motor Vehicle’s website does not prohibit this practice as well.  I have searched the world wide web and various state websites, I have never seen a list of approved Neighborhood Electric Vehicles.  Prior to purchasing this vehicle, I read:

 

•             California Senate Bill -1151 NEV.

•             SANDAG Regional Mobility Hub Strategy Plan

•             Civic Technologies’ White Paper on Neighborhood Electric Vehicles

•             South Bay Cities Council of Government’s Zero Emission Local Use Vehicles,

               The Neglected Sustainable Transportation Mode Report

•             California Governor’s Office of Planning & Research Zero-Emission Vehicles

  In California: Community Readiness Guidebook

•            Governor’s Office of Business & Economic Development California Zero-

  Emission Vehicle Market Development Strategy Plan

 

                   None of the above publications outlined the process for obtaining a Neighborhood Electric Vehicle.  None of these publications provided a list of approved Neighborhood Electric Vehicles.  These publications stated that a Neighborhood Electric Vehicle must have a 17-digit vehicle identification number.  They also listed the other requirements such as a top speed of 25 mile per hour and must have four wheels and weigh less than 3,000 pounds loaded.  I purchased this vehicle with the intention of using it as a last mile solution to the poor access that I have to public transportation and for local errands.  This vehicle is powered by electricity stored in six (6) 12 VDC absorbed glass matting batteries that supplies a 5kW electric motor.  This Neighborhood Electric Vehicle complies with Governor Newsom’s Executive Order outlining California's plan to electrify all vehicles by 2035 (N-79-20).

 

 The telephone conversation between Mr. Swanton and I on 27 May 2022 was distressing.  Mr. Swanton has caused me to lose confidence in my state government.  Mr. Swanton feels that the state of California has the right to impose arbitrary “policies” that I do not have access to; regarding my choice of Neighborhood Electric Vehicle.  I did everything right.  I exercised due diligence and researched my purchase.  I looked for, and did not find guidance from the state of California before, during, and after the purchase of this vehicle.    Governor Newsom’s Executive Order N-79-20 mandates in section 9, “The State Air Resources Board, in consultation with other State agencies, shall develop and propose strategies to continue the State's current efforts to reduce the carbon intensity of fuels beyond 2030 with consideration of the full life cycle of carbon.”  My understanding of this issue viewed under the lens of Executive Order N-79-20 would be to grant a waiver or variance.  A variance or waiver would allow me to register and utilize a vehicle that does not produce emissions.  Additionally, a waiver or variance would prevent further economic and environmental impact by allowing me to utilize a Neighborhood Electric Vehicle in place of an internal combustion engine powered vehicle.

 

Lastly, I am shocked that the state of California has not published a comprehensive website or FAQ that addresses consumer issues regarding Neighborhood Electric Vehicles.  Why would the California Air Resources Board not live up to its mission statement?  “CARB's mission is to promote and protect public health, welfare, and ecological resources through effective reduction of air pollutants while recognizing and considering effects on the economy. CARB is the lead agency for climate change programs and oversees all air pollution control efforts in California to attain and maintain health-based air quality standards.”   My only question is how can the California Air Resources Board justify preventing a California resident from transitioning to a carbon neutral vehicle from an internal combustion engine powered vehicle?  I thank you for your time.

   


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Date and Time Comment Was Submitted 2022-06-15 15:32:57

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