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Comment 220 for 2022 Climate Change Scoping Plan (scopingplan2022) - Non-Reg.
|Subject||EV embodied CO2e|
I want to elevate EJAC for their
exceptional testimony yesterday. Please listen to them.
True Sustainable transportation is
electrified rail transit for all and Active transportation plus
micromobility for all. Everything else is stumbling towards
failure. This scoping plan
intentionally ignores Life Cycle Assessment to avoid double
counting of emissions.
This is a very dangerous methodology that
allows long range, luxury cars SUVs and trucks to be called zero
emissions. The very significant impact of EVs, will largely be from
materials mining and production emissions.
According to Volvo’s own Impact
report its electric C40 Recharge still has 27 tons of emissions
even if it is always charged with 100% renewable energy. But those
embodied emissions occur elsewhere, so CARB has been and will
continue to label EVs erroneously as zero emissions. Reducing
emissions by only 54% with EVs is not what any of us expected.
That model is
completely unsustainable in 2050 under zero carbon. We cannot
ignore the impacts a constantly replaced EV fleet will continually
Elon Musk has admitted that Tesla is losing
billions of dollars as we speak because the resources needed to
make EVs don’t match industry’s aspiration to build
them. That is the reality of EVs not being a sustainable choice
even in these early days of adoption.
|Original File Name|| |
|Date and Time Comment Was Submitted|| 2022-06-24 10:58:20|
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