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Comment 220 for 2022 Climate Change Scoping Plan (scopingplan2022) - Non-Reg.

First NameKarl
Last NameAldinger
SubjectEV 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 demand, perpetually.

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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