Comment Log Display

These comments have been submitted on-line as part of the record
for this meeting and for the current review of the ZEV mandate
that has apparently been requested by the Auto Manufacturers'
Alliance (AAM).

If you accede to AAM requests to let them out of their prior fuel
cell production commitments, it can never be undone; there will be
only further requests later on.  

Mercedes Benz testimony for this meeting is that they will produce
100,000 fuel cell ZEV by 2015; if so, there is no need to lower
standards.  

Stand fast.  No change is required; AAM can always return to
proven, reliable battery EVs.  If the Board allows them to give up
on fuel cells now, their commitment in the future will only get
weaker.  

AAM has always asked to be released from their obligations, and so
far always won.  This consistent record of regulatory failure must
be halted if our greenhouse gas reduction targets are to be met. 


The tailpipe of each Internal Combustion vehicle extends to the
oil refinery needed to make their fuel, and beyond, to the
electric wellhead pumps, oil tankers, oil drilling platforms,
foreign oil diplomacy and wars.  

Each ZEV has the dual benefit of reducing stationary and mobile
source pollution.

Moreover, if battery plug-in ZEV are for sale on the free market,
the avoided cost of gasoline can finance each driver's solar
rooftop system, enabling them to drive clean while helping
stabilize the electric usage curve.


1.  2003 RELIANCE ON FUEL CELLS WAS A MISTAKE p. 3

The 2000 Battery Assessment Workshop estimated the cost of the
battery for an EV at no more than $10,500.  Compared to fuel cell
vehicle cost of up to $1 million, and the attendant cost of
producing technical-grade hydrogen and specially-treated
high-pressure tanks, that now seems a bargain.  

AAM consistently ignored customer demand for battery EVs, and are
continuing to do so, particularly considering the recent oil price
increases.  Loss of a proven technology was a mistake then and now.
 AAM must either produce the fuel cells it promised, according to
the schedule they agreed to in 2003, or return to battery EV
production.  

No questionable breakthrough research is needed for battery EVs. 
Highly reliable Toyota RAV4-EV, HondaEV and GM EV1 were, and are,
proven and successful only because ARB once enforced the ZEV
mandate.  

Giving up now would be a slippery slope of future surrender.

2. STAFF PROPOSAL WEAKENS ZEV MANDATE p. i

Staff was charged with not weakening the "overall objectives" of
the (ZEV) program, which they are interpreting as retaining 2018
as the date that there will be a sudden return to ZEV production. 


As this date approaches, the idea of a miraculous surge, a sudden
conversion, becomes more and more unlikely.  ARB has always
acceded to AAM requests to rework ZEV; this proposal continues
that tradition by lowering the number of ZEV produced.  This idea
must be rejected.  Hold AAM to the agreement made in 2003: 
produce either fuel cells or battery EVs.

3. GRANT ZEV CREDIT ONLY FOR SALE, NOT LEASE p. 6

There were 43,726 ZEV gold credits granted for only 4,560 ZEV
vehicles, of which 4,400 were battery EV "placements".  The vast
majority of ZEV were Battery EVs.  However, almost all of them
were taken off the road and crushed.  This gives the appearance of
bad faith on the part of AAM (other than Toyota, which did leave
its RAV4-EV in the hands of the public and in fleets).

There must be no ZEV credit granted for leases that allow this
sort of intransigence in the future.  There has been no
explanation for why AAM insisted on removing these clean air ZEV
from the hands of the public, then destroying them, and no
explanation for why GM and Honda could not follow the example of
Toyota, selling them to willing buyers.

The crushing of almost all of the ZEV fleet reflects poorly AAM as
well as ARB.

The staff report needs to be corrected to the actual number of
Battery EV on the road, not the sleight-of-hand number produced
and then crushed.  Like the vehicles themselves, the credits
should vanish and be crushed.

Henceforward, ZEV credit must only be granted for vehicle sales,
complete change of ownership to willing buyers, so that this sort
of misleading accounting does not recur. 

4.  STICK TO ORIGINAL (OR ALTERNATE) PATH

AAM promised, in 2003, to produce requisite numbers of ZEV
according to the relaxed schedule of requirements agreed to by
CARB at that time. The Auto Alliance had, and has still, the
option of continuing to produce proven BEV, or, as they claimed
was the easier path, produce smaller numbers of  fuel cell
vehicles. There is no reason, particularly in view of the Mercedes
Benz testimony about their planned production of fuel cells, to
relax standards.  Let them stick to their original commitments. 

5.  FUEL CELLS ARE THE DEAD END

AAM and ARB staff argued in 2003 that Battery EVs were a dead-end,
and that every dollar spent on BEV production took away from fuel
cell research, which, they claimed, was the ultimate goal.  Why
pour money into short-term Battery EV production that they claimed
was a dead end?

AAM and ARB gave up on what was then a proven technology, with a
fan club and thousands of BEV on the streets in the hands of
loving drivers, for what
now seems, according to the Expert Panel, to be an unrealistic
assumption.  

After 5 years of the "Hydrogen Fuel Cell Research", AAM is
requesting more time to pursue fuel cells. It may be that Fuel
Cell research is the dead end, and the ultimate standard be
Battery EVs. Sticking to the original agreement gives AAM more
chances to demonstrate fuel cells, but if they fail, they can go
back to selling proven Battery EVs. 

6.  ZEV REGULATIONS NEED SIMPLIFICATION p. 15 et seq.

The Board ordered staff to simplify the ZEV regulations; instead,
the proposed changes make them much more complicated.

The original ZEV mandate was simple: each zero-emission car is
counted as one ZEV, and only one.  By complicating the idea, the
Board risks obscurantism and loss of credibility.

The Board must return with the people to the plain idea of "one
vehicle, one ZEV", and reject the concepts of EAER, UFrcd, 4th
order polynomial fits, and arcane grants of ZEV credit which have
nothing to do with zero-pollution vehicles.

The public can understand that the Board is under pressure from
very powerful vested interests; if you have to surrender to them,
at least admit it, and stop using problematic terms such as
"partial zero emission."

Make ZEV regulations simpler, you don't have to agree with staff
proposals to complicate and mystify them further.

7.  Type F PHEV must do highway-speed in ZEV mode (p. 17)

Staff is requesting what amounts to replacement gold ZEV credit
for "advanced componentry allowance" on a new "type F" PHEV that
goes through the UDDS  FTP-72 test cycle for light vehicles
partially on "ZEV fuel," even if the vehicle's engine starts at
times.  The maximum speed attained momentarily on this cycle is
less than 60 mph, and most driving is stop-and-start at about 18
mph.  
http://www.dieselnet.com/standards/cycles/ftp72.html

So the plug-in Prius and the GM dual-mode hybrid pickup truck
would both get "ZEV credits" that displace real ZEV, even if the
driver never plugs in the car at all, under the theory that it
will "...encourage the deployment of higher battery capacity HEV
drive systems...[so that] costs can be shared...".

Staff report, p. 17 states these use "10 kW" of power, instead of
talking about how much all-electric range they have (kWh).   The
proposal creates a loophole ZEV credit for HEV that cannot run in
normal driving without an Internal Combustion (IC) engine.  The
electric motor is envisaged only an IC assist. 

This already assumes defeat of the ZEV mandate; such vehicles can
never be zero emission ZEV, they will always require gasoline for
the daily grind.

NO gold ZEV credits, or replacement credits, should be granted for
any vehicle that can't go at highway speed in all-electric mode. 
Such a vehicle, whether blended mode or serial hybrid, is
primarily an oil-fired vehicle, and should be restricted to Silver
or Bronze credits only. 

A plug-in hybrid awarded ZEV credits must have a demonstrated
range on ZEV fuel only of at least 40 miles at highway speed,
capable of being augmented with add-on battery packs for those
wishing to convert them to longer-range BEV. Features such as the
built-in routine to stop add-on battery packs on the Toyota Prius
should be prohibited and penalized.

ARB must make explicit the difference between plug-in serial
hybrids such as the proposed GM VOLT, which are just an EV with a
genset, and the so-called plug-in blended hybrids, like the
plug-in Prius and the GM "dual mode" hybrid pickup.  The latter
cannot go at highway speed in EV-only mode, so they are dependent
on gasoline.  The full-function serial hybrid can drive oil-free
if you go less than 40-, or 80-, or 160- miles, depending on the
size of the battery. 

This is, after all, the ZEV mandate, not the Internal Combustion
mandate.

Instead of weakening the ZEV mandate, the Board can, and must,
strengthen it in the recommended ways in order to meet our AB32
and AB1493 goals.