Comment Log Display

RAN Response to the California Air Resource Board’s “Staff
Proposal: Initial Statement of Reasons” for the Zero Emission
Vehicle Program

Rainforest Action Network (RAN) has reviewed the "Staff Proposal-
Initial Statement of Reasons" and while it contains some
improvements to the Zero Emission Vehicle (ZEV) Program, we find
that the Proposal undermines the opportunity for ZEV regulation in
the state of California to bring the highest standard of pollution
and petroleum-free vehicles into the marketplace. 

First and foremost, RAN would like to see ZEVs prioritized above
Enhanced AT-PZEVs, and our recommendations are made in the spirit
of getting ZEVs into consumers' hands as soon as possible. Based
on our extensive conversations with automakers, we believe that
they are indeed capable of meeting strong regulations and the
highest bar for ZEVs in California. Given the escalating threats
of global warming, air pollution, and our dependence on oil, we
simply don't have time to wait.
 
1)  INCREASE “GOLD” ZEV NUMBERS - Staff’s proposal notes that the
18-year history of the ZEV Program has yet to make ZEVs
commercially available, and thus the current proposal calls for a
reduction in numbers of ZEVs required. Reducing the number will
reverse the likelihood that ZEVs will become commercially
available. The current proposal would require fewer an average of
140 ZEVs per year from any individual automaker until 2015- few
enough that several automakers can use banked credits for the next
decade to meet this requirement. Those with fewer banked credits
can easily accomplish these numbers through credit trading with
small automakers, such as Tesla. Worse, the lower numbers reduce
the likelihood that ZEVs will reach mass production and a viable
economy of scale. Or, if they do, it will occur outside of
California and may have no benefit for Californians, costing us a
priceless opportunity to lead the way into the new generation of
transportation technology.

We therefore recommend that California does not decrease, but in
fact increases the numbers of ZEVs required from the industry
under the Alternative Path for Compliance from 2,500 to 10,000 in
Phase II (2009-2011) and from 25,000 to 100,000 in Phase III
(2012-2014). 

2) RAISE THE FLOOR, NOT THE CEILING- To the extent that allocation
is taken from another category to make room for Enhanced AT-PZEVs,
it should be taken from the dirtiest category in the ZEV Program,
not the cleanest. While PZEVs have served as an air-quality
victory for the Program, they no longer need commercialization
support, and lend no ZEV-enabling value. Therefore, we propose
that the percentage of the Program requirements allowed to be met
by PZEVs be reduced to 4% in Phase III, 2% in Phase IV, and phase
out completely after 2018. In each Phase, the reduced PZEV
requirement would be transferred up to the Enhanced AT-PZEV
category, creating a stand-alone requirement for these vehicles
without distracting from commercialization efforts of true ZEVs. 

RAN agrees that PZEVs play an important role in achieving
California’s air quality goals. However, they don’t support the
specific goals of the ZEV Program; our proposal provides adequate
time for a PZEV requirement to be shifted to a more appropriate
program such as LEV III. 

3) DEFINING PHEV CREDITS- We strongly encourage the Board to
reconsider defining and crediting Plug-in Hybrid Vehicles (PHEV)
by kWh (either onboard or net usable) rather than miles. 

Using kWh provides more flexibility to the automakers to build
PHEVs according to what they think will sell in the marketplace
and will result in more overall cars on the road. Defining by
miles biases toward small PHEVs, while defining by kWh will still
encourage smaller, more efficient vehicles because they are more
cost-effective to build, but also reward manufacturers who choose
to electrify larger vehicles.  

3) BACKFILLING- RAN opposes the use of Enhanced AT-PZEVs to
backfill for any portion of the ZEV requirement and prefers to see
separate, appropriate requirements created for ZEVs and Enhanced
AT-PZEVs.

4) PUBLIC FLEET OPPORTUNITIES- While there is certainly retail
demand for ZEV and near-ZEV cars, fleets can play a significant
role in assuring a market for automakers compelled to build them,
as well as in producing air-quality results for the areas in which
they’re deployed. We therefore encourage CARB to consider requiring
public fleets to purchase ZEVs and Enhanced AT-PZEVs when available
and where practical for their intended use. However, because these
vehicles are purchased with public funds, we propose that fleets
must choose the most economical vehicle technology (lifetime cost)
for a given air-quality benefit. 

5) CREATIVE ZEV ECONOMICS- It makes sense for staff to consider
the economic impact of the regulation on the automaker, however,
citing 2003 battery cost estimates and projected 2012-2014 fuel
cell costs to determine the incremental cost of each technology
(ISOR, pg. 33) paints an inaccurate economic scenario that biases
against plug-in vehicles. The two technologies need to be
evaluated on an even economic playing field. 

6) TRAVEL PROVISION – RAN opposes any travel provision in
combination with decreasing the number of ZEVs required in any
phase. We are very aware of how this issue has been “gamed” in the
past, with vehicles being removed from service after a few years
and placed in another state for credit. However, sanctioning the
idea of building fewer ZEVs not only for one state, but eleven,
will not lead to the market-building volume that we need. 

7) EFFICIENCY MATTERS – California should incentivize ZEVs based
on their overall energy efficiencies on a well-to-wheels or
lifecycle basis, and not consider vehicles alone, divorced from
energy production. Incorporating overall efficiency into
considerations today will prepare us for the time when both
vehicles and some energy sources will be zero-emission, and ZEV
choices will be based on efficiency, economics, and other
considerations.

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Founded in 1985, Rainforest Action Network campaigns for the
forests, their inhabitants and the natural systems that sustain
life by transforming the global marketplace through education,
grassroots organizing, and non-violent direct action. For more
information visit www.ran.org.