Comment Log Display

The Staff Proposal creates an “either/or” scenario between ZEVs and
Enhanced AT-PZEVs that we find very disconcerting because it
creates the appearance of “selling out” one technology for the
other. While the near-term market potential may be different, only
the market should determine to what extent each is successful. We
therefore propose specific treatment for each category, as well as
general suggestions for the program.
 
1)  HOLD FIRM ON “GOLD” ZEV NUMBERS - Staff’s proposal notes that
the 18-year history of the ZEV Program has yet to make ZEVs
commercially available- reducing the number of ZEVs required yet
again will not accomplish this goal. 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, like Tesla. Worse,
the lower numbers ensure that ZEVs will never leave hand built
production volumes, and that costs will remain too high for
commercial viability. 
 
We therefore ask that CARB hold firm on the current 25,000 ZEVs
required in Phase III, and 50,000 ZEVs required in Phase IV. These
are the numbers previously committed to by automakers, and are
appropriate to bridge the gap between R&D and commercialization. 
 

2) ENHANCED AT-PZEVs -  these enhanced vehicles are incredibly
promising, both for their ZEV-enabling properties, and for the
near-term air quality benefits. Several automakers have expressed
their enthusiasm for these vehicles, with at least two models
committed for production during Phase II. However, these vehicles
should not come at the expense of ZEVs, and merit requirements of
their own to support their commercialization. 
 
a) PZEVs NEED TO GROW UP - 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. 

 

As noted above, PIA understands 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. 

 
b) PHEV DEFINITION METRICS- We strongly encourage the Board to
reconsider defining and crediting Plug-in Hybrid Vehicles (PHEV)
by a more straightforward metric such as kWh (either onboard or
net usable) rather than miles. 

 
Using kWh provides more flexibility to the automakers to build
PHEVs in both propulsion configuration (serial, parallel, etc.)
and body style what they think will sell in the marketplace and
will result in more overall cars on the road. Because a kWh of
electricity offsets roughly the same amount of petroleum in a
large vehicle as a small one, it is more important to encourage
maximum electrification of all vehicles more than any one
particular vehicle.  Defining by miles unfairly biases toward
small PHEVs, and will result in more similar vehicle models
competing for the same market share, while providing few options
to the significant segment of CA consumers who want a larger
vehicle. Using this metric will still encourage smaller, more
efficient vehicles because they are more cost-effective to build,
but also rewards manufacturers who choose to electrify larger
vehicles.  

 

c) BATTERY WARRANTY –We recommend a temporary reprieve in this
requirement for PHEVs using lithium batteries only, in order to
encourage automakers to commercialize vehicles sooner. The
following warranty schedule still provides sufficient consumer
protection and ensures a low emissions profile for a reasonable
amount of time. 

 
Phase II:   Five (5) years/ 60,000 miles

Phase III: Seven (7)/100,000 miles

Phase IV: Ten (10)/150,000 miles

 

3)BACKFILLING- Plug In America 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.
 
 However, to the extent that CARB is wedded to the idea, we
propose raising the bar on both the quality and number of vehicles
required to backfill:
 
Only PHEV20s or better can backfill (PHEV10s can still get credit
in Silver) 
Enhanced AT-PZEVs of any kind would backfill at half the credit
they would otherwise earn in the Silver category. 
 
This would result in roughly 5-6 Enhanced AT-PZEVs for each ZEV
instead of only 2-3, providing compliance flexibility for
automakers while still encouraging development of ZEVs. 
 
Additionally, to the extent that EAER must be used (again, we
prefer kWh over any mileage metric), we request that CARB base
evaluations on the US06 test cycle, not UDDS, which again favors
vehicles “blended” at lower speeds and doesn’t represent “real
world” driving. 
 
 
 
 
4) PUBLIC FLEET REQUIREMENTS- 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
the reader against plug-in vehicles. We are watching this trend
with increasing alarm since these flawed assumptions are appearing
in a variety of documents relating to various ARB regulations. The
two technologies need to be evaluated on an even economic playing
field. 
 
6) TRAVEL PROVISION – Plug In America 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 – Vehicles in the ZEV Program should be
defined and credited  based on their overall energy efficiencies
using a wells-to-wheels or lifecycle analysis. We encourage the
Board to look toward the future by considering overall efficiency
today.