Comment Log Display

In summary, the
following comments are filed:
 
• CARB has a statutory requirement
to minimize leakage when considering the AB 32 Climate Change
Scoping Plan Update and needs to address the carbon intensity of
BEV battery manufacturing (Slide 2 of Today’s
Presentation)
 
• CARB has a statutory requirement
to support cost-effective and flexile compliance when considering
the AB 32 Climate Change Scoping Plan Update, where heavy-duty ZEV
provides neither. (Slide 2 of Today’s Presentation)
 
• CARB should include BEV Battery
Manufacturing Emissions into the LCFS since the core tenets of the
LCFS are based on life-cycle analysis.
 
• When modeling for Transportation
Demand for ZEVs and Energy Demand by Fuel Type, the carbon
intensity of the BEV batteries should be based on an honest
life-cycle analysis referencing the European Studies.
 
• Modeling the 4 scenarios does not
even mention RNG, while keeping diesel use around for decades.
 
• CARB’s Environmental
Justice Advisory Committee should be briefed and provide input on
the forced child labor in the Democratic Republic of the Congo and
review Amnesty International documents on the serious human rights
violations linked to the extraction of the minerals used in
lithium-ion batteries. The EJAC should consider the extraordinary
volume of water and resources used to mine rare minerals for the
car’s BEV, and the environmental degradation the BEV car
imposes on people outside of California on the people of Africa,
China, South America, and first nations people of Canada. CARB will
be hosting the EJAC on March 30, 2022, where we plan to present
this information in more details with references.