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Comment 3 for Advanced Clean Cars II Rulemaking (accii-comments-w3-ws) - 3rd Workshop.


First Name: Vanessa
Last Name: Warheit
Email Address: vwarheit@gmail.com
Affiliation: EV Charging Access for All coalition

Subject: Additional Comments
Comment:
Here are some additional comments based on today's workshop:

1) Do not wait until 2026 to begin the EJ credits programs. Put
these in place ASAP.

2) Do not use EJ credits to lower standards - this pits the climate
issue against the imperative to address structural inequities.
Maintain strict standards! Use some other incentive for EJ.

3) Include fleets in your incentive structure. Rental car fleets in
particular need to be incentivized to electrify.

4) If NEVs no longer count toward OEM compliance, how will CARB
ensure that NEVs continue to be electrified? This is particularly
important for city 'meter maid' parking vehicles.

5) Lower the minimum range for compliance to 100 miles EPA rating.
(As one example: our family has a long-range EV that we purchased
new, and we are now in the market for a cheaper, short-range used
EV as a second car, for which a 100-mile range is plenty.) If the
mass market is pushing OEMs to create longer-range vehicles, it's
extra important for CARB to ensure cheaper/lower range vehicles
continue to be manufactured to serve lower-income drivers.

6) Mimicking the EU's limit of 150 GWP for refrigerants is not
aggressive enough and based on out of date data. That EU law has
been in effect since 2017; today there are many refrigerants on the
market with GWP below 10.

Thank you for taking these comments! 

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Date and Time Comment Was Submitted: 2021-08-11 17:54:29



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