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Comment 3 for Public Workshop on the 2022 Scoping Plan Update – Initial Modeling Results Workshop (sp22-modelresults-ws) - 1st Workshop.


First Name: Evan
Last Name: Edgar
Email Address: evan@edgarinc.org
Affiliation:

Subject: ZEV are not Zero Emissions but are plus 62.52 to 90.64
Comment:
ZEVs are not Zero Emissions but have a Carbon Intensity of 62 to 90
(gCO2e/MJ) 
ZEVs are not zero greenhouse gas emission vehicles but have a
carbon intensity of 62 to 90 (gCO2e/MJ) when combining the energy
required to produce electricity to charge the battery and the
manufacturing process of the battery. CARB's existing emissions
factor, which accounts for the energy required to produce the
electricity the charge the battery is 23.39 (gCO2e/MJ). The range
of emissions from the battery manufacturing alone, assuming a
100,000-mile lifespan, have a carbon intensity of 38.13 - 66.26
(gCO2e/MJ) depending on the type of ZEV battery. 

AB 32 Climate Change Scoping Plan Statutory Requirements is to
Minimize Leakage
ZEV batteries that are manufactured out of state are increasing
non-Californian emissions in other states and countries in the
amount of 38.13 - 66.26 (gCO2e/MJ) depending on the type of ZEV
battery.  CARB is picking ZEV as the technology winner while
leaking emission out of state.

Environmental Justice for All? 
CARB Should Not Exacerbate Harm to Disproportionately Impacted
Communities 
Cobalt is mined by forced child labor in the Democratic Republic of
the Congo. Think about the extraordinary volume of water and
resources used to mine rare minerals for the car's Battery Electric
Vehicle (BEV). Amnesty International has documented serious human
rights violations linked to the extraction of the minerals used in
lithium-ion batteries. Think about the environmental degradation
the BEV car imposes on Mother Earth, outside of California on the
people of Africa, China, South America, and first nations people of
Canada. The Environmental Justice Advisory Committee should be
briefed and provide input on this topic.




Attachment: www.arb.ca.gov/lists/com-attach/4-sp22-modelresults-ws-VTZRNlAjUGFRCFIo.pdf

Original File Name: CARB ZEV Modeling AB 32 Scoping Plan Final Draft.pdf

Date and Time Comment Was Submitted: 2022-03-23 21:11:00



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