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Thursday, March 20, 2008 at 9:00 AM
The California Air Resources Board (CARB) is considering changes to the Zero Emission Vehicle Program (also commonly known as the "ZEV Mandate") (see Appendix A) on March 27th at its Board meeting in Sacramento. This is a big deal.
What is CARB?
The California Air Resources Board, or CARB, is a regulatory agency that sits under the California Environmental Protection Agency and regulates everything from air and water to transportation from an emissions standpoint and climate change legislation implementation like the Global Warming Solutions Act, AB 32 (text).
Quick History of ZEV Program
Shortly after GM launched the EV1 (GM page, Wikipedia, EV1 Club), CARB passed the ZEV Program, requiring that 2% of sales by automakers in California constitute zero emission vehicles by 1998, 5% by 2001, and 10% by 2003. The other big car manufacturers also developed electric vehicles in response to the ZEV Program. In 1998 CARB decided to allow cars other than pure ZEVs to count for ZEVs. In 2003 the ZEV Program changed again to be more complicated and weaker, delaying introduction of large numbers of ZEVs by until 2012 and beyond, and putting an emphasis on fuel cell vehicles over battery electric vehicles. Around the same time GM and all the other manufacturers canceled their electric vehicle (EV) programs in favor of fuel cell vehicles. In other words, the ZEV Program has had a tough history and has evolved from an extremely simple program to a very complicated one.
ZEV Program Today
Today the ZEV Program looks almost nothing like the original program. It is now very complicated, classifying vehicles into three types, allocating credits to each vehicle.
The ZEV Program, in short, is a regulation that requires major automakers to produce a certain number of ZEVs1 each model year in order to do business in California. Some of the credits may be met with vehicles that are not pure ZEVs, such as hybrids and plug-in hybrids, that include some advanced, low polluting components. The ZEV Program does not treat all vehicles equally; it gives fuel cell vehicles the most credits, then pure electric vehicles and plug-in hybrids, followed by a host of advanced vehicles like hybrids. The ultimate objective is to improve California air quality.
You can see the proposed staff changes HERE (known as the "Initial Statement of Reasons" or ISOR).
Our Recommendations
Google.org has been talking with Board Members, staff, and stakeholder groups to understand their perspectives on the proposed changes to the regulations. After meeting with them, we decided there are five recommendations relating to the proposed changes that we will submit to the Air Resources Board. Our hope is that when approved and implemented, the ZEV Program will accelerate innovation and reduce air pollution by getting large numbers of vehicles into consumers hands and on the road. We ultimately see this as a phenomenal business opportunity for the automakers. Californians are ready for more advanced vehicles like battery electric vehicles and plug-in hybrids. Once these vehicles become available, they expect them to take off just like existing hybrids have and they will help California simultaneously improve its air quality at a faster speed than traditional hybrids.
The following are our five recommendations:
1. Strengthen the newly proposed "enhanced AT PZEV" category to require a minimum capability to drive in pure electric mode for 25 miles, not the proposed 10 miles, to accommodate the commuting range of a majority of drivers and make the vehicles more useful, profitable, and marketable.
2. Require automakers produce at least 10,000 electric or fuel cell vehicles total from 2012 to 2014, not the proposed 2,500 vehicles.
3. Do not allow the electric and fuel cell vehicles sold in other states to count towards the credits for the California requirement (known as the "travel provision"); placing vehicles in other states will not result in the necessary net improvements in California air quality. Each state's requirements should count only towards their own state -- a larger total number of vehicles across the country will result in improved economies of scale and lower prices for the vehicles, and will result in a larger air quality improvement countrywide.
4. Maintain the credit sunset for less efficient, lower power hybrids (known as Silver Type C); the current proposal asks to extend these credits indefinitely.
5. Do not increase the credits for Neighborhood Electric Vehicles (low speed vehicles similar to electric golf carts); they are not driven like full-function vehicles that are the focus of the ZEV Program.
The California Air Resources Board has a phenomenal opportunity to improve the air quality in California by incentivizing the production and sale of vehicles that pollute less and as a side benefit get better fuel economy. Ten other states have signed on to the tougher restrictions of California's ZEV Program and will follow California's lead.
We encourage the California Air Resources Board to consider our recommendations. We believe these proposed changes to the staff recommendations are pragmatic, realistic, and achievable.
Where You Fit In
You can have a say in this decision as well, by calling Board Members and Staff, mailing, or e-mailing the Air Resources Board prior to the final vote on March 27, 2008.
1 ZEVs are fuel cell vehicles, battery electric vehicles, and neighborhood electric vehicles.
