Tuesday, March 25, 2008

Some of the Facts : Automakers Comment to CARB

The Large Volume Manufacturers, the automakers with obligations under the California Air Resources Board (CARB) Zero Emission Vehicle Program, have made a joint comment about the staff proposed revisions that will be voted on Thursday March 27 in Sacramento. It can be seen here (comment #121) along with 187 other public comments (overwhelmingly asking for a stronger mandate for plug-in cars) on the CARB website. Despite the various positions advanced by each automaker independently, they overcame their differences to say they “remain very concerned” that “provisions being proposed by Staff are overly stringent.” The letter states that the Staff recommendation has increased the volume of ZEVs and PHEVs required from 2012-2014 and this would result in additional costs of up to $3.4 billion. An accompanying chart shows the increases.

But the explanation is disingenuous. The chart compares the November 2007 Concept Paper to the February 2008 45-day Notice, which results in a possible increase of 630 zero-emission vehicles. Yes, 630 vehicles over a three year period from 2012 to 2014. What is missing in this presentation is the ZEV Program requirements endorsed by CARB in 2003, the requirements as they stand now. Back then, when the intention was to kill the electric car, automakers signed on to an “alternative path” replacing battery electric vehicles with fuel cell vehicles. An obligation to manufacture a meaningful percentage of electric cars dropped down to a required 250 FCVs by 2008, then 2500 by 2012, and then 25,000 by 2015. But what happened to the 25,000 ZEVs in the automaker’s plea? Absent of course, since including it would make clear that the staff revision in fact lops off 90% of the 2003 ZEV requirement. The automakers bemoan a supposed 25% increase, while ignoring what is actually a 90% reduction.



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Anonymous said...

That CARB would dilute the ZEV mandate even further is beyond comprehension. One would think that they might want to clean a bit of the egg off their face from their past debacles. Nope. "Throw another omelette at us, please."

Here's my question: if you were in charge of CARB, what would you propose to facilitate and accelerate the transition to clean, renewable energy for transportation?

IMHO, I think that CARB should completely forget about percentages (like before) or numbers and credits (like now).

The ZEV mandate should simply require that, by 2012, the franchise dealers of all the major auto manufacturers (and I would lower that "threshold" to include companies like Mitsubishi, Subaru, Volvo, etc.) must comply with these stipulations:

* They must have a ZEV vehicle in their showrooms, and at least one more on the lot for customers to test drive.

* Those ZEVs must be capable of a top speed of no less than 80 mph.

* They must have an emissions-free, EPA certified range of no less than 125 miles.

* They must meet federal safety standards.

* They must cost no more than 125% of the average base price of all the models in the same "class" sold by the parent company in the previous year.

* They must be deliverable to customers who purchase them within at least a 60-day period.

* For its part, CARB will work with the governor and the legislature to establish the very best government incentives available to those who purchase the ZEVs (say, for example, tax deductions, no registration fees, no sales tax, carpool lane access, etc., etc.).

* If the car manufacturers do not comply? They just can't develop and produce the ZEVs fast enough so that their dealers can meet that deadline? Then make it legally possible for the dealers to secure their ZEVs from other sources without losing their franchises.

* And if the dealers do not comply? Then the state revokes their business licenses until the requirement is met. Period. THAT will get the auto companies moving, believe me. They might not listen to CARB, or even consumers, but they sure will listen to their own local dealers!

I do not think that such a mandate is unreasonable. After all, the EV1 and the RAV4-EV were capable of that same speed and range back in 2002, so surely car manufacturers can do even better nowadays.

What kind of ZEV the car companies wish to provide should be entirely left up to them --be it an electric car, a fuel-cell vehicle, a series hybrid, or even one powered by a flywheel or compressed air or a solar panel-- as long as it produces ZERO emissions for at least 125 miles. No more of CARB favoring one technology over another: let the technology itself decide.

And no more of this "no customer demand" excuse. If customers do not even know about the option, how can they demand it? This ZEV mandate would assure that customers DO know --and can decide accordingly. Get the ZEVs in the showrooms! Take advantage of the free market system instead of trying to thwart it.

Jim's Words Music and Science said...

Nice work! I just highlighted your blog on my own blog, Chemistry for a Sustainable World, in a post on plug-in hybrids and electric cars that I'll publish in a minute or two.

Best wishes, Jim

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