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.