On February 8, 2008, CARB released it proposal for modifying the current ZEV program regulations. For an overview of the proposal, please refer to the summary below which is verbatim text from the CARB Staff Report: Inititial Statement of Reasons.
The CARB Board will formally consider the proposal at a two-day hearing in Sacramento, CA which will start at 9:00 am on March 27. Written comments on the proposal must be filed by noon March 26.
Inquiries regarding the substance of the proposed regulatory action may be directed to the designated agency contact persons, Dr. Elise Keddie, Manager, ZEV Implementation Section at (916) 323-8966 or by e-mail at ekeddie@arb.ca.gov or Mr. Mark Williams, Air Pollution Specialist, at (916) 327-5610 or by e-mail at mwilliam@arb.ca.gov.
Overview of CARB’s Proposed Amendments to the ZEV Program Regulations (taken from the CARB Staff Report: Initial Statement of Reasons)
ARB staff is proposing amendments to the ZEV program that are designed to better reflect the state of technology and create incentives for new vehicle designs. Other proposed changes are intended to clarify and simplify specific program requirements pertaining to 2009 and subsequent model years (MY).
The most significant proposed amendments pertain to Phase III and Phase IV (2012 –2017), while Phase (2009 – 2011) requirements remain largely unchanged. The proposed amendments are expected to maintain pressure on the commercialization of pure ZEV technologies while recognizing the technological limitations and costs of current vehicles.
The key elements of the proposal are the following:
A. Creation of the “New Path” for 2012. Combine the Base Path and Alternative Path requirements into a New Path where the ZEV obligation and the options to use other vehicle types are expressed as annual percentage requirements. The pure ZEV requirement may be offset by up to 90 percent “Enhanced” Advanced Technology Partial ZEVs (Enhanced AT PZEV), a new classification of vehicle in Phase III (2012 –2014). In Phase IV (2015 – 2017), 50 percent of the ZEV target requirement could be met with Enhanced AT PZEVs. Enhanced AT PZEVs are AT PZEVs with credit allowances totaling more than 1.0 and which use fuels that can be used in a ZEV, like electricity or hydrogen. Examples of Enhanced AT PZEVs are plug-in hybrid electric vehicles (PHEVs) and hydrogen internal combustion engine vehicles. The proposed changes act to simplify the regulation while maintaining the overall outcome of the Alternative Path. Establish a new Type IV category to recognize longer range ZEVs and adjust ZEV credits such that Type III ZEVs earn 4 credits and Type IV ZEVs earn 5 credits through 2017.
B. Establish Carry-Forward and Carry-Back provisions for ZEV credits. Modify the credit provisions under the proposed “New Path” to be consistent with the existing provisions contained in the Alternative Path which allow compliance over a three year window. Additionally, modify the way credits may be used after a specified time to limit the possibility that amassed credits could cause a black out of ZEV production for an extended period of time and to make the regulatory requirements better reflect the expected outcome in terms of vehicles produced.
C. Provide More Equal Treatment of Battery Electric Vehicles. Eliminate the cap on the use of full-function and city battery electric vehicles (EV) within the Alternative Compliance Path. Change the ratio for substitution for each vehicle type to be consistent with the credits earned by the vehicle rather than a separate ratio established only for pure ZEV obligation compliance. Create a new Type I.5 to recognize opportunity for a marketable longer range city EV.
D. Adjust Credits for AT PZEVs. Modify the AT PZEV requirements, primarily to address PHEVs. The proposed amendments include addressing deployment of “blended” HEVs through an equivalent all electric range (EAER) credit, adjusting the credits for advanced componentry and fuel cycle emissions, and other conforming changes.
E. Increase Credit for Neighborhood Electric Vehicles. Double the existing credit for neighborhood electric vehicles (NEV) to 0.3 credits per vehicle to reflect the vehicle’s positive environmental benefits but limited functionality compared with full function battery or fuel cell EVs.
F. Extend “Travel” Provision. Extend the provision that allows Type III ZEVs placed in any state that has adopted California’s ZEV program to count towards California’s ZEV requirement through 2017, and include Type IV ZEVs. Include battery EVs within the provision but sunset the application of this provision for these vehicles in 2014.
G. Modify Transition for Intermediate Automakers. Create a ramp-up period of six years for intermediate volume manufacturers (IVM) who are transitioning to large volume status. During this time, an automaker would be allowed to meet its ZEV requirements with increasing numbers of partial ZEV allowance (PZEV) of which a percentage must be AT PZEVs.
H. Public Availability of ZEV Credit Data. Require that all production data be publicly available starting with the 2009 model year and release ZEV credit bank balance information for the 2010 model year and beyond.
Effect of Proposed Amendments
2009 – 2011: The staff proposal is not expected to change the number of pure ZEVs (e.g., fuel cell and battery EVs) in the near term. However, the changes made do allow additional flexibility for the use of battery EVs, should products be available in this timeframe. Since many automakers still retain sufficient banked credits to assist with their compliance plans for this time period, staff expects they will aggressively use banked credits to meet the requirements in this timeframe since ZEV technologies remain very expensive. Thus the actual number of new ZEVs produced is expected to be lower than the 2,500 commonly referred to for this time period. Additionally, the amendments provide a clearer path for the use of PHEVs which are under development.
2012 – 2017: The staff proposal is expected to decrease the number of pure ZEVs (e.g. fuel cell and battery EVs) introduced during this timeframe relative to the existing program. Where the existing program would call for 75,000 ZEVs between 2012 and 2017, the staff proposal could result in as few as 27,500 ZEVs if manufacturers comply using the highest credit earning ZEVs. A mix of ZEV types used for compliance in this time period, including fuel cell vehicles and a range of battery EVs, would result in a higher number of ZEVs. The overall number of advanced technology vehicles should increase as manufacturers are allowed to meet a part of the requirements with a new class of vehicle, referred to as Enhanced AT PZEVs. More than 150,000 Enhanced AT PZEVs could result in the 2012 – 2017 timeframe. The exact number of vehicles that will be placed is unknown; however use of banked credits will not be as significant in this timeframe, meaning that production of ZEVs should more closely match the stated requirements than in previous years of the program.
2018 and subsequent: No changes are proposed to the ZEV requirements for the long term. The current 16% requirement beginning in 2018 remains in place. It is expected that the program will be revisited prior to the implementation of this portion of the regulation to determine if the pace of vehicle introduction is correct or if it can be accelerated. The proposal is expected to reduce the cost of compliance by reducing the number of vehicles incorporating the most expensive technologies (fuel cell and battery EVs) needed during the 2012 – 2017 timeframe. The estimated annual savings averages $1.3 billion in 2012 – 2014 and nearly $0.9 billion in 2015 – 2017. The ZEV program continues to provide positive air quality impacts as compared to no program. The changes proposed by staff significantly reduce an automaker’s cost of compliance, but still provide increased air quality benefits primarily because they rely upon the proven emissions benefits of commercially viable and increasingly available AT PZEVs. Staff believes that a reduction in the near term production volume of ZEVs is warranted because technological and cost hurdles remain that are best solved through continued lower volume demonstrations of the technologies. In making these changes, the program will reduce criteria pollutant emissions by 7,000 tons over the life of the affected vehicles. The proposed changes further encourage AT PZEV technologies as well as Enhanced AT PZEV technologies, both of which enable pure ZEV technology.
