Center for Energy Efficiency and Renewable Technologies
Providing global warming solutions for California and the West.
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cleaner transportation and alternative fuels
Gasoline and diesel transportation fuels represent a major share of America’s most pernicious air pollution, water-borne toxins, and climate emissions. While we presently have better technological choices for cleaner electricity production than for transportation fuels, there is still significant progress available from more fuel-efficient vehicles, hybrid technologies, and alternate fuels. There is also much future promise in hydrogen fuel-cell vehicle technologies. CEERT has been working to clean up CO2 from cars and trucks, promote smarter transportation and development planning, and help develop an alternate fuel-distribution infrastructure as near-term means to reduce the impacts of fossil-fueled transportation.
Advanced Clean Cars (ACC)
The ACC front continues to make progress on state and national air quality and climate goals.
A Federal Reset
On August 5 President Biden revealed how plans being developed by the US Environmental Protection Agency (US-EPA) and the National Highway and Traffic Safety Administration (NHTSA) will address the Trump Administration’s attack on California and the Section 177 states’ authority to regulate vehicle emissions. Previously, under President Obama, automakers were required to reduce GHGs by effectively increasing fleet-average fuel efficiency by 5% a year, to a fleet-average of 54.5 miles per gallon by model year 2025. The Biden Rule will take effect for cars beginning in Model Year 2023 and run through 2026.
This approach will fall short of the 60% in reductions by 2030 many environmental groups had been requesting, and is a compromise broadly based on the voluntary MOU (Memorandum of Understanding) some automakers had entered into with CARB (California Air Resources Board) in response to the Trump rollbacks. According to Administration officials, the new rule will require automakers to achieve fleet-average GHG reductions equivalent to 52 miles per gallon by model year 2026. In the first year, carmakers will have to cut emissions 10% more than under the Trump rules, then make 5% reductions each of the three following years. (The result of the Biden course correction to the Trump rollback is that the U.S. will be in deficit relative to the GHG reductions that would have been reached by adhering to the realistically achievable Obama targets.)
At the same time that President Biden announced the US-EPA and NHTSA change of direction, he issued an Executive Order encouraging automakers to make at least half of all new light cars and trucks zero-emission vehicles (ZEVs) by 2030. The EO also directed the US-EPA and NHTSA to begin work on the next set of vehicle regulations required to address accelerating climate change, beginning in 2027.
CEERT and our allies in the Advanced Clean Cars/ACC Coalition are urging CARB to adopt a strong set of post-2025 vehicle standards, and we are working with Staff on the design and implementation of the post-2025 Advanced Clean Cars Regulations (aka ACC II). CARB initially plans to limit the updates to improvements in the criteria emissions requirements of internal combustion engine (ICE) vehicles (the LEV regulations); and to the design of the ZEV Program to achieve the goal in Governor Newsom’s 2020 Executive Order N-79-20 that all passenger vehicles sold in California be ZEVs by 2035.
CARB staff will update the GHG emission standards for passenger vehicles once it has redesigned the LEV and ZEV regulations. The development of the LEV GHG rules will likely be in coordination with the efforts of the US-EPA and NHTSA, which were directed by the Biden August 5 Executive Order to work in coordination with California and other Section 177 states on new vehicle emissions standards.
The ACC Coalition’s advocacy has been primarily focused on ensuring that CARB incorporate environmental justice and equity considerations throughout the regulation. We also support the removal of ZEVs from future fleet averaging for criteria pollutants to ensure there is no backsliding in the emissions performance of any post-2025 ICE-equipped cars, and support increased stringency for lower allowed criteria emissions from those cars. We are further recommending that Staff explore whether it would be more appropriate to include large vans and pickup trucks addressed in California’s Omnibus Truck Regulations within the ACCII regulation.
We support Staff improving the emissions performance of plug-in hybrid electric vehicles (PHEVs) by requiring that they have an increased all-electric range that will better motivate PHEV owners to keep their vehicles charged, thereby increasing their total zero emission miles. We also support Staff increasing the stringency of the criteria emissions performance of these vehicles, which have unique operating characteristics previously not captured in testing and certification requirements under ACCI.
The ACC Coalition feels that Staff have proposed a ramp of annual 2026-2035 ZEV sales requirements for automakers that is overly conservative and risks the state falling short of its 2035 goals. The Coalition has recommended a more aggressive sales-ramp requirement that will hold many of the automakers to their public pronouncements, and will have a greater chance of ensuring that California can practically achieve 100% ZEV sales by 2035.
In furtherance of that ZEV goal, the Coalition is supporting CARB restricting the use of the glut of ACCI ZEV credits before 2025, and is also recommending that CARB restrict the use of ZEV credits under ACCII, tying their generation more closely to actual pure-ZEV sales than is currently the case under ACCI. There should be a stringent cap on the use of ACCII ZEV credits, which should have a shorter lifespan than the 5-year ACCI ZEV credits, and credits should no longer be available after the 2035 model year (thus requiring all passenger vehicles sold to be pure ZEVs from then on).
We support Staff requiring that, as is the case for ICE-equipped cars, automakers meet durability requirements on their ZEV powertrains and provide minimum warranty requirements for the ZEV powertrain, batteries and fuel cell stacks. We are also encouraging Staff to work with other state agencies to establish measures to enable battery recycling and re-use, given the heavy demand that will be placed on the world’s mineral resources to meet our climate emergency.
The ACC Coalition believes Staff’s initial work on cost assessments for future ZEVs, as presented at their May 6 workshop, uses cost projections that are too conservative. We have submitted detailed comments that we hope will help Staff improve the accuracy of their cost analysis as they work toward adoption of the ACCII regulation package at CARB’s June 2022 Board hearings.
A Continent United?
For the past several years CEERT has been working with Canadian NGOs to encourage the Canadian Federal Government to adopt a ZEV mandate. On June 29 Canada announced it would be adopting a requirement that the sale of all light-duty cars and trucks be ZEVs by 2035, thereby joining Québec and British Columbia. Consultations on developing similar federal regulations could begin later this year.
With Virginia’s passage of clean car regulations in February, 14 states and the District of Columbia had adopted some or all of California’s LDV regulations. Minnesota has since adopted similar regulations, New Mexico has started the development of its regulations, and Nevada’s Clean Car regulations are approaching final approval. If these 17 states were to adopt ZEV mandates along with Québec and British Columbia, they would account for roughly 40% of the North American LDV market. Despite the April 21 letter from California and 11 other states requesting that his Administration require all new LDV sales be zero-emission by 2035, President Biden’s August 5 Executive Order only set a goal of encouraging automakers to make 50% of their sales EVs by 2030.
Clean Miles Standard
The CARB Board adopted the Clean Miles Standard at its May 20 hearings. The regulation will take effect in January 2022, when Transportation Networking Companies (e.g., Lyft, Uber) are required to submit the first of their biannual GHG-compliance plans, and will then need to begin actual compliance in 2023, pending approval for their first 2-year plan. With CARB’s adoption of the regulations, the CPUC will assume responsibility for the implementation and oversight of the program.
Clean Truck Regulations
Advanced Clean Fleet Regulation
CARB Staff continue to develop the Advanced Clean Fleet Regulation (ACF Rule) as a complement to the ACT and Low-NOx Omnibus Rules. The ACF Rule will supplement the ACT Rule by requiring that public and private fleets transition to 100% zero-emission medium- and heavy-duty trucks (ZETs), thereby spurring technology development and market investment. CEERT and other members of the ACT Coalition are working with CARB staff on the ACF Rule, in part to ensure that its benefits are maximized for disadvantaged and low-income communities. The Coalition is encouraging CARB to work with other state agencies to address the trucking industry’s continuing worker exploitation through the misclassification of drivers who operate 70 to 90% of California’s drayage trucks, making misclassification the drayage segment’s dominant business model.
While CARB Staff originally intended to bring the proposed ACF Rule to the Board in its December 2021 hearings, it now appears that the regulatory package will be delayed into 2022.
Federal Clean Truck Regulations
While the US-EPA has taken no public action on its Cleaner Trucks Initiative since its July 2020 postponement of any further work on the rulemaking, President Biden’s August 5 Executive Order lays out a schedule for developing fuel efficiency and multi-pollutant emissions standards for medium- and heavy-duty vehicles beginning with model year 2027. (Current fuel efficiency and GHG emissions standards run through 2027.) The President’s EO leaves open the possibility that the agencies (especially the US-EPA) could include ZETs in any new regulations for model years 2027 or 2028 and beyond, which would allow the federal agencies to work with California and the 11 other states that submitted an April 21 letter to President Biden requesting that all medium- and heavy-duty vehicle sales be zero-emission by 2045.
Clean Transportation Investment Plan
With approval of the State Budget in July, California will direct significant levels of funding to its clean transportation system. The $262.6 billion budget includes $3.5 billion for critical zero-emission vehicle and infrastructure programs, as follows:
- $1.4 billion for electrifying medium- and heavy-duty vehicles on California roads to clean the air, including 3,000 zero-emission drayage trucks, school buses, and transit buses;
- $415 million to deploy the necessary charging infrastructure for those vehicles;
- $400 million for equity-focused transportation projects like Clean Cars 4 All, which enables low-income Californians to scrap their old cars and replace them with a new or used option that is less polluting and more efficient;
- $500 million for the CEC’s Clean Transportation Program, which deploys charging infrastructure for light-, medium-, and heavy-duty vehicles;
- $525 million for consumer rebates on new ZEV purchases through the Clean Vehicle Rebate Project; and
- $250 million for zero-emission manufacturing.
With the adoption of the Budget, the CEC will convene the next meeting of its Advisory Committee for the Clean Transportation Program (formerly the Alternative and Renewable Fuel and Vehicle Technology Program) on September 16 to consider its next Investment Plan Update.