Submitted Comment Name Jeremy Mall Affiliation N/A Subject ZEV Definition Message Note that there is no definition for ZEV in the definitions and acronyms section of AB 32. This is a problem because common nomenclature for ZEV is that it’s an acronym for "Zero Emission Vehicle" and Staff uses this interchangeably with EVs (the acronym for "electric vehicles") from time to time. This is very confusing to both participants and onlookers The "ZEV" acronym is a marketing term used by electric vehicle ("EV") manufacturers to brand their vehicles and make them appear cleaner to consumers than they actually are. It is a great marketing ploy because the average consumer does not know the difference between zero tailpipe emissions and zero GHG emissions. They can put a little asterisk that says “zero emission claim refers only to tailpipe emissions” and no one is any wiser. Staff does not have that luxury as AB 32 is a complete cradle to grave GHG policy, making most EVs greater than zero emission due to the use of grid electricity for fuel. Therefore, ZEV and EV acronyms are not interchangeable within the contexts of AB 32. As its sits today, Staff should define ZEV as zero emission H2 fuel cell vehicles or EVs that only use charging stations connected to off-grid renewable power. Broadly interchanging the acronyms "EV" and "ZEV" is misleading to participants of program, especially those less familiar with cradle to grave GHG programs. This was especially evident in the most recent workshop when there were multiple comments from the environmental justice community and other NGOs speaking negatively about dairy RNG and its role in AB 32. No grid can run on 100% wind and solar energy and while the California grid significantly lower GHG emission than the rest of the US, it is far from zero. RNG is a key feedstock to decarbonize the CA grid and reduce criteria pollutants in the state. But yet multiple EJ commenters spoke on the fuel as if it were worse than petroleum natural gas. EJ advocates and other NGOs spoke as if grid electricity were already zero emission. In truth, it is nowhere close. Staff need to be more clear with the community about that fact. It starts with defining ZEV within the proper context of AB 32. File Upload (i.e., Attachments): N/A
Submission information