California Air Resources Board

Dear Members of the California Air Resources Board,
Advanced Clean Cars III is a step in the right direction giving the outright hostile regulatory environment created by a malfeasant federal government and a concerted political campaign to stoke cynicism and inaction in order to perpetuate a severely unhealthy and inequitable status quo.
You will undoubtedly receive many comments, couched in the language of "supporting the goals" of ACC III while imploring state regulators to "slow it down" and "recognize the reality". The reality, in this case, is their extremely myopic and oftentimes self-serving declaration that our zero-emission transportation and renewable energy goals are impossible to achieve- even entirely fanciful. As someone who has monitored the progress of our transition to renewable and carbon-free forms of electricity generation with keen interest, I can confidently state that these people have zero vision, zero courage, and zero interest in the future well-being of Californians. CAISO's renewable generation reports and other data related to electrical supply will show that renewable electricity generation in California increased by over 55% in absolute terms between June 2019 and June 2024, going from less than 35% of the total electrical load to more than 52% during that same period. Improvements in renewable energy technologies, reductions in their cost, and emerging utility-scale battery and other energy storage technologies are making a massive transition a near-term possibility, given strong enough political will and resolve. Even to the extent that the grid is not fully decarbonized, battery-electric vehicles are STILL far more efficient and less polluting, given the efficencies of burning fossil fuels to produce electricity at scale compared to an internal combustion engine in each individual vehicle. Further, the creation of an overhead catenary electric system on key goods movement highways in the state would reduce the need for solar curtailment during off-peak hours while alleviating range anxiety related to medium and heavy-duty battery electric trucks.
While the trucking and oil industries have vigorously promoted the idea that battery-electric trucks are years away from overcoming operational deficiencies that place them at a disadvantage compared to internal combustion and diesel trucks, the gap is closing, and the progress of battery-electric vehicle technology is rapidly picking up pace. China, for example, added 230,000 electric heavy-duty trucks to its fleet in 2024 and battery-electric heavy and medium duty trucks now have an approximately 14% market share in China. By early this year, the market share of battery electric heavy and medium duty trucks had increased to 22% and 21%, respectively. Americans tend to look down their noses with disdain at China, as if China is an inferior country. If that is the case, why are they able to make such monumental progress while we whine and complain about how unfair their state-led subsidies and long-term planning are to our "free market" (read: oligarchic, rentier-controlled) economy and how the modest efforts of states like California to affect the transition to zero-emission transportation are "onerous" and "utopian". These people need to cut the bullshit: either the United States is the greatest country in the world, as they allege, and can easily leapfrog to a clean energy economy if it wanted to or it is a reactionary, backsliding country that lacks the political will to do anything that infringes upon the ability of large shareholders to skim enormous profits in perpetuity. It is impossible to square USA #1 jingoism with stubborn refusal to transition away from intensive fossil fuel consumption.
Energy density of batteries is increasing at a remarkable pace. In China, MG has released a car that retails for the equivalent of about $11,000 that has a semi-solid state battery with only 5% electrolyte. It has an energy density of 180Wh/kg and a range of 334 miles, and better cold weather performance than previous batteries. If we are averse to viewing China as a positive example, it is also worth noting that even the much troubled Stellantis is poised to launch a semi-solid state battery in the Dodge Charger by 2027 that will boast an energy density of 177wH/lb. Stellantis is partnered with a firm called Factorial that has touted a solid state battery that has demonstrated an energy density of over 375Wh/kg and the ability to charge from 15% to 90% in about 18 minutes. That completely negates most of the most potent criticisms of electric vehicles as we know them.
The benefits are manifestly obvious in terms of improved air quality and reduced harms to human and ecological health. Severe air pollution has long been linked to respiratory and heart issues, but the consequences are becoming increasingly more obvious. Levels of air pollution such as we experience here in the San Joaquin Valley are high enough to harm the intellectual development of children who are exposed. A recent University of Michigan study (attached) has suggested that people who have been exposed to heavy air pollution over long periods experience greater difficulties living independently and completing basic tasks in old age than those who have not spent most of their lives breathing in noxious air.
Many people will acknowledge the public health harms done by burning fossil fuels, but they will present the transition away from fossil fuel vehicles as too burdensome to be worth it. If it really is the case that electric vehicles are inherently more expensive than internal combustion cars, and will remain that way indefinitely, why has the United States placed tariffs of more than 100% on Chinese electric cars? And why, then, do said cars still retail at prices that are competitive with "American" cars that are subject to no such tariff?
It is important that our state regulators not be cowed by a campaign of industry intimidation or disingenuous concern trolling from bad faith actors. California has the chance to once again be at the leading edge of fantastic new developments in US industry, technology, and social development. However, for that to happen, we have to have the strength and vision to not acquiesce to business as usual and prostrate ourselves before the titans of big business.