ARB hosting public hearing on ZEV modifications; battery swapping out for fast refueling of ZEVs
10 September 2013
The California Air Resources Board (ARB) will conduct a public hearing on 24 October in Sacramento to consider minor proposed amendments to the California Zero Emission Vehicle (ZEV) regulation being put forward by ARB staff. (Earlier post.)
In January 2012, the ARB approved the Advanced Clean Cars program, which included increased ZEV requirements through 2025 model year, and the next generation of light duty greenhouse gas (GHG) and criteria pollutant emission standards (LEV III). (Earlier post.) This program combined the control of smog-causing pollutants and GHG emissions into a single coordinated package of requirements for model years 2017 through 2025.
In November 2012, the Board approved minor amendments to the Advanced Clean Car program and a final EPA waiver was granted in January 2013. Due to a compressed schedule, staff was not able to make additional minor modifications before the regulation was finalized in December 2012.
Staff is returning to the Board with amendments in four areas: changes to effectuate an agreement between other states adopting California motor vehicle emission standards including the ZEV regulation (Section 177 states) and regulated manufacturers; provisions to ensure ZEVs are delivered for sale in California every year; modifying the fast refueling definition; and adding conforming and clarifying language where needed.
Section 177 state compliance path. In 2012, the Board approved a new optional provision which allowed manufacturers to produce extra ZEVs in the section 177 states prior to model year 2018. In exchange for these extra ZEVs, manufacturers gain the ability to pool credits across state lines within and between two Regional pools.
Additionally, manufacturers would also be allowed to comply with a reduced transitional zero emission vehicles (TZEV) and ZEV portion of their requirement in certain model years. This provision was put in place to smooth the transition into 2018 and subsequent model year requirements, and ensure ZEVs were placed in the section 177 states prior to 2018 model year. Manufacturers and the section 177 states helped draft language, which was finalized in 2012.
Since adoption, manufacturers and Section 177 states have continued discussions surrounding this provision, and have requested a number of changes. Staff is proposing to exclude the use of transportation system credits for meeting the additional ZEV percentages in each of the Section 177 states in model years 2016 and 2017. This modification will help ensure those additional percentages are met with credits from actual vehicles.
Staff is also proposing to allow manufacturers on the optional compliance path to trade and transfer 2012 through 2017 model year ZEV and TZEV credits within and between each Regional pool. This means that, for example, a manufacturer could use 2012 through 2015 model year credits to meet a 2015 model year obligation.
There are two Regional Pools: West and East. States west of the Mississippi River, excluding California, make up the West Region pool, and states east of the Mississippi River make up the East Region pool.
Staff is also proposing to remove the requirement to provide vehicle identification numbers (VIN) for TZEVs prior to 2018 model year and substitute a requirement that manufacturers provide VINs for ZEVs and TZEVs upon request. Lastly, staff is proposing to simplify the provision specifying what happens when a manufacturer elects the optional Section 177 state compliance path, but fails to comply with any or all of the requirements.
Maintaining a minimum ZEV requirement. This amendment maintains a minimum ZEV credit requirement, regardless of model year and use of non-ZEV credits earned in the regulation.
Various caps on use of credits from special flexibility provisions have been put in place over iterations of the regulation to ensure manufacturers are still required to produce ZEVs. However, staff found that there was no clear direction for how to apply these caps in combination to meet ZEV requirements. For example, a large volume manufacturer is subject to the following caps when meeting its 2018 model year minimum ZEV requirement:
Extended Range Battery Electric Vehicle (BEVx) Credits: No more than 50% of minimum ZEV requirement.
GHG-ZEV Over-compliance Credits: No more than 50% of minimum ZEV requirement.
Transportation System Credits from ZEVs: No more than 10% of minimum ZEV requirement
Staff is now proposing an overall 50% cap when a manufacturer uses credits (other than pure ZEV credits) in combination to meet its minimum ZEV requirement in any given model year.
Modifying fast refueling definition to exclude range accumulation through battery exchange. ZEVs with the ability to refuel to 95% of full capacity within 15 minutes are allowed (§1962.1.d.5.A) to earn more credit:
A Type IV ZEV (200+ mile range, and fast refueling capable, i.e., 190 miles of range in <15 minutes) earns 5 credits in 2012-2014, and 5 credits in 2015-2017.
A Type V ZEV (300+ mile range, and fast refueling capable, i.e., 285 miles of range in <15 minutes) earns 7 credits in 2012-2014 and 9 in 2015-2017.
By contrast, a Type II ZEV (>100 miles range, no fast refueling), earns 3 credits.
(The 2013 Tesla Model S is currently classified as a Type III (40 kWh variant); Type IV (60 kWh variant); or Type V (85 kWh variant) ZEV.)
Staff is proposing to remove battery exchange from qualifying under the fast refueling definition, starting in 2015 model year. Hydrogen fast refueling capable Type V ZEVs will still earn 9 credits each in model years 2015 through 2017 upon placement in service. ARB Staff believes it is important to maintain the difference in credit level between the two ZEV technologies to ensure appropriate incentives are in place to support hydrogen technologies as infrastructure ramps up through 2017.
Hydrogen remains a long-term solution for all vehicle classes, and is essential for meeting California’s long-term air quality and GHG reduction goals, according to ARB.
Staff is also proposing minor clarifying, grammatical, and numbering corrections.
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