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CARB releases Midterm Review of ZEV regulation, LEV III GHG and PM standards; calls for post-2025 standards

When the California Air Resources Board (ARB) adopted the Advanced Clean Cars (ACC) program in 2012 (earlier post), the agency committed to conduct a comprehensive midterm review of three elements of the program: the zero-emission vehicle (ZEV) regulation; the 1 mg/mi particulate matter (PM) standard; and the light-duty vehicle greenhouse gas standards for 2022 and later model years. ARB has now released the Midterm Review of Advanced Clean Cars Program—an extensive evaluation of the California passenger vehicle market and technology.

The Review finds that the greenhouse gas (GHG) emission standards currently in place for model years 2022-2025 are readily feasible at or below the costs estimated back in 2012. The report also finds that ZEV technology has seen significant development that, in many cases, is beyond what was envisioned just four years ago. The report indicates that existing programs in California will add at least 1 million zero-emission vehicles on its roads and highways by 2025.

  • GHG. Currently, manufacturers are over-complying with the GHG requirements and are offering various vehicles on the road today that are already able to comply with the GHG standards for later model years. For example, the report finds that of the more than 1,300 conventional vehicle model configurations available in 2016, 23 truck configurations, 23 sport utility vehicle (SUV) configurations, and 26 passenger car configurations meet 2020 or later GHG standards with a conventional gasoline powertrain. An additional 78 model variants comprising hybrid electric vehicles (HEVs), PHEVs, and BEVs also meet the 2020 or later standards.

  • PM and criteria pollutants. Manufacturers have been marketing passenger cars and SUVs meeting the 2025 LEV III criteria pollutant fleet average requirement of super ultra-low emissions vehicles (SULEV30) for more than a decade. Sixteen manufacturers certified 74 vehicle models to the SULEV30 standards in 2016, including mainstream models. The technology to meet this stringent requirement is well defined and manufacturers have significant lead time to incorporate it across their fleets.

    Furthermore, testing data confirms that newer gasoline direct injection engines (GDOI) vehicles have significantly lower PM emissions than earlier generation GDI vehicles and are readily capable today of meeting the upcoming 3 mg/mi standard with typical emission rates from 1.2-1.5 mg/mi. These advances position manufacturers well to make the final refinements in control towards the 1 mg/mi PM standard, the report finds.

  • ZEVs. Through August 2016, nearly 230,000 ZEVs and PHEVs have been registered in California, with an additional 62,000 in nine Section 177 states that have adopted California’s ZEV regulation. These represent more than half of the more than 500,000 ZEVs and PHEVs in the US.

    ZEV electric infrastructure in California and Section 177 ZEV states has grown with substantial investments in the past several years, and accelerated investments are expected as new infrastructure developments emerge. More than 17,000 Level 2 and 2,100 direct current fast charger (DCFC) connectors have been deployed across California and the nine Section 177 ZEV states.

    California’s current programs enabled by important legislation are launching the first major fuel cell electric vehicle (FCEV) market and hydrogen fueling network in the US. Three FCEVs are currently for sale in California while 25 retail hydrogen refueling stations are open in California with an additional 20 stations already in development. Toyota and Honda have also announced partnerships with private companies for financial support of additional stations in California and the Northeast.

The major findings and recommendations of the Review include:

  • Continue California participation in the National Program by maintaining the “deemed to comply” provision allowing for compliance with the adopted US EPA GHG standards for 2022 through 2025 model years.

    The updated national vehicle forecast shows that changes in vehicle fleet composition due to increased truck sales are now projected to result in a slightly higher 2025 model year fleet average CO2 level. Similarly updated analysis for California, however, found that the originally projected California GHG benefits will still be achieved. An analysis specific to the California car/truck fleet mix projects the 2025 model year fleet average to be the same or lower than originally projected.

    Despite a similar trend as seen nationally in increased truck sales, the updated analysis projects the equivalent CO2 fleet average in California will be between 153 and 167 grams per mile CO2 compared to the original 2012 ARB projection of 166 grams CO2 per mile, largely due to the actual share of passenger cars in the fleet mix being much higher than originally estimated.

  • Maintain the existing PM emission gravimetric measurement method for the 1 mg/mi standard.

  • Maintain the stringency and implementation schedule of the adopted 1 mg/mi PM emission standard applicable in 2025 model year. Testing work determined that compliance with the 1 mg/mi emission standard by 2025 model year is feasible and that manufacturers are on track to meet this standard. The findings also support that the currently provided lead time is necessary to ensure manufacturers can incorporate broadly the knowledge gained from the in-use operation of newer, 3 mg/mi compliant, GDI systems into normally scheduled engine redesigns to optimize for PM control at little to no added cost.

    further improvements are needed for gasoline direct injection (GDI) vehicles to meet a 1 mg/mi standard with a sufficient compliance margin, but manufacturers and suppliers appear to be on track to achieve control within the current lead time provided by the adopted regulation.

  • Develop more comprehensive PM emission standards to phase-in with the 1 mg/mi standard in 2025 model year to ensure manufacturers implement robust control strategies that result in low PM emissions in the real world. Emission test results suggest that additional regulatory requirements are needed to better ensure that when the 1 mg/mi Federal Test Procedure (FTP) standard is phased-in, it results in robust in-use PM control over a broader spectrum of driving conditions. To this end, ARB plans to develop a more stringent US06 cycle PM emission standard, which would verify PM is well-controlled over more aggressive in-use driving conditions, as well as consider PM emission standards for other test cycles and ambient conditions as necessary to ensure in-use PM emissions are minimized.

  • Strengthen the ZEV program for 2026 and subsequent model years to continue on the path towards meeting California’s 2030 and later climate change and air quality targets. Set new requirements to target credit provisions and regulatory structure adjustments in order to increase certainty on future vehicle volumes, technology improvement, and PHEV qualifications and other factors to maximize GHG and criteria pollutant reductions.

    In 2012, the Board adopted increased ZEV credit requirements. This action, in concert with the development of strong comprehensive complementary policies to support infrastructure deployment and consumer awareness, led to the advancement of ZEV technology and growth in ZEV sales, the report finds.

    Modeling to meet the 2030 GHG targets indicates approximately three million additional ZEVs and PHEVs will be needed in 2026 through 2030. To reach these volumes with any certainty, a new regulation would need modifications that provide a more direct connection to vehicle volumes and require vehicle characteristics that best ensure market success. For such significant revisions to the regulation to be successful, however, it would require greater market acceptance, more technology advancements, and lower technology costs than is known with certainty today, the report finds.

  • Maintain the current ZEV stringency for California through 2025 model year including the existing regulatory and credit structure. Despite ZEV successes in California, it is widely recognized that the ZEV and PHEV market is still in the early stages of development. The current market has benefited from multiple purchase incentives that have substantially discounted ZEVs and PHEVs such that their prices are more aligned with those of conventional vehicles. Between 2018 and 2025, these and other incentives are expected to phase out. While decreased reliance on incentives is essential for building a self-sustaining market, it is unclear what consumer response will be without purchase and other incentives (such as high occupancy vehicle (HOV) lane access).

    Consumer awareness of ZEVs is still low and top motivations such as saving money on fuel are less influential as gasoline prices remain low. Given the market uncertainties that still exist in these early years, regulatory stability of the 2018 through 2025 model year standards can help ensure a continued path of increasing, but achievable, ZEV volumes, the report says.

  • Maintain the current ZEV stringency for California through 2025 model year including the existing regulatory and credit structure. PHEVs will continue to play a role in the electrification of transportation for long-term emission reduction targets. The adopted standards are consistent with ARB’s long-term modeling scenarios and already recognize PHEVs not only can help consumers and manufacturers transition to pure ZEVs but that they also can continue to be a significant share of the vehicle market.

    PHEVs are projected to make up more than 60% of all ZEVs and PHEVs on the road by 2025 even with the current use caps on PHEV credits. This indicates the current regulatory structure already provides sufficient flexibility as the ZEV market is developing to determine the role PHEVs will ultimately play, the report says. The new analysis does not support more flexibility for PHEVs at this time such as allowing manufacturers to comply with ZEV requirements with more PHEVs than currently allowed.

    While strong electric drive capability PHEVs with significant all-electric range and minimal engine starts are very encouraging, the analysis in this report finds that their benefits do not match or exceed those of pure ZEVs; thus PHEVs are credited less than pure ZEVs in the existing regulation. Furthermore, allowing for more credits per PHEV such that fewer total vehicles are needed to comply does not result in additional emission benefits or furtherance of the technology-forcing goals of the ZEV regulation.

  • Continue efforts by ARB and other stakeholders to accelerate and expand non-regulatory complementary policies that have been identified as successful in building market demand and removing remaining barriers to ZEV adoption.

Following a comment period, the Board will conduct a public meeting for staff of the Board to describe its ACC Midterm Review and recommendations, and obtain direction from the Board on future actions to develop and propose to the Board.



After 2025 a total ban on production and import on non-zero emission light duty vehicles should be implemented. Moreover, after 2030 make production and import of any non-zero emission vehicle illegal. We need to move that fast in order to prevent catastrophic global warming that could make agricultural production very difficult or impossible for most countries and that could melt the poles causing the world’s oceans to rise by 210 feet drowning most of today’s coast cities. We also need to go zero emission on all vehicles to prevent 7 million people from dying prematurely every year due to air pollution.

All we need to do to stop making polluting cars globally before 2030 is to build approximately 100 of those 50Gwh battery factories that Tesla is building. This is very doable within that timeline.

Dr. Strange Love

CARB. This is great news. Also, it looks like your services are no longer needed given the steady industry progress. We really appreciate your dedication and "duty to serve". You all have the opportunity now to relax and think about your next big challenge.

Brent Jatko

CA continues to lead the way.

It has such a large share of the personal transportation market that national automakers tend to follow CA regulations to preserve sales.

Dr. Strange Love

Brent. What is "the way"?

Dr. Strange Love

Change. Yesterday, my kids were telling me the same thing about the 100 Tesla battery factories. They heard it on Arthur, one of those popular kids' television programs.


Now is not the time to rest on our laurels. The previous GHG requirements were far too low for what is needed and what could have been done. The proof of that is how easily they have been met.


Millions of PHEVs running biofuels will reduce pollution and imported oil.


Hmm, someone in the comments section is making stuff up, and hopes no one will spot it. 'Arthur' stopped production in 2012 ( The first public mention of the Tesla Gigafactory was in 2013 (

Did car manufacturer's meet these standards because of CARB or in spite of it? If the former, then logically CARB should continue its work and its services are still very much needed.

Dr. Strange Love

CARB scorecard includes "REVENUE Generation". The ORG is a "Cash Cow" for the state right now. They certainly don't want the good times to end.

U.S. Treasury is no different. They will hold Fannie Mae and Freddie Mac in "Conservatorship" as long as these organizations' remain revenue generators.

Dr. Strange Love

BTW. CARB should be working on the regulations concerning the Ubiquitous House Hold Cloths dryer.

There is more Green House Emissions from this device than any other, period, end-of-story.

Problem is, CARB cannot extend Intuition past their own NOSE can detect. That is how myopic this ORG is.


DLS I know you can do the math but you didn’t do it so you thought it was impossible. So let me do it. 50GWh is equal to nearly 1 million Tesla Model 3 vehicles with a 55kwh battery and 100 factories can therefore make 100 million long range BEVs per year. Total investment required to make 100 50GWh factories is about 500 billion USD. Very manageable for a world with an 80,000 billion USD per year GDP.

Some BEVs will need larger battery packs but many more will need smaller battery packs. When self-driving taxis are in the second generation (with model 3 being the first) we will see small two seaters because 80% of all cars driving only transport 1 person so why not make the self-driving taxi smaller. The point is a two seaters can go over 200 miles on just 30kwh.

For a link to the 100 Giga factories to save the world from fossils see here with Musk and Leonardo DiCaprio.


"because of CARB"
California is car country, if you can not sell there you lose LOTS of revenue.

Dr. Strange Love

Like Brutus, like CARB. I am aware of the California Effect.

The impact is analogous to the all-or-nothing impact of state electorates in presidential elections. Trump did not win the popular vote. It is committee via weight or force, however you want to look at it. Screw 40+ other states.


The difference is vote winner takes all affects ALL Americans,
CARB affects Californians who can change it if they want.


The world has enough resources (and needs) to build REs, H2 stations, batteries mega-factories, ultra quick charge stations, BEVs and FCEVs to replace CPPs, NGPPs, fossil and bio fuels and most ICEVs.

It may not be enough to clean the environment, but it would be a good start.

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