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Pavley or Not, California ARB Developing Scoping Plan For Further Reduction of Greenhouse Gas Emissions from Passenger Vehicles

This chart by Dr. Lee Schipper plots real-world fuel consumption and emissions for national fleets calculated with VMT and fuel consumed. Note that Japan’s plot converges with that of the US before improving again recently. Click to enlarge.

California’s Global Warming Solutions Act of 2006 (AB 32) requires reduction of greenhouse gas (GHG) emissions to 1990 levels by 2020. To achieve that reduction, California must take major steps to reduce emissions from the transport sector—the largest source of GHG emissions in the state (38% in 2004).

The Pavley Bill (AB 1493), which mandates reductions in greenhouse gas emissions from new passenger vehicles, is currently the major component of that effort. However, even if implementation of the Pavley regulation were not uncertain (EPA denied the requisite waiver and the matter is in court, earlier post), both it, and the Low Carbon Fuel Standard under development (earlier post) still leave California with a shortfall in reductions required to go back to 1990 levels. (See table below.)

On-road Passenger Vehicle GHG Emissions
Million Metric Tons (MMT) in CA, 2020
ScenarioGHG (MMT)
Business as Usual 164
   With current Pavley reg. 137
   With Pavley 21 133
   With Low Carbon Fuel Standard 120
1990 Level (target) 106
   Shortfall with 3 policies above 14
   Shortfall w/o Pavley reg. 222
  1. Much larger benefits beyond 2020.
  2. Includes reductions due to Federal 35 mpg standard which is not included in the BAU scenario.

Furthermore, AB 32 contains what is known as “Pavley Backup” Requirement: §38590 states that if the Pavley regulations do not remain in effect—for whatever reason—ARB is required to implement alternative regulations to control mobile sources of greenhouse gas emissions to achieve equivalent or greater reductions.

Accordingly, the California Air Resources Board is preparing a draft Scoping Plan, as required by AB 32, to lay out how California will achieve the 2020 target. The plan may include new regulations, voluntary actions, and market instruments. ARB staff plans to release a draft this summer, and the board may consider it for adoption by the end of this year.

Given the uncertainty around Pavley implementation, devising alternatives becomes even more important. In support of this effort, ARB convened a one-day symposium in Sacramento this week to identify additional actions that can be taken prior to 2020 to further reduce greenhouse gas emissions from passenger vehicles.

While the first half of the symposium focused on potential vehicle technologies, the second half focused on market mechanisms, beginning with the efficacy of using feebates but then exploring other mechanisms and pricing policies, including vehicle fees proportional to their GHGs, congestion charging, and usage-based pricing for insurance.

Dr. Lee Schipper, Director of Research at EMBARQ and currently a Visiting Scholar at UC Berkeley, argued the most broadly that a combination of vehicle efficiency, reduction in vehicle miles traveled (VMT), and transport policies is required to reduce greenhouse gas emissions from the sector.

As an example, he pointed out that while nominally Japan has higher new vehicle fuel economy than the US, in terms of real-world consumption (liters gasoline equivalent/100km), Japan’s fuel intensity increased to match that of the US in the late 1990s, and stayed approximately even with it until beginning to improve again around 2003. (See chart above.)

One reason for that, Schipper pointed out, is the time the Japanese vehicles—even the small minicars—spend stuck in traffic.

Schipper suggested that California could take a number of steps, starting with raising the price of using a car with variable cost insurance—an approach also embraced by Michael Replogle, Transportation Director, Environmental Defense Fund at the symposium.

Schipper also suggested suing congestion and peak pricing where warranted, and raising the gasoline tax to finance transport locally. Also on the tax front, he suggested a revenue-neutral carbon tax—implementing an economy-wide carbon tax accompanied with a reduction in sales taxes. This would “scare away” fake biofuels, he said.

Following those, the state should strengthen its transit programs, and begin implementing careful land-use controls.

Boldness really matters. Pavley was bold. We have to do things like that to break the idea that we have to do things in small increments.

—Dr. Lee Schipper




If you want to reduce CO2 and pollution, streamline the process for certification of natural gas conversions. It seems like one part of government does not know what the other part is doing.



And this is why people like me don't like to depend on government too much when things need to get done. For instance, there are two state agencies that must approve any renewable energy project. Two completely separate bureaucracies. It's no wonder Texas surpassed us in renewable energy, and continues to eclipse the rest of the nation.


It is easy to fix, but state governments sometimes overlook it. They have so many things to deal with, this is not a major priority. It is not like the state is going to fail because there are not enough natural gas cars on the road, but they will fail if they do not fix the multi billion dollar budget deficit.

I have written emails to AQMD and others that are listed on the web sites asking for information. Replies are running 0 for 4 from agency employees that are suppose to respond to inquiries. Maybe they are real busy, but all I know is our tax dollars are paying their salaries and if they were a regular business we could take our business elsewhere.

I have run into similar situations on renewable energy in the past. A government employee in Santa Clara County was suppose to help promote renewable energy businesses. She had an email and phone number and when I contacted her to find out what programs they had to help, she said none. She was just there to "facilitate" renewable enery business, whatever that meant.

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