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CARB approves Clean Miles Standard for TNCs

The California Air Resources Board (CARB) has approved the US’ first standard to transition ride-hailing fleets to zero-emission vehicles by 2030. The Clean Miles Standard (CMS) (earlier post) sets electrification and greenhouse gas emission targets for transportation network companies (TNCs)—e.g., Uber and Lyft.

The goals of the CMS are to:

  • Reduce GHG emissions

  • Increase vehicle electrification

  • Reduce vehicle miles traveled (VMT)

The now-approved program will be implemented in January 2022, when TNCs submit two-year plans. Compliance begins in 2023.

Studies have shows that the rise of Uber and Lyft has pulled riders away from public transit and other forms of transportation and increased air pollution in US cities. Surveys of California riders, for example, indicate that 24% of non-pooled rides and 36% of pooled trips would have been taken via mass transit, walking or biking, or not taken at all.

According to a 2020 Union of Concerned Scientists (UCS) analysis, ride-hailing trips are 69% more polluting than the trips they replace, and a non-pooled Uber or Lyft ride is 47% more polluting than a private car trip.

In the presentation of the CMS at the Board meeting, CARB staff noted that 1.5% of California’s light-duty VMT—4.3 billion miles—was associated with TNCS in 2018. The TNC VMT broke out into 62% Passenger VMT and 38% Deadhead VMT.

Staff also presented that 1% of California’s light-duty GHG emissions come from TNCs.

The CMS electrification targets use the metric of percent electric vehicle miles traveled (eVMT); GHG emission targets are set using the metric of grams of CO2 per passenger-mile-traveled (g CO2/PMT).

The regulation will also support active transport and public transit by providing regulatory compliance credits for use with the GHG emission target when TNCs facilitate those modes of travel.

The electrification and GHG targets start in 2023 at 2% eVMT and 252 g CO2/PMT, respectively, and slowly increase in stringency to 90% eVMT and 0 g CO2/PMT in 2030. (Note that the GHG target in 2030 is effectively equivalent to 100% eVMT in TNC fleets.)

The electrification targets can only be met with electric miles driven with passengers in the car using a battery-electric vehicle (BEV) or a fuel-cell electric vehicle (FCEV).

TNCs have a number of options for reducing company-wide GHG emissions to comply with the annual targets. These include improving fleet-wide fuel efficiency; reducing VMT by increasing shared rides; reducing VMT by reducing deadhead miles; and earning CO2 credits by investing in active transportation infrastructure, or by providing integrated fare services to connect riders to mass transit.

The proposed regulation also includes requirements for annual data submittals, annual compliance reports, and biennial compliance plans.

Small TNCs whose operations result in five million annual VMT or less statewide will be exempt from meeting electrification and GHG targets. Small TNCs are not exempt, however, from continued annual data submittals as part of the TNC permit requirement. Small TNCs are also exempt from the requirement to submit two-year (biennial) plans and annual compliance reports. If a small TNC grows to exceed five million VMT in a given calendar year, they will be subject to the requirements beginning the following calendar year.

To assess cost and emission impacts, CARB staff modeled compliance with the GHG target given that it is the more stringent of the two requirements. This target was used to estimate reductions in GHG emissions, criteria emissions including NOx and PM2.5, and health costs for California residents.

CARB staff estimates cumulative statewide emission reductions from the proposed regulation from 2023–2031 to be 93.21 tons PM2.5, 298.03 tons NOx and 1.81 million metric tons (MMT) CO2.

In addition, the proposed regulation is estimated to result in a reduction of 0.36 MMT of CO2 in the year 2030, which represents a 0.39% reduction in the light-duty fleet for that year.

Emission reductions are estimated based on an assumption of 100 percent eVMT and do not include emission reductions that could come from implementing VMT reduction strategies for compliance with the GHG targets (e.g., pooling and deadhead mile reduction).


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