Key Takeaways

• Future Advanced Clean Car II (ACCII) regulations are a key policy plank to reduce emissions from the light-duty vehicle sector.
• There are three components of ACCII: Low Emission Vehicle (LEV) Criteria focusing on air quality improvements, LEV GHG -GHG reductions, and ZEV -technology advancement.
• Despite last week’s approved federal rollback to the national GHG and fuel economy standards, CARB continues to move ahead with programs such as ACCII, for the health of both the public and the economy. 

The Package

On May 28th, 2020, CARB held an informal discussion to review an update on a potential new package of Advanced Clean Car II regulations for post-2025 model year vehicles. CARB staff proceeded to give a presentation explaining how ACCII regulations will deliver vehicle emissions reductions by tightening standards, and preventing emissions backsliding as cleaner vehicles are introduced into California’s on-road fleet. Staff also outlined requirements intended to raise the quantity and quality of zero-emissions vehicles in California.

 A reminder

• Last month’s board meeting was on the mobile store strategy in the Scoping Plan update. This update indicated that deep emissions reductions would be needed in all sectors, including the light-duty vehicle sector, to meet the state’s carbon neutrality target by 2045, and for the South Coast to meet the 2031 and 2037 standards.
• The light-duty sector comprises a significant share of the state’s GHG emissions and nitrous oxide emissions.

 The ACCII package

The package contains three main components:

• LEV Criteria: provides standards for criteria pollutants such as nitrogen oxides, hydrocarbons, and matter that affects ambient air quality.
• LEV GHG: provides standards for pollutants such as carbon dioxide and methane. Reductions are needed to meet the SB-32 and carbon neutrality targets.
• ZEV: a technology-forcing program that requires vehicle manufacturers to produce an increasing number of ZEVs.

The stated objectives of ACCII are to:

1. Maximize criteria and GHG emission reductions from combustion vehicles.

• This means more stringent criteria for the GHG fleet average, robust PM emission control, and optimizing emission control for heavier vehicles. Some medium-duty vehicles qualify for using either chassis or engine testing for certification. The effects of higher loads and towing emissions will be explored, as will evaluating in-use standards for this category.
• Reductions can be achieved by aligning GHG standards to real-world performance, obtaining better control of engine start emissions, and addressing unique challenges for PHEV engine start emissions. Cold-starts account for over 70% of criteria emissions, regulations for better control of cold-start emissions are forthcoming. Reducing high power start emissions for truck/SUV/minivan PHEVs to reach the certification standard is also essential.

1. Accelerate the transition to zero-emission vehicles.

• Improving ZEVs for consumers would entail warranty and durability requirements, adding vehicle and battery state-of-health monitoring, raising minimum requirements for PHEVs to earn ZEV regulation credits, and standardizing fast charging ports. A limit to ZEV credit life can also increase certainty on future sales volumes. 
• These changes would need more non-regulatory support, a continuation of reductions in the carbon intensity of liquid fuels, and collaborations with other agencies to further influence vehicle purchases and usage.

The planned timeline of ACCII will see workshops beginning in the summer/fall of 2020, a preliminary proposal in winter 2021, a proposed regulation in spring 2021, a staff report in fall 2021, and finally, a board hearing in December 2021

Comments

Public commentators showed overwhelming support for the package, including Steven Douglas, who represented the Alliance for Automotive Innovation (AAI). Significantly AAI includes big names in the automotive industry, such as Ferrari, Ford, Kia, Mitsubishi, and many more. Support from automotive companies is promising when considering the impacts the package will have on the industry. 

A suggestion was also given by Chet France, on behalf of the Environmental Defense Fund, to implement more policies that would further accelerate the retirement of older internal combustion vehicles. France noted that carbon neutrality can only be reached with additional policies, even with 100% ZEV sales by 2035 and 80% near-term CO₂ reductions from the power sector.

Concluding Remarks: CARB

CARB seemed to unanimously agree on the importance of the ACCII package and supported the program, although some members did voice a few questions, concerns, and potential ideas. 

First expressed was an idea to collaborate with other industries in an attempt to figure out the changing infrastructure of the low emissions vehicle industry, this idea was met with agreement.

The staff was then asked to elaborate further on their discussion of raising requirements for plug-in hybrids, as to earn credits under ZEV regulation. Staff is still looking into the current plug-in requirements under the ZEV regulation, but future considerations would likely include tightening the requirements for plug-in hybrids to encourage hybrid technology to move towards all-electric. In some cases it could be feasible to impose the requirements on old vehicles, however, the new requirements would most likely only pertain to new vehicles.  While considering new vehicles, CARB pondered how they would increase market shares for the parts of the market consumers have yet to see, such as electric or hybrid trucks. Staff members acknowledged the concerns but informed CARB of their anticipation of the emergence of at least four model all-electric truck models in the next few years. These trucks would be able to receive a rebate under the clean vehicle rebate project, on the condition they fall under the MSRP cap.

Addressing the “chicken & egg” problem: LCFS and ACCII

The Advanced Clean Cars program is designed to work in conjunction with the Low Carbon Fuel Standard (LCFS) to achieve emissions reduction from the transportation sector. 

The latest discussions on ACCII provide an opportunity for California to increase penetration of zero-emission vehicles. Prior to ACCII’s current efforts to catalyze ZEV transition, LCFS amendments in 2018 allowed credit generation for ZEV infrastructure. This established two new fuel pathways namely the Hydrogen Fueling Infrastructure and Fast Charging Infrastructure. Since 2018, the number of LCFS credits generated through electricity and hydrogen has increased by 96% and 209% respectively. 

The next phase of the Advanced Clean Cars program promises to build on the existing successes of tandem programs like LCFS. These programs were inherently constructed to ensure the growth of supply (via LCFS) as well as demand (via ACCII) in the long-run, with the aim to subdue the “chicken & egg” problem plaguing the ZEV industry. 

Final thoughts:

CARB also considered the opportunities that the COVID-19 pandemic has presented. The economic downturn from the pandemic could potentially aid in their effort to change transportation companies. 

CARB further speculated what could be done until the majority of vehicles are EVs or ZEVs. The secondary market seemed of potential interest, as it could be a good opportunity to get the market into underserved communities. 

Overall, CARB wholeheartedly supported ACCII, only questioning how it could be improved or what could be done in the meantime. As of yet, it seems those questions are still under discussion, at least meetings like this give just a flavour of the regulators’ thinking.