2007 CARB ZEV Tech Review

Some comments to the CARB ZEV Technology Review. San Diego, CA May 24 & 25, 2007. Status report is found here.

Submitted by Darell Dickey.

Clerk of the Board
California Air Resources Board
1001 I Street
Sacramento, California 95814

Dear Air Resources Board Members:

While Battery Electric Vehicles (BEVs) are slowly regaining a small percentage of the respect that they deserve, the board continues to make inaccurate assumptions that undermine BEVs while simultaneously putting Fuel Cell Vehicles (FCVs) on a pedestal. Thanks to the CARB, in 1996 we had new ZEVs available to the public. Thanks to the promise of FCVs, today we have just a handful of used ZEVs being sold for astronomical prices – along with the promise of “future” FCVs. There is currently no way to purchase or lease a full-featured ZEV. How have we ended up in worse shape in 2007 than in 1996?

From the panel’s summary regarding BEVS:

“…the Panel concluded that in California, full-sized battery electric vehicles are still not likely to be a mass market technology in the foreseeable future due to high cost of the batteries, and limited customer acceptance.”

The “limited customer acceptance” assumes:

And of course these assumptions do not match reality. If BEVs had never been pressed into public service, would they be enjoying the same sort of “future perfection” distinction that is granted to the FCVs of the indeterminate future? If we had no practical, privately-driven, on-road experience with BEVs in the past, we would today be talking about hundreds of miles of range, recharge time measured in minutes and durability measured in 10’s of years and 100’s of thousands of miles. And all of this in a package that benefits from relatively simple and cheap infrastructure, and costs less than the cheapest FCV product to date! Instead, we DID have BEVs on the road in the late 1990’s and for the most part, they were fantastic vehicles that almost nobody wanted to let go of when the leases expired. And from the above assumptions – and also assuming that a modern BEV would be no better than what we could muster eleven years ago – we hear the conclusion that “full-sized battery electric vehicles are still not likely to be a mass market technology in the foreseeable future due to high cost of the batteries, and limited customer acceptance.”

After dismissing the mass marketability of Battery Electric Vehicles, the panel concludes about Fuel Cell Vehicles that “…while these challenges [of performance, cost, infrastructure, efficiency and durability] are not trivial, the past rate of success and the massive intellectual and financial resources being devoted to fuel cell vehicle technology, ensures that FCEVs remain a promising candidate for a future mass market true ZEV.”

Compared to BEVs being made by small auto makers today, the FCVs being made by the big players are not as durable, they cost more, they are less efficient, they lack performance and have close to zero infrastructure. Yet, because of the car makers’ “devotion” to FCVs, the board has determined that there is better mass market appeal for FCVs than for BEVs. Even though FCVs are still not available to the consumer eleven years after road-ready BEVs were (and in many cases still are!) serving as daily drivers. How can we continue to compare the past performance of BEVs with the promise of stellar *future* performance of FCV’s that seem to be pushed back every time they are discussed? BEVs can be on the road today, helping to keep our air clean. Instead we continue to wait for the perfect FCV to save us. To save us from the gasoline cars that the car makers will continue to churn out just as long as they keep being given the “Get out of Jail Free” card of making just a few FCVs for the foreseeable future.

We are pinning our hopes on a vehicle that has no “consumer ready” date even a decade after BEVs proved to be viable and desirable in the real world. FCVs will, at best, use 3-4 times more energy than a BEV. FCVs currently cost an order of magnitude more to build. FCV “mass marketability” is based on promises, and not real-world public acceptance. FCV technology has been chosen as the winner by the same industry that claimed unleaded gasoline would put them out of business; that bankruptcy would be the result of enforcement of the original CAFE standards. Should we not choose the winner simply by selecting the technology that is proven and ready today? Maybe tomorrow the winner will be different, and we can adapt. Why do we keep waiting, year after year, for FCVs to come close to the BEVs of eleven years ago?

With the same amount of funding and devotion, the same infrastructure effort, and given the same production costs, I simply cannot envision how a FCV could be better than a modern BEV by any metric. Yet I already know many of the ways that a BEV is better than a FCV – starting with the most obvious: An affordable BEV could be on the road efficiently driving with zero emissions today, just as they were eleven years ago.

Allow auto makers to continue down the FCV path at their own expense. But demand salable ZEVS now, and see what they come up with. Waiting for FCVs to be perfected is killing us.

Darell Dickey

Submitted by David Goldstein

Subject: Independent Expert Panel Report - Prospects for BEV Technology

I am Dave Goldstein, President of EVA/DC, the Electric Vehicle Association of Greater Washington since 1980, with more than 30 years of diversified experience with electric and hybrid vehicles and advanced battery systems. I have served on a number of U.S. Department of Energy advisory committees, including many years as a member of the Ad Hoc Advanced Battery Readiness Working Group (ABRWG.)

Thank you for the opportunity to review the 2007 ARB Independent Expert Panel Report on the Status and Prospects for Zero Emission Vehicle Technology. Although I have not had sufficient time to review the entire 207 page report, I have read through a great deal of it, and have been generally impressed with the depth of this effort to characterize the current state of energy storage, its metrics and implications for California, and effectively, for the entire world.

The panel has painstakingly characterized each technology, its strengths and weaknesses, market potential and presumed market penetration. It has done a particularly admirable job in describing the various Lithium-Ion battery chemistries and fuel cell challenges.

In so doing, however, the panel has, by nature of the questions posed, relied heavily upon industry sources and opinions to gather and produce this information. In the process – no doubt inadvertently – an unfortunate but pervasive automotive industry bias is evident throughout this report. Several statements and key assumptions, particularly with regard to economics and consumer attitudes, are highly questionable and should be reviewed with a critical eye by ARB staff, noting that industry opinions and regulatory actions are inherently at odds with one another,

Properly informed regulatory decisions, on the other hand, ultimately benefit both industry and consumers, by rationalizing the market, creating meaningful standards, accelerating critical mass in emerging technologies and thereby creating new business opportunities as well as consumer choices while ultimately providing cleaner air for all of us.

I do not envy the challenge before ARB staff. We are running out of time. Yet we are aiming at a moving target – Energy Storage – which has challenged us for most of the past century and which will likely challenge us for most of this one as well. Thus, a fundamental question that may or may not be properly framed by this report is, or should be: “When is good enough good enough?” It is up to ARB to decide.

Within that context, here are a few statements that I believe should be critically reviewed:

Page 3, NIMH costs – The panel states that “high costs remain the greatest challenge for battery and HEV manufacturers” as well as Medium Power and High Energy NiMH, then states that costs would be significantly reduced in 1 million systems per year to roughly 40 percent to no more than $2,500. This is about the cost of a premium sound package and/or GPS system in many vehicles and is more than eclipsed by the added cost premium of an SUV compared to a pickup truck or minivan. Yet consumers make that choice every day. If the value proposition is there – overlooked, apparently, by this panel, then why should “cost” remain the greatest challenge?

Page 3, etc. – The panel repeatedly compares initial battery prices to “lifetime fuel costs.”
While this may be one metric applied by consumers, it is not the sole determinant of consumer demand, and hence, market opportunity. Rather, it is a false argument presented by OEMs that do not presently offer hybrids in any significant numbers. In fact, – a more appropriate comparison would be lifetime vehicle costs including batteries (and for PHEVs, electricity) vs. lifetime costs for ICEVs, including fuel and maintenance.

Page 3, etc, -- Li-Ions are claimed to offer “lower specific costs,” yet the numbers shown for Medium Energy/Power Li-Ion batteries in mass production are about the same cost as NiMH’s in mass production. In fact, this matches the predictions of an EPRI study that found that both chemistries in mass production would ultimately cost about the same (approx. $250-300/kWh.) Yet the panel seems to be suggesting that OEMs – and hence CARB – should wait for Li-Ions to be perfected rather than to allow or encourage NiMH to accelerate the early adoption of PHEVs. Again, this is an OEM argument for delaying implementation of technology-forcing standards until battery technology is “mature.”

NiMH technology, as the panel correctly states, is relatively mature, as the panel states, and [this] has already [been] demonstrated. Now the argument seems to be, “Let’s wait for the next technology to come along before proceeding.”

Unfortunately time has run out to submit further comments. I would welcome the opportunity to continue this analysis with regard to Li-Ion, which indeed is a very promising near term technology.

But I must end my analysis here.


Dave Goldstein
President, EVA/DC

Submitted by William Korthof

Subject: Let’s Get Going.


I’m William Korthof, a business owner, Southern California resident, and EV driver. I drive a 2002 Toyota RAV4-EV. Last month my odometer rolled past 100,000 miles and the car continues to perform and meet all my needs. This turned out to be an all-around incredible car: completely trouble free, nearly maintenance free, and cost effective.

My company, EE Solar, is a leading residential electrical solar contractor in California. In addition to installing solar panels, we are committed to a cleaner California. The ZEV program matters to us because we actually drive clean air vehicles every day: 8 electric cars, 6 natural gas powered vans, and a natural gas sedan.

My observations:

I’ve read the latest technical report, and I noted some problems:


Consumers are more eager for electric cars than ever. Today, five-year-old RAV4 EV cars are reselling for more than than the original price, and more than double the price of a new gasoline counterpart.

ZEV mandate changes in 2002 allowed the car companies to abruptly halt this emerging market. The compromise with the car companies was supposed to lead to many fuel cell ZEV cars in the future. Five years ago, chairman Alan Lloyd insisted that fuel cell cars had tremendous promise, despite concerns from experts like Alec Brooks and Tom Gage. Time and billions of dollars in research have proven Alan Lloyd wrong; hydrogen faces the same insurmountable laws of physics. In all likelihood, these problems will always prevent hydrogen from being a viable fuel for cars: Five years, twenty years, or a century from now. The Fuel Cell pathway is a failure for getting ZEV cars on the road.

That brings us back to plug-in, battery electric cars: consumers want ZEV choices and California needs ZEVs. Battery electric cars already proved practical and effective, and time has shown us that sometimes, it takes laws to get business to do the right thing.

What to Do:

So now as your agency again considers changes in the ZEV program, I’d suggest a simple outcome as the key program goal: that California consumers have a selection of zero-emission options when they buy a new car. When the program succeeds, there should be a sizeable and growing number of ZEV cars every year.

The technology for plug-in cars is ready now and works. We need a ZEV program that gets real numbers of real ZEV cars on the road, not public relations gimmicks. We don’t need hundreds of pages of complicated multipliers and partial credit substitutions. Californians should have the choice of a car like my RAV4 EV. Your program is the key to getting that to happen. So Let’s Get Going!

My suggested new schedule for the ZEV program

Year ZEV Mandate All Trucks, SUVs, Cars ZEVs New ZEVs Cumulative
2008 0.1% 2000000 2000 2000
2009 0.2% 2000000 4000 6000
2010 1% 2000000 20000 26000
2011 2% 2000000 40000 66000
2012 3% 2000000 60000 106000
2013 4% 2000000 80000 186000
2014 5% 2000000 100000 286000
2015 6% 2000000 120000 406000
2016 7% 2000000 140000 546000
2017 8% 2000000 160000 706000
2018 9% 2000000 180000 986000
2019 10% 2000000 200000 1186000
2020 11% 2000000 220000 1406000

- William Korthof

Submitted by Mike Gaylord.

Subject: Zero Emission Vehicle Mandate

Please reinstate the legislation mandating manufacturers produce Zero Emissions Vehicles for sale in California --in this case, electric cars. In fact, the best thing would be to increase the percentage of cars brought in to this state, more than the original act called for.

Electric cars worked. People wanted them. Battery technology is good enough, and all the software and hardware worked. The cars
were built, and almost without exception, they were sweet. Manufacturers still have the plans to these cars, and truth be told they probably still have the factory dies and technology to start up again where they left off.

There is no good reason why they can't resume production. If they say they aren't ready, or that the technology is not proven, then they are lying. The cars worked. Please make them bring them back into production. That is what the people of this state --your employers-- want.

Submitted by Jerry Pohorsky.

Subject: Stop Driving with your Brakes on

The original ZEV mandate required 10% of all new cars sold in California to be ZEVs. Over the years many concessions have been made and a precious handful of BEVs were made available to the public such as the RAV4 EV that I now own and drive. I have over 60 K miles on it and drive it over 1,000 miles per month.

Thanks to the hard work of fellow EAA members, Toyota was persuaded to stop crushing these cars and allow them to remain in service. I used to have an EV1 but GM did not behave the same way as Toyota. Now GM is making noises about the Chevy Volt - probably because they realize that they can't pull off the fuel cell promise they made and will need something else electric to meet your requirements sooner or later.

If you had merely left the regulation alone we would have thousands of battery electric cars on the road by now instead of just a few hundred. Instead we have all these layers of nonsense like PZEV and FCVs that nobody can afford to build, buy, or fill with fuel.

Several times each week I am asked by someone how they can get an electric car like mine and I have to tell them that thanks to CARB, you can't. Nobody ever asks me how they can get a fuel cell car.

Please streamline the ZEV mandate and make it simple again. Otherwise you will reap the harvest of unintended consequences like you have in the past. Do you want more lawsuits from the automakers? Cars like mine prove that we already had the technology needed 5 or 10 years ago.

Battery improvements are nice but the Panasonic EV-95 was good enough already. Ask Chevron why we can't get those batteries anymore. Maybe their record profits have something to do with it. It is time you are accountable to the people who breathe the air in California instead of the ones with the deep pockets and expensive lobbyists.

All I ask is that you go back to the original 10% requirement and let the automakers figure out how to get there. It would not surprise me if there were lots of Battery Electric Cars in dealer showrooms as a result. All of these other modifications to the mandate have resulted in fewer ZEVs, not more.


Jerry Pohorsky

Submitted by Mark Looper.

Subject: Expert panel report too optimistic about FCVs, pessimistic about FPBEVs

Thank you for the opportunity to submit comments about the ZEV independent panel report. I write as a long-time user and advocate of alternative fuels; I have owned natural-gas vehicles since 1993, and in 1998 I drove my CNG Dodge van from Los Angeles to Maine and back to draw attention to the viability of fuels besides gasoline and petrodiesel. Since 1998 I have maintained a web site on the topic, now at www.altfuels.org.

After reading the panel's report, I am concerned that they reached conclusions about the relative viability of full-performance battery EVs and fuel-cell vehicles that are driven more by the automakers' priorities than by the inherent merits of the technologies. Specifically, the panel notes that no substantial improvement in hydrogen storage will be possible without breakthroughs in technologies that are not out of the lab yet; they also note that the fuel cell stack itself must improve in many different directions (higher power density, greater durability, lower cost) that conflict with one another, so that the simultaneous solution of all the problems will again require technological breakthroughs. As far as I could tell, though, their status projection amounts to saying that "with all the effort being expended on these tasks, success seems likely," and their timeline for scale-up of manufacturing amounts to saying that "once these problems are solved, commercialization will occur quickly."

By contrast, their conclusions about FPBEVs start from the automakers' assertion that these are too limited to progress beyond niche-vehicle status, and they proceed from this to note that there has not been much improvement in batteries suitable for FPBEVs because of lack of automaker interest, nor is likely to be. I am, of course, aware that the panel's charter was by necessity circumscribed, and they were charged with evaluating the status of technologies as they found them; however, they were also charged to make projections for scale-up of manufacturing, and this involves assumptions about what will be as well as observations of what is. In this case, it seems that the panel accepted at face value the automakers' denigration of FPBEVs.

A year after "Who Killed the Electric Car?", the Air Resources Board has an opportunity to revisit this question. As a pre-emptive strike against negative publicity from that film, GM bought full-page newspaper ads and Google AdWords to drive traffic to a blog posting defending their actions with regard to the EV1; I posted a page at http://www.altfuels.org/misc/onlygm.html with a detailed, point-by-point rebuttal of GM's spin. Other automakers are equally guilty of misrepresenting both their level of effort to "sell" (in most cases, of course, actually only lease) FPBEVs several years ago and also the level of consumer interest in the vehicles. Ed Begley, Jr., famously said that FPBEVs were so limited that they could serve the needs of "only" 90% of the population; the true potential market is likely smaller than that, of course, but certainly it should include a large fraction of two-car households. What needed, and needs, to be done is (1) to make the vehicles actually available and (2) to base a sales pitch on the advantages of the vehicles, namely that even without exotic batteries they have enough range for the vast majority of daily driving on an overnight charge that leaves you with a full "tank" of cheap fuel every morning, and they free you from smog checks, tune ups, and rush-hour gas lines, and on top of that you have all of your torque available off the line. Automakers failed to do either (1) or (2).

The panel concluded, without having any specific reasons that I could divine from their report, that the huge obstacles to commercializing fuel-cell vehicles will be overcome simply because automakers and component suppliers are putting so much effort into the task. But surely it's a lot easier to change customer preferences with public education, i.e., advertising, than it is to fight the laws of physics! The automakers claim they tried but failed to commercialize FPBEVs several years ago; if, like many observers, the Board sees through this claim, then surely it seems reasonable that you should require them to divert some of the resources being (in the view of many) squandered on fuel cells to make another, honest try at tasks (1) and (2), with tighter supervision this time to keep them from "faking it" (by making the vehicles nearly impossible to get, by running minimal and not very persuasive ads, etc.). In the MOA period, automakers promised to produce enough FPBEVs to "meet demand," which gave them an incentive to claim there wasn't any demand to meet; then a few years ago, they promised to ramp up FCV production starting at the end of this decade, if only they would be let out of making battery EVs. Now I understand that automakers want the FCV introduction timing stretched by another decade. "Fool me once, shame on you; fool me twice, shame on me," but there isn't a proverb to cover allowing oneself to be fooled three times in a row! I urge the Board to hold the line on the present ZEV regulations, and if automakers can't keep their fuel-cell promises, then let them be forced to make an honest effort this time to build and sell plug-in vehicles.

- Mark Looper

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