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CARB’s Mid-Term Review of Fuel Economy Aligns with EPA’s

01.18.17 | Blog | By:

All of the focus on fuel economy standards in the U.S. has been focused at the federal level, but the California Air Resources Board (CARB) has been working on its own mid-term review of its 2022-2025 standards (which are aligned with the federal government’s), which it released this week.

No surprises: CARB has “confirm[ed] that the previously adopted package of GHG standards, technology-forcing zero-emission vehicle standards, and the most health-protective particulate matter standards in the world are appropriate.”  And CARB is aligning with EPA on its decision to speed up the final determination on the standards (initially scheduled for April 2018). Incidentally, those GHG standards were finalized on January 12, 2017. EPA noted in a statement:

“This final determination finds that automakers are well positioned to meet the standards at lower costs than previously estimated. The Administrator is choosing to retain the current standards to provide regulatory certainty for the auto industry despite a technical record that suggests the standards could be made more stringent.”

That leaves the National Highway Traffic Safety Administration (NHTSA) which is responsible for setting the corporate average fuel economy standards (the non-GHG part of the regulation). Those standards are expected to be set for the 2022-2025 model years sometime in the next year.

Notably, in a Senate hearing this week, Oklahoma Attorney General Scott Pruitt, President-Elect Trump’s pick for EPA Administrator, said that he would review EPA’s decision to lock in the fuel economy regulations. Not only that, he also would not commit to allowing California to continue its own program at the same time CARB has announced its intention to set post-2025 standards (see quote below). In short, I see a showdown is coming between CARB and the Pruitt-lead EPA, assuming he is confirmed.

CARB’s Mid-Term Review Findings and Recommendations

Turning back to CARB’s mid-term review, CARB notes that:

“Similar to the federal evaluation, CARB staff’s analysis found that conventional technology to achieve those standards is moving at a faster pace than originally expected, and that achieving those vehicle emission limits is feasible, and will result in cost-savings for consumers.


CARB staff’s recommendations align with the Final Determination signed on January 12, 2017, by U.S. EPA confirming the federal GHG vehicle standards for the 2022-2025 model years are appropriate. Maintaining the existing national GHG program through 2025 will help California meet its greenhouse gas reduction requirements and unique environmental challenges for the immediate future, avoiding the need for California-only requirements. But staff also finds that the national program is very modest in terms of promoting electrification needed to meet California’s public health and environmental needs beyond 2025. Staff therefore recommends that California make a major push now to develop new post-2025 standards while working with automakers, federal regulators and partner states to further develop the market for electric cars.”

Other findings and recommendations included:

  • Continue California’s participation in the federal program by maintaining the “deemed to comply” provision allowing for compliance with the adopted U.S. EPA GHG standards for 2022 through 2025 model years.
  • 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.
  • 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.
  • 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 plug-in hybrid electric vehicle (PHEV) qualifications and other factors to maximize GHG and criteria pollutant reductions.
  • Maintain the current ZEV stringency for California through 2025 model year including the existing regulatory and credit structure.
  • Maintain the existing flexibilities, including as amended in 2014, for intermediate volume manufacturers (IVMs).
  • Maintain the existing credit structure and use caps for PHEVs through the 2025 model year.
  • 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.
  • Maintain the adopted flexibilities for the states following California’s ZEV program.

Following a comment period, CARB will conduct a public meeting for staff to describe its midterm review and recommendations, and obtain direction on future actions to develop and propose to the Board.

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