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March 27, 2003
Contacts:
Andrew Weisser, (818) 703-6444
aweisser@earthlink.net
or your local American Lung Association
at (800) LUNG-USA. www.californialung.org
American Lung Association of California Testimony
California Air Resources Board
Zero Emission Vehicle Program
March 27, 2003
Bonnie Holmes-Gen
Assistant V.P., Government Relations
Introduction:
I am here today on behalf of the American Lung Association of California (ALAC) and its medical section, the California Thoracic Society to thank you for your past record of support for the ZEV program and to urge the board to build on the successes that have already been achieved in zero emission technology. Specifically, the American Lung Association of California believes revision of the ZEV program must accomplish the following objectives:
- Promote zero emission fuel cell progress;
- Keep an open door to zero emission battery technologies;
- Increase regulatory requirements for hybrid-electric technology; and
- Continue to push ZEV advancement with clear, enforceable, and increasing regulatory goals over the next decade and beyond.
Unfortunately, the staff report before you today falls short in most of these areas and sends the wrong signal to the auto companies and the public. By proposing NO ZEV requirements in 2009 and after, the staff report sends the signal that car companies will be let off the hook from their longstanding commitment to get to zero emissions. Also, by focusing only on fuel cell technologies in the alternative compliance pathway, the staff report closes the door to battery technologies that are achieving real ZEV miles today. While we applaud an increased focus on advancement of fuel cells and believe there is great potential in this area, we do not believe that shutting out battery technologies is necessary or prudent. Furthermore, we would like to emphasize that establishing technology-forcing goals has been a key aspect of the board’s leadership and success in pollution control for several decades, and technology-forcing goals should continue to be a key element of the ZEV program.
As the board considers another major revision of the ZEV program, it is important to remember the purpose of the program. The program is not just about advancing vehicle emission control technology; it’s purpose is to improve public health by cleaning the air we breathe. As you are aware, the state board initiated the ZEV program in 1990 because it recognized that the state absolutely could not achieve the state and federal health based air quality standards without a major transformation of the vehicle fleet. Since 1990, those health-based standards have become even more stringent at the state and federal level as researchers uncover more information on the damaging health impacts of pollution, especially to children. In addition, the shortfall in emission reductions needed to achieve compliance has widened in many areas of the state, especially in the South Coast and more tools are desperately needed to make progress toward attainment. Since motor vehicles make up approximately 60% of the pollution inventory statewide, the ZEV program clearly has an important role to play. Now more than ever, California needs a strong ZEV program directed by a long term vision of pollution-free mobility and backed up by technology forcing goals.
Public Health Demands A Strong ZEV Program:
As you know from your monthly board updates on air pollution health effects and your recent review and revision of the particulate matter standard, the public health toll in terms of morbidity and mortality from pollution is extremely high. We now know that failing to achieve the state ozone and particulate matter air quality standards is contributing to at least 6,500 premature deaths every year with lives shortened by an average of 14 years. This number is roughly equivalent to the number of deaths linked to second hand smoke in the year 2000 (Estimates are 4200-7400 deaths from second hand smoke in 2000).
In addition to premature deaths, pollution contributes annually to hundreds of thousands of asthma attacks and illnesses for respiratory and heart conditions, thousands of emergency room visits and hospitalizations and millions of lost work days and lost school days. The health cost of these illnesses and hospitalizations alone is at least $1 billion dollars annually. Pollution also significantly impacts the basic growth and functioning of our lungs. We know that the lungs of children in highly polluted areas actually develop more slowly and have less reserve capacity, making them more vulnerable to the onset of lung illnesses or chronic respiratory disease later in life. Sensitive individuals including children and asthma sufferers are facing poor air quality one out of every three days — or more - in the South Coast and the San Joaquin Valley.
In summary, the more ZEVs and near-ZEVs we have on the road, the less pollution generated, and the less health effects that will be experienced. Every additional ZEV that is put on the road is reducing pollution that irritates asthma sufferers and keeps children home from school.
Recommendations:
We have forwarded the following specific recommendations to you as a joint proposal from our organization, the Natural Resources Defense Council and the Union of Concerned Scientists. My colleagues from these organizations will provide further comments on each recommendation.
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Re-design the "alternative compliance pathway" in the staff proposal to allow other ZEV technologies to compete, as long as a fuel cell floor is achieved. The number of vehicles required by 2008 should be increased to 500 vehicles (fuel cell vehicle equivalent), with a minimum floor of 250 fuel cell vehicles.
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Establish a minimum requirement for car companies to produce at least 5,000 fresh ZEVs (fuel cell equivalent) cumulatively in 2009-2011 and restore the ramp to the 2001 program. For the period 2009-2011, the board should restore a ZEV requirement that, if met through FCVs, would require at least 5,000 vehicles. For the next period, 2012-2014, the number of required vehicles should be increased to 30,000 across all automakers if met exclusively with FCVs. These requirements could not be met through banked credits but would require the production of new vehicles, as required in the pre-2009 time frame. By 2015, the 2001 program (or "red line") would be restored.
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Move the Expert Review Panel to a post-2006 time frame and ensure the panel’s scope is limited to technology review. We believe that moving the expert review panel to post-2006 is critical to ensure time for new steps in technology advancement to occur, and to allow the panel to get a better picture of the pace of advancement toward the end of this decade. In addition, we believe the panel’s scope should be narrowly defined to focus on technology review rather than making policy recommendations about ZEV levels.
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Strongly support the staff-proposed increased requirements for Silver Category AT PZEVs. We believe it is extremely important for the board to build on the existing success of advanced technologies by ramping up the requirements in this category, especially when the board is providing more flexibility and reduced requirements in the gold category.
The American Lung Association has a motto, which says, "When you can’t breathe, nothing else matters." We urge you to adopt the strongest possible ZEV program as a breath-saving strategy that is critical to improving public health for communities throughout California.
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