Loopholes and Hurdles in CA’s Plan for Transportation Electrification

California is dreaming of a future where electric vehicles (EVs) will gradually replace internal combustion engines (ICEs) by 2035. That is when 100% of new vehicles sold in the state are required to be electric. The California Air Resources Board, which is tasked with the bulk of the responsibility for this massive change, recently released its comprehensive roadmap to reach that nirvana.

Transportation is the largest source of the state’s greenhouse gases, producing far more than the electricity sector.

As far as CARB is concerned, the path to full vehicle electrification is straightforward: Provide sufficient incentives for drivers to switch to EVs and for car manufacturers to make and sell them in sufficient numbers and invest in the necessary charging infrastructure so that the EV drivers can conveniently charge them. But it will be far more complicated than that in practice.

CARB figures an 8% annual increase of zero-emission vehicles market share will do the job starting from 16% at the end of the first quarter of this year. That is considerably higher than the 7.5% figure in 2020. It says that the market needs to double between now and 2026 and grow steadily thereafter.

Source; CARB

While ambitious in scope, there are challenges ahead.

California is already the biggest EV market in the US.

CARB’s roadmap assumes that the state’s grid will be able to fill the empty batteries of the new EVs. But that is an immense task if the cars are not charged off peak and do not include bidirectional capabilities to be able to also supply the grid.

California wants only electric cars sold starting in 2035 but power shortages expected this summer and beyond may slow reaching that target. Moreover, CARB’s plan is too narrow in scope, creating a few loopholes in its roadmap that may result in unintended consequences, according to A Gap in California’s Plan for the EV Future, a Blog posted on May 9 by James Sallee , a University of California, Berkeley professor.

“The proposed regulation, and the governor’s executive order, only specify rules and targets for new vehicles,” Sallee points out. They do nothing to encourage the retirement of ICE vehicles, “nor the roughly 6 million ICE vehicles that will be sold after 2026 if the car market follows the proposed schedule,” he adds.

Impact of the used car market

As Sallee notes, to actually reduce transportation pollution, you can’t ignore what is happening in the used car market. While the new vehicle market share of ZEVs was most recently 16%, “the California Energy Commission shows that ZEVs are still less than 2% of the entire vehicle stock, and this will change slowly .” That is well below what is needed for transportation electrification.

According to Sallee, there are other issues associated with the used car market, including a big loophole for those who want to stick to ICEs. “California residents would be free to import ICE vehicles from out of state, even after the mandate is fully phased in,” he warns.

Source: CARB

This matters, according to Sallee, because California’s ZEV mandate “creates a large, implicit subsidy to sell EVs in the state. This motivates automakers to market and discount their EVs in California relative to other states, over and above what consumers would demand." This creates an imbalance from “extra” used ZEV cars in California and a shortage elsewhere. "This will create price differences across states, which the used car market will tend to resolve by exporting used ZEVs out of California.” He points out that CARB cites evidence that already used EVs are "disproportionately exported out of state.” And the stronger the ZEV mandate, “the more powerful this force will be.”