Midterm Review


At the urging of the automotive industry in 2012, when California finalized its Clean Cars Program and U.S. EPA and NHTSA finalized federal GHG and fuel economy standards harmonized with California’s rule, all parties agreed to a midterm review process to assess the progress of the regulations and allow for adjustments, if needed. In 2016 and 2017, two concurrent midterm reviews are underway. One is for the harmonized National Program for fuel economy and greenhouse gases; it is being conducted jointly by U.S. EPA, NHTSA, and ARB. The second review is a California-only process to review California’s ZEV regulation and its Low Emission Vehicle (LEV III) standards.

As a part of this review process, ARB staff is evaluating the growing ZEV market, consumer demand, and data related to vehicle adoption, infrastructure development and technological advancements in ZEVs since the 2012 rulemaking. The Board will review the staff assessments and stakeholder input before deciding whether adjustments are needed.

Today, advances in ZEV technology are thoroughly exceeding expectations. When the ZEV rule was last revised, the average battery electric vehicle in 2018 was expected to have a real-world range of roughly 70 miles between charges, and no improvement was assumed through 2025. Already, today’s cars are way ahead. The 2016 Nissan Leaf has exceeded this goal, while the range of Tesla’s forthcoming Model 3 and the Chevy Bolt will exceed 200 real-world miles. As positive as these technology advancements are, the unforeseen result is that automakers build up more ZEV credits for their sales than regulators anticipated in 2012. Together with a multitude of provisions that allow automakers to gain extra and early ZEV credits, the result is a ZEV credit glut that threatens the 15 percent ZEV sales goal by 2025.

A “tune-up” of the ZEV regulation is necessary to ensure automakers produce enough vehicles to meet the regulatory goal of at least a 15% sales share in 2025 and the state’s goal to place 1.5 million electric-drive cars and light-trucks on the road by 2025. Failure to act could jeopardize the ability to meet climate and air quality targets and put the state on a trajectory inconsistent with the GHG reduction requirements under SB32, with the State Implementation Plan to meet National Ambient Air Quality Standards, and ARB’s own Mobile Source Strategy.