Important work by Ramboll US Consulting has been published which illuminates that CARB, in the recent publication of its 2020 update to the Mobile Source Strategy, failed to meet statutory requirements as required by SB44 (2019). Instead of a robust update that considers deployment of technology options that are ready and cost-effective today, the strategy instead focuses myopically on electrification and results in a suboptimal outcome for California residents, businesses and local governments who are required to meet Federal deadlines for attainment of lower NOx levels in 2023 and 2031.
The resulting CARB 2020 Mobile Source Strategy update:
- Glosses over CARB’s own gross failure to deliver its own premises that were outlined in the 2016 Mobile Source Strategy, leaving significant portions of the state with the likelihood of being in non-attainment for Federal NOx standards that must be met by January 1, 2023.
- Does not address the need for these NOx reductions for non-attainment areas in 2023 and 2031, despite much higher costs associated with CARB’s all-in electrification-only scenario that back-end loads air quality benefits. Interestingly, even as late as 2037 the CARB scenario is delivering less NOx reductions than Ramboll’s Multi-Technology alternative.
- Relies heavily on the future value of LCFS credits that, per recent assessments, may become compromised by the penetration of electrification of transport in the future and require CARB to “reorganize” the LCFS and phase out electricity as a credit generating fuel. This would effectively “pull the rug out” from under businesses that relied on its value to justify the expensive projects and fleet acquisitions required by this strategy.
- Dismisses real-world considerations such as the ability to build out the electrical infrastructure required to reliably deliver low-carbon electricity to transportation.
The Multi-Technology Pathway developed by Ramboll:
- Leverages technology that is available today to deliver a 25x greater percentage of reduction in NOx in 2023 versus the CARB strategy, which is sustained through 2037.
- Delivers these results based on known technology costs today, versus the anticipation of lower costs in the future that are not yet proven.
- Incents a broader mix of renewable fuel technologies that would allow California to maintain its status as a leader for policy innovations to reduce GHGs and criteria air pollutants.
It is not too late to act upon these findings. CARB can amend its 2020 Mobile Source Strategy and consider these important revelations as it commences its 2022 Scoping Plan update – and should be strongly encouraged to do so.
Read the full report here.