josh, in two separate posts, asked:

>  >> *How* is the ZEV mandate a fuel economy standard?
>>
>California's recent attempt to regulate
>CO2 emissions is not the ZEV mandate.  They are, unless I am mistaken,
>two very different laws.

You are correct on that latter point, that the ZEV and the CO2 rule 
are different provisions.  To the best of my knowledge, the CO2 
standard is being challenged simply on the basis that it is a 
disguised attempt to regulate miles per gallon.  One of the 
lynch-pins of the auto-makers' legal claim is that CO2 has never been 
regulated in the past, so this extension of the law by California 
regulators was not contemplated by the lawmakers who originally 
granted California the power to lower emissions standards below the 
federal requirements.  But you are correct that this has nothing 
directly to do with the ZEV.

However, the ZEV can still be (and actually is being) challenged on 
the same grounds.  How?

A later news post from Bruce provides the answer:

>http://www.bizjournals.com/sacramento/stories/2002/10/07/daily36.html
>The state Air Resources Board set rules last year revising
>the state's "zero- emission vehicle" guidelines. The
>revisions stepped back from prior guidelines, which called
>for 10 percent of all vehicles sold in California by the
>2003 model year to have no emissions, essentially mandating
>electric cars.
>
>The revised rules, driven in part by the technical and
>marketing problems with electric vehicles, cut the
>requirements to 2 percent electric cars (about 4,600
>vehicles) and a mix of gasoline-electric hybrids and "very
>low emission" vehicles. The fuel economy of the hybrids
>would be a factor in how much they count against the
>electric-vehicle requirement.

Since mileage is directly connected to a manufacturer's compliance 
with the ZEV, there's your nexus.  After reading this summary (and 
not having read a word of the actual statutes at issue, by way of a 
warning to the reader) I'd have to conclude that the auto-makers have 
a pretty good case.  Of course, the provisions tying mileage to 
compliance with the ZEV may be severable, allowing the law to be 
enforced in a limited way, depending on the precise wording of the 
statute, so even if the state loses, it may not be a total loss. 
And, of course, there are plenty of ways to re-write the statute that 
would not cause a tie-in with vehicle mileage, if that becomes 
politically feasible within the state.

-- 

-Adam Kuehn

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