On Sat, 12 Oct 2002 12:30:34 -0400, you wrote:

>On 12 Oct 2002 at 4:01, josh wrote:
>
>> *How* is the ZEV mandate a fuel economy standard?
>
>The automakers fought to place CAFE (fuel efficiency) under the control of 
>the highly cooperative NHTSA, and get a guarantee of no "interference" in 
>the matter from state control.  Then, they made the bizarre and brazen 
>contention that CA's proposed rulemaking controlling CO2 emissions was an 
>attempt to regulate fuel efficiency because -- according to them -- the only 
>way to reduce CO2 emissions is to reduce fuel usage.

But even aside from all that, California's recent attempt to regulate
CO2 emissions is not the ZEV mandate.  They are, unless I am mistaken,
two very different laws.

Now, I grant you that if the truth were told, many people who are fans
of the ZEV mandate are fans of it because it might help improve
overall mpg, various environmental concerns as well as emissions
issues.... in an interconnected-issues sort of way.  But, from a legal
standpoint, it is not clear to me that ZEV is the recent anti-CO2
statute.

Ok, so are they saying that by defining zero emissions as also
including CO2, they're making the ZEV mandate into an anti-CO2 thing?
I guess you might make that case.  But CARB seems like it's saying,
with the various SULEV classifications and such, that it is amenable
to near-zero claims by auto manufacturers as being quite a bit of
progress.

Even if CARB's ZEV mandate policy is anti-CO2 or even if it works out
that by requiring virtually no bad emissions, it is hard to burn
hydrocarbons, this is still not a mileage mandate of any sort, that I
can see.  Maybe since emissions go up, for any given fuel, the more
you use, and so by improving mileage and keeping emissions constant,
as I think you spell out?

The ZEV mandate is fundamentally about emissions at the point of fuel
use, not about mileage.  I'm not sure how this will play in the
courts, but I'm pretty sure that California has a legal right, by
agreement with the Federal Government to plot a different course on
emisssions, given their arguably emergency-level-smog situations that
occassioned much of their clean-air concerns, and, it should be added,
the despicable recalcitrant unresponsive attitude of  the
manufacturers when California sought some relief and better
technology.

It's not often said so I will say it: 

When you're a damn good customer, you ought to rate better treatment.
We buy a lot of cars here, and we ought to get some responsiveness
from Automakers when we ask for better-mileage cars and
better-emission cars.

jl

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