Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
California Air Resources Board
Appendix G
ACC II ZEV Technology Assessment
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
Table of Contents
I. Introduction ............................................................................................................................ 5
II. Electric Vehicle Technology: Status and Trends .................................................................... 8
A. Current and Future ZEVs and PHEVs ................................................................................ 8
B. Increase in All Electric Range .......................................................................................... 21
C. Battery Electric Vehicle Improvements ........................................................................... 23
1. Increase in Battery Pack Energy Capacity .................................................................... 23
2. Dedicated BEV platforms ............................................................................................. 24
D. Plug-in Hybrid Electric Vehicle Improvements ................................................................ 25
E. Fuel Cell Electric Vehicle Improvements ......................................................................... 26
III. Battery Technology for ZEVs and PHEVs: Status and Trends ............................................. 28
A. Lithium-ion Battery Overview .......................................................................................... 28
B. Battery Durability ............................................................................................................. 31
1. Factors Impacting Battery Durability and Degradation ............................................... 33
2. Battery Electric Vehicle Durability Improvements ........................................................ 35
C. Battery Trends and Future Improvements ...................................................................... 36
D. Energy Efficiency Improvements ..................................................................................... 39
E. Critical Materials for Electric Vehicle Batteries ................................................................ 41
F. Battery Recycling and Reuse ........................................................................................... 42
1. Battery Reuse and Repurposing ................................................................................... 42
2. Battery Recycling .......................................................................................................... 44
IV. Battery Assumptions and Costs ......................................................................................... 46
A. BEV and PHEV Efficiencies .............................................................................................. 46
B. BEV and PHEV Battery Assumptions and Costs .............................................................. 47
C. FCEV Battery Assumptions and Costs............................................................................. 50
D. Fuel Cell System Assumptions and Costs ....................................................................... 51
V. Non-Battery Component Assumptions and Costs .............................................................. 54
VI. Delete Costs ....................................................................................................................... 60
A. Background and methodology for standard ICEVs to convert to ZEVs .......................... 60
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
B. ICE and Transmissions Removal Costs ............................................................................ 60
C. Criteria pollutant emissions technology removal costs ................................................... 61
D. GHG reduction equipment technology removal costs ................................................... 61
E. ZEV Assembly Reductions ............................................................................................... 61
VII. Rolled Up Incremental Technology Costs ......................................................................... 62
A. Add-on Technologies (Cold, eAWD, Towing) ................................................................. 62
1. Cold Weather Package ................................................................................................ 62
2. Towing Package ........................................................................................................... 63
3. Electric All-Wheel-Drive (eAWD) .................................................................................. 64
VIII. Direct Manufacturing Cost Results ................................................................................... 66
IX. References .......................................................................................................................... 69
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
List of Figures
Figure 1. California New Vehicle Market Share of ZEVs and PHEVs from 2012 to 2021 .......... 7
Figure 2. 2021 ZEV and PHEV Models by Class Size .............................................................. 11
Figure 3. Aggregate ZEV and PHEV Models Projected by Model Year Through 2025 .......... 12
Figure 4. Anticipated ZEV and PHEVs Available by EPA Size Class for New Model Year 2022-
2025 Offerings ........................................................................................................................ 13
Figure 5. Battery Electric Vehicle Maximum and Median Ranges from Model Year 2011 to
2021......................................................................................................................................... 22
Figure 6. Plug-in Hybrid Electric Vehicle Maximum and Median Ranges from Model Year
2011 to 2022 ........................................................................................................................... 23
Figure 7. Cylindrical and Prismatic lithium-ion battery ........................................................... 30
Figure 8. Battery Pack Costs for BEVs and PHEVs for Model Years 2026 through 2035 ........ 49
Figure 9. FCEV Battery Pack Specific Costs ............................................................................ 51
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
List of Tables
Table 1. New BEV, FCEV, and PHEV Annual Sales and Market Share in California ................. 6
Table 2. Electric Vehicles Available by Manufacturer, Model Year 2021 .................................. 9
Table 3. Anticipated New ZEVs and PHEVs Introduced in Model Years 2022 to 2025 .......... 13
Table 4. Public Announcements of Manufacturer Long-Term ZEV and PHEV Targets and
Production Goals ..................................................................................................................... 18
Table 5. Jurisdictions with 100% ZEV Sales or Phase-Outs of Gasoline, Diesel, or Fossil Fuels
................................................................................................................................................ 20
Table 6. Energy Density of Battery Technologies ................................................................... 37
Table 7. BEV and PHEV Efficiency Modifications to 2021 ANL Autonomie Report Data for Use
in Development of CARB Staff Projected Battery Pack Sizes ................................................. 47
Table 8. Small SUV Charge Depleting Energy Efficiency (Wh/mi)........................................... 47
Table 9. Small SUV Total Battery Energy (kWh) ...................................................................... 47
Table 10. Total Battery Pack Costs for Small SUVs ................................................................. 50
Table 11: Fuel Cell System power (kW) .................................................................................. 53
Table 12: Hydrogen Fuel Tank Size (kg) .................................................................................. 53
Table 13: Hydrogen Storage System Cost Model Coefficients ............................................... 53
Table 14: Fuel Cell System Cost ($/vehicle) ........................................................................... 53
Table 15: Hydrogen Tank Cost ($/vehicle) .............................................................................. 54
Table 16. Modifications to Electric Motor Power from 2021 Autonomie Report Data ........... 56
Table 17. Electric Motor Power for Small SUVs ...................................................................... 57
Table 18. Non-battery Component Costs ............................................................................... 59
Table 19. Small SUV Non-Battery Costs .................................................................................. 59
Table 20. Applicability of Additive ZEV Technologies ............................................................ 62
Table 21. BEV 300 and 400 Cold Weather Costs .................................................................... 63
Table 22. eMotor Power for Towing Packages ....................................................................... 63
Table 23. Towing Package Costs ............................................................................................ 64
Table 24. AWD Mechanical Delete Costs Estimates ............................................................... 65
Table 25. Small SUV eAWD Package Costs ............................................................................ 65
Table 26. Small SUV ZEV and PHEV Non-Incremental Technology DMC ............................... 66
Table 27. Small SUV ZEV and PHEV Delete DMC ................................................................... 66
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
Table 28. Small SUV Incremental DMC ................................................................................... 66
Table 29. PHEV Incremental Cost by MY, Vehicle Class, Type, Drivetrain, and Towing
Capability ($) ........................................................................................................................... 67
Table 30. BEV300 Incremental Cost by Model Year, Vehicle Class, Type, Drivetrain, and
Towing Capability ($)............................................................................................................... 67
Table 31. FCEV Incremental Cost by MY, Vehicle Class, Type, Drivetrain, and Towing
Capability ($) ........................................................................................................................... 68
Table 32. BEV400 Incremental Cost by MY, Vehicle Class, Type, Drivetrain, and Towing
Capability ($) ........................................................................................................................... 68
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
I. Introduction
Since the adoption of the Advanced Clean Cars (ACC) regulations in 2012, zero-emission
vehicle technology developmentsfor battery electric vehicles (BEVs), fuel cell electric
vehicles (FCEVs), and plug-in hybrid electric vehicles (PHEVs)have progressed quickly. This
has led to the introduction of zero-emission vehicles (ZEVs) with longer all-electric driving
ranges and more efficient and capable drivetrains far earlier than expected. Looking to the
future of ZEV and PHEV technologies in the 2026 to 2035 timeframe, even greater efficiency
improvements, longer ranges, and vehicle offerings across all passenger car and truck
categories with comparable capabilities as conventional gasoline vehicles is anticipated.
ZEVs produce no exhaust emissions of any criteria pollutant under any possible operational
modes and conditions (BEVs and FCEVs). BEVs utilize batteries to store energy needed to
power electric motors, and FCEVs use hydrogen stored on board to create electricity from a
fuel cell in combination with a traction battery to power the electric motor(s). These electric
vehicles have instant torque response, low noise, regenerative braking that greatly reduces
brake wear and generally have a simple mechanical drivetrain, often with no transmission.
Similarly, plug-in hybrid electric vehicles use batteries to power an electric motor, but they
also use another fuel, such as gasoline, to power an internal combustion engine (ICE).
1
A
PHEV is defined as a vehicle that can draw propulsion power from multiple on-board sources
including a combustible fuel and a traction battery, with the ability to charge the battery from
an off-vehicle power source, such as the electric power grid. PHEVs can also be blended or
non-blended, where blended PHEVs refer to those that require the engine to meet the full
power demands of the vehicle before the battery has been depleted and non-blended
PHEVs are those that can drive fully electric even during high-power demand. BEVs, FCEVs,
and PHEVs collectively are referred to as electric vehicles.
By the end of 2020, the number of electric passenger vehicles reached 10 million
units worldwide, an increase of 42 percent from 2019.
2
China maintained the largest electric
vehicle fleet in the world with a total of 4.5 million electric vehicles, but for the first time
Europe had the largest annual increase in electric vehicles to reach a total of 3.2 million by
the end of 2020. The United States had about 1.8 million ZEV and PHEV registrations by the
end of 2020, with about 78 percent of newly registered electric cars in 2020 being BEVs.
3
While the ongoing health and economic crisis of the COVID-19 pandemic caused
conventional and new car registrations to fall in 2020, the global electric vehicle sales share
1
U.S. Department of Energy Alternative Fuels Data Center. n.d. How Do Plug-In Hybrid Electric Cars Work?
Accessed March 1, 2022. https://afdc.energy.gov/vehicles/how-do-plug-in-hybrid-electric-cars-work.
2
Hongyang, Cui, Dale Hall, Jin Li, and Nic Lutsey. 2021. Update on the global transition to electric vehicles
through 2020. International Council on Clean Transportation. Accessed March 1, 2022.
https://theicct.org/sites/default/files/publications/global-update-evs-transition-oct21.pdf.
3
International Energy Agency. 2021. Global EV Outlook 2021: Accelerating ambitions despite the pandemic.
International Energy Agency. Accessed March 1, 2022. https://iea.blob.core.windows.net/assets/ed5f4484-f556-
4110-8c5c-4ede8bcba637/GlobalEVOutlook2021.pdf.
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
rose 70 percent from 2019 levels as electric vehicle sales declined less than the overall
market.
4
In the United States, a large fraction of the electric vehicle sales occurs in California due to
strong consumer demand, regulatory mechanisms, and ZEV market support policies in the
state. New ZEV and PHEV sales in 2020 reached 145,099, which was a slight decline from
2019 sales given the impact of the global health and economic crisis, but sales rebounded to
250,279 in 2021. Table 1 shows details of new ZEVs and PHEVs sold over the last five years,
indicating that the California electric vehicle market continues to grow. Roughly 1,054,100
electric vehicles were sold cumulatively by the end of 2021, with California hitting its first
electric vehicle deployment goal of 1 million ZEVs and PHEVs by 2023 two years early.
5 6
This
puts California on track to reach the second goal of 1.5 million ZEVs on the road sooner than
the 2025 target as directed in Executive Order B-16-12.
7
These promising market signals in
combination with the Advanced Clean Cars II regulations will help California reach the goal of
5 million ZEVs by 2030 as directed by Executive Order B-48-18 and reach the goal of all new
passenger car and truck sales being electric by 2035 as directed by Executive Order N-79-20.
8 9
Table 1. New BEV, FCEV, and PHEV Annual Sales and Market Share in California
10 11
Metric
2017
2018
2019
2020
2021
PHEV New Sales
45,492
59,699
50,660
38,153
63,141
BEV and FCEV New Sales
48,095
97,444
96,687
106,946
187,138
Total New ZEV and PHEV Sales
93,587
157,143
147,347
145,099
250,279
Total New Vehicle Sales
2,183,293
2,251,593
2,153,747
1,864,164
2,016,192
PHEV Market Share
2.08%
2.65%
2.35%
2.05%
3.13%
BEV and FCEV Market Share
2.20%
4.33%
4.49%
5.74%
9.28%
4
International Energy Agency, Global EV Outlook 2021
5
California Energy Commission. 2022. "New ZEV Sales." California Energy Commission Zero Emission Vehicle
and Infrastructure Statistics Data. January 31. Accessed March 2, 2022. https://www.energy.ca.gov/files/zev-
and-infrastructure-stats-data.
6
SB 1275 (De León, Chapter 530, Statute of 2014) established the Charge Ahead California Initiative with the
goal of placing one million zero-emission and near zero-emission vehicles in California by 2023
7
Governor Edmund G. Brown, Jr. 2012. Executive Order B-16-2012. March 23. Accessed March 1, 2022.
https://www.library.ca.gov/wp-content/uploads/GovernmentPublications/executive-order-proclamation/39-B-
16-12.pdf.
8
Governor Edmund G. Brown, Jr. 2018. Executive Order B-48-18. January 26. Accessed March 1, 2022.
https://www.library.ca.gov/wp-content/uploads/GovernmentPublications/executive-order-proclamation/39-B-
48-18.pdf.
9
Governor Gavin Newsom. 2020. Executive Order N-79-20. September 23. Accessed March 1, 2022.
https://www.gov.ca.gov/wp-content/uploads/2020/09/9.23.20-EO-N-79-20-Climate.pdf
10
California Energy Commission, “New ZEV Sales”
11
California Energy Commission. 2021. "Vehicle Population." California Energy Commission Zero Emission
Vehicle and Infrastructure Statistics Data. April 30. Accessed March 2, 2022.
https://www.energy.ca.gov/files/zev-and-infrastructure-stats-data.
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
Metric
2017
2018
2019
2020
2021
Total ZEV and PHEV Market Share
4.29%
6.98%
6.84%
7.78%
12.41%
The electric vehicle market share of new light-duty vehicle sales in California has continued to
grow. California ZEV and PHEV market share held steady at about 7 percent of the new light-
duty vehicle sales from 2018 to 2020 before accelerating sharply in 2021. The growing
number of ZEV and PHEV models, continued expansion of California’s charging and
hydrogen fueling network, and the state’s commitment to strong electric vehicle incentives
has helped maintain a robust electric vehicle market. Figure 1 below shows the growth of
ZEV and PHEV market share in California from 2012 to 2021, with BEVs seeing a much larger
market share than other technologies from 2018 onward. The California electric vehicle
market share is expected to continue to increase rapidly as more ZEV and PHEV model
offerings enter the market and in vehicle segments not previously offered before.
Figure 1. California New Vehicle Market Share of ZEVs and PHEVs from 2012 to 2021
1213
Supportive ZEV policies, such as funding for ZEV infrastructure and purchase incentives, have
helped a growing electric vehicle market in California as technology costs continue to come
down. Despite impressive cost reductions in batteries and ongoing technology development,
BEVs, FCEVs, and PHEVs are projected to continue to have cost premiums relative to future
conventional internal combustion engine vehicles (ICEVs) in the early model years of the ACC
II regulations. In 2016, the Joint Agency Draft Technical Assessment Report (TAR) projected
12
California Energy Commission, “New ZEV Sales”
13
California Energy Commission, “Vehicle Population”
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
an incremental cost of $6,500 to $14,200 for PHEV40
14
and BEV200s
15
over an equivalent ICE
vehicle in the 2025 model year.
16
Incremental cost analysis recently completed by CARB staff
projects an incremental cost of $2,454 to $6,262 for 300-mile range BEVs for small cars to
pickup trucks respectively in the 2026 model year. These changes in incremental cost
projections represent updated ZEV technology innovations, including increased battery
energy storage performance, lower battery costs per kWh, and improved component
efficiency, collectively reducing system costs even while battery pack sizes increased. While
BEV costs are anticipated to reach cost parity with ICEV costs by 2030 for most vehicle
classes, PHEV and FCEV manufacturing costs are projected to continue to have a cost
premium over ICEVs through 2035. Costs for non-battery components are also declining due
to improvements in design and integration, demonstrated by several vehicle and component
teardowns. Integration and developments in non-battery components are expected to
continue, resulting in cost improvements of roughly 10 percent from the 2026 to 2035 model
year.
This appendix provides an assessment of the current state of the ZEV market, the progress of
BEV, PHEV, and FCEV technologies, and implications for the economic analysis of the ACC II
regulations.
II. Electric Vehicle Technology: Status and Trends
ZEV and PHEV technology continues to change rapidly as the industry responds to evolving
market pressures, consumer demands, and California, U.S., and other global regulatory
requirements. Manufacturers are now accelerating plans to bring more ZEVs and highly
capable PHEVs to the market while indicating plans to phase out new ICE vehicles. These
electrified vehicles utilize various technologies that continue to improve with ongoing
development. There have been several broader trends in ZEV technology taking place within
the industry: battery packs with increased energy capacity, vehicles with more electric range,
and expanding electric vehicle technology into various vehicle segments. These technology
improvements are leading to a wider range of ZEV and PHEV models that offer customers
more utility.
A. Current and Future ZEVs and PHEVs
The electric vehicle market has seen a significant increase in available models since the
Nissan Leaf and Chevrolet Volt 2010 market introductions. Currently, the market has
14
PHEV40 means a 40 mile all electric range (label) PHEV (non-blended)
15
BEV200 means a 200 mile all electric range (label) BEV
16
U.S. Environmental Protection Agency, U.S. National Highway Traffic Safety Administration, California Air
Resources Board. 2016. Draft Technical Assessment Report: Midterm Evaluation of Light-Duty Vehicle
Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards for Model Years 2022-
2025. July 2016. Accessed March 1, 2022.
https://nepis.epa.gov/Exe/ZyPDF.cgi/P100OXEO.PDF?Dockey=P100OXEO.PDF
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
increased from one
17
to 60 models offered through 2021.
18
This rapid market growth and
expansion of product offerings over the past decade is expected to accelerate significantly in
the next five years.
Consumers have different needs and expectations, especially when it comes to vehicles.
Vehicle choice and model availability across market segments is a critical decision-making
factor for new car shoppers, and a diverse selection of makes and models is an indicator for
market growth. According to research by the International Council on Clean Transportation
(ICCT), cities with more ZEV models available to consumers had higher electric vehicle
registrations.
19
Table 2 lists the 2021 model year ZEVs and PHEVs available by technology
type across different vehicle classes in the U.S. market.
20
Table 2. Electric Vehicles Available by Manufacturer, Model Year 2021
21
Make
Model
Vehicle
Type
Electric
Range
22
Audi
e-tron
BEV
222
Standard Sport Utility Vehicle 4WD
Audi
e-tron Sportback
BEV
218
Standard Sport Utility Vehicle 4WD
BMW
i3 / i3s
BEV
153
Subcompact Cars
Chevrolet
Bolt EV
BEV
259
Small Station Wagons
Ford
Mustang Mach-E
BEV
211-305
Small Station Wagons
Hyundai
Ioniq Electric
BEV
170
Midsize Cars
Hyundai
Kona Electric
BEV
258
Small Sport Utility Vehicle 2WD
Jaguar
I-Pace EV400
BEV
234
Small Sport Utility Vehicle 4WD
Kandi
K27
BEV
59
Compact Cars
Kia
Niro Electric
BEV
239
Small Station Wagons
MINI
Cooper SE Hardtop 2 door
BEV
110
Subcompact Cars
Nissan
LEAF (S/SV/SL)
BEV
149-226
Midsize Cars
Polestar
2
BEV
233
Midsize Cars
Porsche
Taycan (4/4S/Turbo/Perf)
BEV
199-227
Large Cars
Tesla
Model 3
BEV
263-353
Midsize Cars
17
One model from a manufacturer subject to the ZEV regulation in 2010.
18
Models here are defined as a unique vehicle offering, excluding trim versions of that model. For example, the
Nissan Leaf is offered in the S, SV, and SL trims, but the Leaf is only counted as one model.
19
International Council on Clean Transportation. 2019. The surge of electric vehicles in United States cities.
International Council on Clean Transportation. June. Accessed March 1, 2022.
https://theicct.org/sites/default/files/publications/ICCT_EV_surge_US_cities_20190610.pdf
20
If trim levels of models are accounted for, there were 108 different models and trim varieties on the market in
2021.
21
U.S. Department of Energy and U.S. Environmental Protection Agency. 2022. Fuel Economy Guide: Model
Year 2021. March 2. Accessed March 4, 2022. https://www.fueleconomy.gov/feg/pdfs/guides/FEG2021.pdf
22
The electric range value represents the approximate number of miles that can be travelled in combined city
and highway driving before the vehicle must be recharged (assumes 55% city and 45% highway). The EPA
estimates are meant to be a general guideline for consumers when comparing vehicles; however, range will vary
depending on factors like cold weather, accessory use (such as A/C), and high-speed driving, which can lower
the vehicle’s range significantly.
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
Tesla
Model S
BEV
334-405
Large Cars
Tesla
Model X
BEV
300-371
Standard Sport Utility Vehicle 4WD
Tesla
Model Y
BEV
244-326
Small Sport Utility Vehicle 4WD
Volkswagen
ID.4
BEV
240-260
Small Sport Utility Vehicle 2WD
Volvo
XC40 AWD BEV
BEV
208
Small Sport Utility Vehicle 4WD
BMW
i3 / i3s with Range
Extender
BEVx
126
Subcompact Cars
Honda
Clarity Fuel Cell
FCEV
360
Midsize Cars
Hyundai
Nexo / Blue
FCEV
354, 380
Standard Sport Utility Vehicle FWD
Toyota
Mirai Limited / XLE
FCEV
357
Compact Cars
Audi
A7 quattro
PHEV
24
Midsize Cars
Audi
A8 L
PHEV
18
Large Cars
Audi
Q5
PHEV
19
Small Sport Utility Vehicle 4WD
BMW
330e
PHEV
23
Compact Cars
BMW
330e xDrive
PHEV
20
Compact Cars
BMW
530e
PHEV
21
Compact Cars
BMW
530e xDrive
PHEV
19
Compact Cars
BMW
745e xDrive
PHEV
17
Large Cars
BMW
X3 xDrive30e
PHEV
18
Small Sport Utility Vehicle 4WD
BMW
X5 xDrive45e
PHEV
31
Standard Sport Utility Vehicle 4WD
Bentley
Bentayga
PHEV
18
Standard Sport Utility Vehicle 4WD
Chrysler
Pacifica Hybrid
PHEV
32
Minivan - 2WD
Ferrari
SF90 Stradale Coupe
PHEV
9
Two Seaters
Ford
Escape FWD PHEV
PHEV
37
Small Sport Utility Vehicle 2WD
Honda
Clarity Plug-in Hybrid
PHEV
48
Midsize Cars
Hyundai
Ioniq Plug-in Hybrid
PHEV
29
Midsize Cars
Jeep
Wrangler 4dr 4xe
PHEV
22
Small Sport Utility Vehicle 4WD
Karma
GS-6
PHEV
54, 61
Subcompact Cars
Karma
GT
PHEV
54, 61
Subcompact Cars
Kia
Niro Plug-in Hybrid
PHEV
26
Small Station Wagons
Land Rover
Range Rover / Sport PHEV
PHEV
19
Standard Sport Utility Vehicle 4WD
Lincoln
Aviator PHEV AWD
PHEV
21
Standard Sport Utility Vehicle 4WD
Lincoln
Corsair AWD PHEV
PHEV
28
Small Sport Utility Vehicle 4WD
MINI
Cooper SE Countryman
All4
PHEV
18
Midsize Cars
Mitsubishi
Outlander PHEV
PHEV
24
Small Sport Utility Vehicle 4WD
Polestar
1
PHEV
52
Minicompact Cars
Porsche
Cayenne
PHEV
15, 17
Standard Sport Utility Vehicle 4WD
Porsche
Panamera 4 e-Hybrid
PHEV
17, 19
Large Cars
Subaru
Crosstrek Hybrid AWD
PHEV
17
Small Sport Utility Vehicle 4WD
Toyota
Prius Prime
PHEV
25
Midsize Cars
Toyota
RAV4 Prime 4WD
PHEV
42
Small Sport Utility Vehicle 4WD
Volvo
S60 AWD PHEV
PHEV
22
Compact Cars
Volvo
S90 AWD PHEV
PHEV
21
Midsize Cars
Volvo
V60 AWD PHEV
PHEV
22
Small Station Wagons
Volvo
XC60 AWD PHEV
PHEV
19
Small Sport Utility Vehicle 4WD
Volvo
XC90 AWD PHEV
PHEV
18
Standard Sport Utility Vehicle 4WD
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
Currently available electric vehicle models span platforms from subcompact cars to large cars
and from small sport utility vehicles (SUVs) to minivans, confirming the technology is available
for a large portion of the light-duty market segment. The 60 available ZEVs and PHEVs in the
2021 model year spanned across ten EPA vehicle size classes and many came with all-wheel
drive capabilities.
23
Figure 2 below shows the number of ZEV and PHEV models offered by
technology type and EPA size class for existing model year 2021 vehicles. However, more
choices in larger vehicle categories like large SUVs and pick-up trucks in the electric vehicle
market are needed to attract more consumers and for ZEVs and PHEVs to become more
competitive with the ICEV market. This is critical in the United States where crossovers, sport
utility vehicles, light pickup trucks and vans (collectively defined as light-duty trucks)
represented over 76 percent of new sales in 2020 and 2021.
24
Within the light-truck sector,
the crossover segment accounted for 45 percent of all new light-vehicle sales.
25
New vehicle
models entering the market in the upcoming model years should begin to fill this gap, with
several light-duty truck products, including full-size pick-ups.
Figure 2. 2021 ZEV and PHEV Models by Class Size
While new vehicle sales in California are less dominated by light-duty trucks than in other
states, in California light-duty trucks’ share of the industry in 2020 and 2021 was
23
U.S. Department of Energy and U.S. Environmental Protection Agency. n.d. www.fueleconomy.gov:
Frequently Asked Questions. Accessed March 4, 2022. https://www.fueleconomy.gov/feg/info.shtml.
24
California New Car Dealers Association. 2022. California Auto Outlook: Comprehensive information on the
California vehicle market. February. Accessed March 4, 2022. https://www.cncda.org/wp-content/uploads/Cal-
Covering-4Q-21.pdf
25
Manzi, Patrick. 2021. “NADA Market Beat: December 2021.” National Automobile Dealers Association.
December. Accessed March 3, 2022. https://www.nada.org/WorkArea/DownloadAsset.aspx?id=21474865289.
3
1
4
2
3
5
3
1 1
2
5
6
3
2
9
6
1
0
2
4
6
8
10
12
14
Number of Models
EPA Size Class
Available ZEV and PHEV Models by Technology and EPA Size
Class, Model Year 2021
FCEV
PHEV
BEV
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
approximately 65 percent.
26
In 2021, nonluxury SUVs made up about 34 percent of all new
vehicle sales in California, with pickups and vans a distant second at 17 percent.
27
As more
ZEV models are introduced in varying vehicle classes and with more diverse and higher-range
BEVs, it is likely that market share will continue to increase. Manufacturers have announced
many additional vehicle introductions anticipated over the next several years specifically in
larger vehicle classes.
Figure 3 shows 179 available and expected ZEV and PHEV models by the 2025 model year.
CARB staff compiled an extensive list of all the currently available models (Table 2) and all
the future models that are expected to be released using publicly available news articles and
DOE/EPA data (Table 3).
28
In developing this figure, staff assumed that each vehicle model,
once introduced, would be offered for at least six model years aligned with the design cycle
of vehicles.
Figure 3. Aggregate ZEV and PHEV Models Projected by Model Year Through 2025
Vehicle diversity is also anticipated to grow significantly over the next few years with several
pick-up trucks, SUVs, and crossovers coming to market starting in 2022 and continuing to
grow from there. Figure 4 indicates that new ZEV and PHEV product offerings are expected
in broader market segments than currently available through the 2021 model year as
indicated prior in Figure 2.
26
California New Car Dealers Association, California Auto Outlook
27
California New Car Dealers Association, California Auto Outlook
28
M.J. Bradley & Associates. 2021. Electric Vehicle Market StatusUpdate, Manufacturer Commitments to
Future Electric Mobility in the U.S. and Worldwide. Accessed March 3, 2022.
https://www.mjbradley.com/sites/default/files/EDF_EV_Market_Report_April_2021_Update.pdf.
6
13
16
23 23
32
38
44
46
52
60
122
152
174
179
0
20
40
60
80
100
120
140
160
180
200
Number of Electric Vehicle Models
Electric Vehicle Models and Projections
BEVs PHEVs FCEVs
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
Figure 4. Anticipated ZEV and PHEVs Available by EPA Size Class for New Model Year
2022-2025 Offerings
A list of new ZEVs and PHEVs by model year is provided in Table 3, which are additional to
the 60 existing electric vehicle offerings that will continue to be offered in later model years,
as well. Staff utilized the EPA Size Classification for vehicle size as this is information is
publicly available as a reference for all current EPA certified vehicles. In most cases the stated
vehicle range is assumed to be the EPA label range unless otherwise noted. By 2026, the ZEV
and PHEV market will have expanded rapidly, with more platform offerings and increased
capability of vehicles to support continued ZEV sales growth.
Table 3. Anticipated New ZEVs and PHEVs Introduced in Model Years 2022 to 2025
Make
Model
Vehicle
Type
Electric Range
EPA Size Class
Alfa Romeo
Tonale
i
PHEV
50
Midsize
Aston Martin
DBX PHEV
ii
PHEV
TBD
Standard SUV
Aston Martin
Sportscar
(DBS/DB11/Vantage)
iii
BEV
372+
Two Seaters
Audi
A6 e-tron
iv
BEV
400 (WLTP)
Large
Audi
e-tron GT
v
BEV
238
Standard SUV
Audi
e-tron S (20, 21, 22in)
v
BEV
181, 208
Standard SUV
7
5
9
15
3
37
26
12
2
1
2
0
3
6
9
12
15
18
21
24
27
30
33
36
39
Number of Models
EPA Size Class
Anticipated EPA Size Class for New ZEVs and PHEVs Not Previously
Offered, Model Years 2022 - 2025
BEV
FCEV
PHEV
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
Make
Model
Vehicle
Type
Electric Range
EPA Size Class
Audi
e-tron S Sportback (20, 21,
22in wheels)
v
BEV
185, 212
Standard SUV
Audi
Q4 e-tron & sportback quattro
v
BEV
241
Small SUV
Audi
RS e-tron GT
v
BEV
232
Midsize
Audi
A4 e-tron
vi
BEV
TBD
Large
Automobili
Pininfarina
Battista hyper GT
vii
BEV
310 (WLTP)
Two Seaters
Bentley
Flying Spur
viii
PHEV
25
Compact
BMW
i4 (4 Series)
v
BEV
227-301
Large
BMW
iX xDrive50
v
BEV
305-324
Standard SUV
BMW
iX3
ix
BEV
286 (WLTP)
Standard SUV
BMW
X5 (Hydrogen NEXT)
x
FCEV
311
Small SUV
BMW
i5
xi
BEV
250
Midsize
BMW
i7
xii
BEV
380
Large
BMW
i8 M
xiii
PHEV
TBD
Two Seaters
Buick
Electra
xiv
BEV
300
Standard SUV
Cadillac
Lyriq SUV
xv
BEV
300
Standard SUV
Cadillac
Celestiq sedan
xvi
BEV
400+
Large
Cadillac
Escalade
xvii
BEV
400+
Standard SUV
Canoo
Lifestyle Vehicle
xviii
BEV
230
Large
Canoo
Electric AWD Pickup Truck
xix
BEV
200
Standard Pickup
Canoo
Electric Van
xix
BEV
250
Standard Pickup
Chevrolet
Blazer
xx
BEV
300
Standard SUV
Chevrolet
Equinox
xxi
BEV
200
Small SUV
Chevrolet
Silverado
xxii
BEV
400
Standard Pickup
Chrysler
Airflow Concept
xxiii
BEV
350+
Large
Dodge
eMuscle
xxiv
BEV
500
TBD
Faraday Future
FF 91
xxv
BEV
378
Large
Fisker
Ocean Crossover
xxvi
BEV
250, 340, 350+
Small SUV
Ford
E-Transit
xxvii
BEV
125
Cargo Van
Ford
F-150 Lightning
xxviii
BEV
230, 300
Standard Pickup
Ford
Explorer SUV
xxix
BEV
TBD
Standard SUV
Genesis
Electrified G80
xxx
BEV
265-310
Large
Genesis
Electrified GV70
xxxi
BEV
249 (Korean)
Small SUV
Genesis
GV60
xxxii
BEV
229, 249, 280
Small SUV
GMC
Hummer EV Edition 1
xxxiii
BEV
329
Standard Pickup
GMC
Sierra Denali
xxxiv
BEV
400
Standard Pickup
GMC
Sierra SUV
xxxv
BEV
400
Standard Pickup
GMC
Hummer EV SUV
xxxvi
BEV
300
Standard SUV
Honda
Acura ADX SUV
xxxvii
BEV
TBD
Small SUV
Honda
Prologue SUV
xxxviii
BEV
300
Small SUV
Hyundai
Ioniq 5 SUV
v
BEV
220, 256, 303
Small SUV
Hyundai
Ioniq 6 Sedan
xxxix
BEV
300
Midsize
Hyundai
Santa Fe Plug-in Hybrid
v
PHEV
31
Small SUV
Hyundai
Tucson Plug-in Hybrid
v
PHEV
33
Small SUV
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
Make
Model
Vehicle
Type
Electric Range
EPA Size Class
Hyundai
Ioniq 7 SUV
xl
BEV
300+
Standard SUV
Infiniti
QX Inspiration SUV Concept
xli
BEV
TBD
Small SUV
Jaguar Land
Rover
Range Rover P440e
xlii
PHEV
48
Standard SUV
Jeep
Compass 4xe PHEV
xliii
PHEV
29-30 (WLTP)
Small SUV
Jeep
Grand Cherokee PHEV
v
PHEV
26
Small SUV
Jeep
Renegade 4xe PHEV
xliv
PHEV
26 (WLTP)
Small SUV
Jeep
Wrangler Magneto
xlv
BEV
250
Small SUV
Kandi
K32
xlvi
BEV
60, 150
Standard Pickup
Karma
GSe-6
xlvii
BEV
230
Midsize
Kia
EV6
v
BEV
232, 274, 310
Midsize
Kia
Sorento Plug-in Hybrid
v
PHEV
32
Small SUV
KIA
EV9
xlviii
BEV
300
Standard SUV
Lamborghini
Urus PHEV
xlix
PHEV
TBD
Standard SUV
Lamborghini
Aventador
l
PHEV
TBD
Two Seaters
Lamborghini
Huracan
li
PHEV
TBD
Two Seaters
Land Rover
Range Rover
lii
BEV
300
Standard SUV
Lexus
NX 450h Plus AWD
v
PHEV
37
Small SUV
Lexus
RZ 450e
liii
BEV
250
Small SUV
Lincoln
Mark E
liv
BEV
300-350
Standard SUV
Lordstown
Motors
Endurance
lv
BEV
250
Standard Pickup
Lordstown
Motors
Van Concept
lvi
BEV
350
Minivan
Lotus
Evija Hypercar
lvii
BEV
250 (WLTP)
Two Seaters
Lotus
Type 132
lviii
BEV
TBD
Standard SUV
Lotus
Unnamed Coupe-Sedan
lix
BEV
TBD
Compact
Lotus
Unnamed Smaller SUV
lx
BEV
TBD
Small SUV
Lucid
Air Dream (all trims)
v
BEV
451-520
Large
Lucid
Air Grand Touring (all trims)
v
BEV
469, 516
Large
Lucid
Air Pure
lxi
BEV
406
Large
Maserati
Grecale PHEV SUV
lxii
PHEV
TBD
Small SUV
Maserati
Levante GT PHEV SUV
lxiii
PHEV
33
Small SUV
Maserati
GranCabriolet
lxiv
BEV
TBD
Compact
Maserati
GranTurismo
lxv
BEV
TBD
Compact
Maserati
Grecale EV
lxvi
BEV
TBD
Standard SUV
Maserati
Levante SUV
lxvii
BEV
TBD
Standard SUV
Maserati
MC20
lxviii
BEV
TBD
Two Seaters
Mazda
MX-30
v
BEV
100
Small SUV
Mazda
MX-30 PHEV
lxix
PHEV
TBD
Small SUV
Mercedes-Benz
EQA (GLA class)
lxx
BEV
200-250
Small SUV
Mercedes-Benz
EQB (GLB class)
lxxi
BEV
240
Small SUV
Mercedes-Benz
EQE (C class)
lxxii
BEV
370
Midsize
Mercedes-Benz
EQS 450 Plus
v
BEV
350
Large
Mercedes-Benz
EQS 580 4matic
v
BEV
340
Large
Mercedes-Benz
EQG
lxxiii
BEV
400
Small SUV
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
Make
Model
Vehicle
Type
Electric Range
EPA Size Class
Mercedes-Benz
Vision EQXX
lxxiv
BEV
620
Large
Mercedes-Benz
EQC (GLC class)
lxxv
BEV
272 (WLTP)
Small SUV
Nissan
Ariya crossover
lxxvi
BEV
210, 300
Small SUV
Polestar
3
lxxvii
BEV
310
Standard SUV
Polestar
4
lxxviii
BEV
300
Small SUV
Polestar
5
lxxix
BEV
TBD
Standard SUV
Porsche
Macan EV
lxxx
BEV
227
Small SUV
Ram
1500 Electric
lxxxi
BEV
500
Standard Pickup
Rivian
R1S
v
BEV
316
Standard SUV
Rivian
R1T
v
BEV
314
Standard Pickup
Rolls-Royce
Spectre
lxxxii
BEV
TBD
TBD
Subaru
Solterra CUV
lxxxiii
BEV
220
Small Station Wagon
Tesla
Cybertruck
lxxxiv
BEV
250, 300, 500
Standard Pickup
Tesla
Roadster
lxxxv
BEV
620
Midsize
Toyota
bZ4X
lxxxvi
BEV
250
Small SUV
VinFast
VF 8
lxxxvii
BEV
313 (WLTP)
Small SUV
VinFast
VF 9
lxxxvii
BEV
342 (WLTP)
Midsize
Volkswagen
ID. 5
lxxxviii
BEV
320
Small SUV
Volkswagen
I.D. Buzz
lxxxix
BEV
300+
Minivan
Volkswagen
ID. Space Vizzion
xc
BEV
300
Small Station Wagon
Volkswagen
ID. Vizzion
xci
BEV
413
Small Station Wagon
Volkswagen
ID.6 Crozz / ID.6 X
xcii
BEV
270, 365
(NEDC)
Standard SUV
Volkswagen
ID Life
xciii
BEV
200
Compact
Volvo
C40 Recharge twin
v
BEV
226
Small SUV
Volvo
Embla (XC90 Replacement)
xciv
BEV
TBD
Small SUV
Volvo
Polestar 2 Single, Dual
v
Motor
xcv
BEV
249, 270
Small SUV
Volvo
XC60
xcvi
BEV
TBD
Standard SUV
Additional expansion of vehicle model offerings is also expected after 2025 based on
manufacturers announced longer-term, broad reaching electrification plans that will affect
model years 2025 and beyond. Five years ago, manufactures made public announcements on
electrification plans that are now coming to light, such as Daimler’s announcement of the
creation of the Mercedes-Benz sub-brand “EQ”, which has since brought dedicated all-
electric vehicles to market.
29
Similarly, the proliferation of recent announcements from
manufacturers signals a rapid shift toward high levels of planned electrification for the light-
duty vehicle market and away from ICE technologies. Many manufacturers have announced
goals to produce only electric vehicles within the next ten to fifteen years: Volvo announced
29
Mercedes-Benz Group AG. 2016. “Next step in electric offensive: Mercedes-Benz to build first electric car of
the new EQ product brand in its Bremen plant.” Mercedes-Benz Group Media. October 27. Accessed March 4,
2022. http://media.daimler.com/marsMediaSite/ko/en/14353750.
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
plans to make only fully electric cars by 2030,
30
General Motors announced their goal to shift
its light-duty vehicles entirely to zero-emissions by 2035,
31
and Fiat announced a move to all
electric vehicles by 2030
32
(along with Fiat’s parent corporation Stellantis announcing an
intensified focus on electrification across all of its brands
33
). Similarly, Mercedes-Benz
announced that all their new architectures would be electric-only from 2025 onward.
34
Other manufacturers have announced sales goals for electric vehicles over the next decade
or two. Volkswagen announced that it expects half of its U.S. vehicle sales to be all-electric
by 2030.
35
Honda announced a full electrification plan to take effect by 2040, with 40 percent
of its North American vehicle sales expected to be zero-emission by 2030 and 100 percent
by 2040.
36
Ford announced they expect 40 percent of their global light-duty vehicle sales to
be all-electric by 2030.
37
These announcements continue a pattern from the past several years of many manufacturers
taking steps to introduce a wide range of zero-emission technologies while reducing their
reliance on the internal-combustion engine in various markets around the globe.
38
,
39
Table 4
provides a list of key manufacturer announcements related to ZEV goals and investments
30
Volvo Car USA. 2021. “Volvo Cars to be fully electric by 2030.” Volvo Newsroom. March 2. Accessed March 4,
2022. https://www.media.volvocars.com/us/en-us/media/pressreleases/277409/volvo-cars-to-be-fully-electric-
by-2030.
31
General Motors. 2021.General Motors, the Largest U.S. Automaker, Plans to be Carbon Neutral by 2040.”
GM Corporate Newsroom. January 28. Accessed March 4, 2022.
https://media.gm.com/media/us/en/gm/home.detail.html/content/Pages/news/us/en/2021/jan/0128-
carbon.html
32
Stellantis. 2021. “World Environment Day 2021Comparing Visions: Olivier Francois and Stefano Boeri, in
Conversation to Rewrite the Future of Cities.” June 4. Accessed March 4, 2022.
https://www.media.stellantis.com/em-en/fiat/press/world-environment-day-2021-comparing-visions-olivier-
franois-and-stefano-boeri-in-conversation-to-rewrite-the-future-of-cities.
33
Stellantis. 2021. “Stellantis Intensifies Electrification While Targeting Sustainable Double-Digit Adjusted
Operating Income Margins in the Mid-Term.” July 8. Accessed March 4, 2022.
https://www.stellantis.com/en/news/press-releases/2021/july/stellantis-intensifies-electrification-while-targeting-
sustainable-double-digit-adjusted-operating-income-margins-in-the-mid-
term#:~:text=Financial%20Performance&text=As%20a%20result%2C%20Stellantis%20is,customers%20on%20a
%20global%20basis.
34
Mercedes-Benz AG. 2021. “Mercedes-Benz prepares to go all-electric.” July 22. Accessed March 4, 2022.
https://mercedes-benz-media.co.uk/en-gb/releases/1431.
35
Volkswagen. 2021. “Strategy update at Volkswagen: The transformation to electromobility was only the
beginning.” Volkswagen Newsroom. March 5. Accessed March 4, 2022. https://www.volkswagen-
newsroom.com/en/stories/strategy-update-at-volkswagen-the-transformation-to-electromobility-was-only-the-
beginning-6875.
36
Honda. 2021. “Summary of Honda Global CEO Inaugural Press Conference,” April 23. Accessed March 4,
2022. https://global.honda/newsroom/news/2021/c210423eng.html.
37
Ford Motor Company. 2021. “Superior Value From EVs, Commercial Business, Connected Services is
Strategic Focus of Today’s ‘Delivering Ford+’ Capital Markets Day.” Ford Media Center. May 26. Accessed
March 4, 2022. https://media.ford.com/content/fordmedia/fna/us/en/news/2021/05/26/capital-markets-
day.html.
38
M.J. Bradley & Associates, Electric Vehicle Market Status
39
Wappelhorst, Sandra. 2020. “The end of the road? An overview of combustion-engine car phase-out
announcements across Europe,” Briefing, International Council on Clean Transportation. Accessed March 3,
2022. https://theicct.org/wp-content/uploads/2021/06/Combustion-engine-phase-out-briefing-may11.2020.pdf.
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
which are supported by increasing availability of electric vehicle models that offer improved
performance and handling.
40 41
Automakers representing one-third of California’s market have
already announced targets for greater than 50% ZEV sales by 2030, as well as significant
financial commitments to electrification and sustainability. This is being driven not only by
California’s push toward electrification, but jurisdictions around the world.
Table 4. Public Announcements of Manufacturer Long-Term ZEV and PHEV Targets and
Production Goals
Vehicle
Manufacturer
Public Announcements
BMW
10 million BEVs on the road within the next 10 years. 50% global sales to
be battery electric by 2030; 2 million BEVs delivered by the end of 2025.
BEVs available for 90% of market segments from compact class to ultra-
luxury segment (i.e., Rolls-Royce) in 2023, with BEVs available for 100% of
market segments by 2030. Mini to be all-electric in the early 2030s.
xcvii xcviii
Canoo
Plans to produce 14K to 17K BEVs a year by the end of 2023; production
targets of 70K to 80K units by 2025. Production of 3 pod like vehicles – a
pickup truck, delivery van, and minivan
xcix c
Fisker
4 new BEVs by 2025
ci
Ford
40% to 50% of global vehicle volume to be fully electric by 2030. 40 EV
models (26 BEVs); Increase production to 150,000 Lightning EVs by mid-
2023. Fully "electrified" Lincoln lineup by 2030, with half of the 4 Lincoln
models fully electric in 5 years
cii ciii civ cv cvi
General Motors
30 new global electric vehicle models by 2025. Offer only electric vehicles
by 2035, increase GM’s North American production capacity for building
electric vehicles to 1 million units by 2025. All Cadillac models to be
electric by 2030; no new models with gas engines now.
cvii cviiicix
Honda
40% of North American vehicle sales to be zero-emission by 2030 and
100% by 2040. Plans to introduce 2 large-sized EV models in 2024 model
yearone from Honda brand and the other from Acura.
cx
Hyundai
Hyundai to fully electrify its lineup in major global markets by 2040, 670K
annual EV sales by 2025. 23 types of EVs and hydrogen cars by 2025.
cxi cxii
Jaguar Land
Rover
All models fully electric by 2025, carbon neutral by 2039, 6 electric Land
Rovers over the next 5 years. By 2030, about 60% of Land Rover models
sold will be zero-emissions vehicles
cxiii cxiv
Kia
500,000 global sales of electric vehicles by 2026, 25% EV sales/7
dedicated BEVs by 2027, 11 fully electric cars
cxv
Lucid Motors
By 2023, the Phase II completion allows for their annual production to
increase from 34K to 90K BEVs. The Lucid Air will be released with 4
Different Variations (8 trims)
cxvi
40
Consumer Reports. 2020. “Electric Cars 101: The Answers to All Your EV Questions,” November 5. Accessed
March 4, 2022. https://www.consumerreports.org/hybrids-evs/electric-cars-101-the-answers-to-all-your-ev-
questions/.
41
Muratori et al. 2021. "The rise of electric vehicles2020 status and future expectations." Progress in Energy.
Accessed March 5, 2022. https://iopscience.iop.org/article/10.1088/2516-1083/abe0ad/pdf.
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
Vehicle
Manufacturer
Public Announcements
Mazda
By 2030, all models will be EV or hybrid. First battery EV is the MX-30, 13
electric car models available by around 2025
cxvii
Mercedes-Benz
By 2022, BEV in all segments the company serves. All newly launched
architectures will be electric-only from 2025 onwards. Investments into
combustion engines and plug-in hybrid technologies will drop by 80%
between 2019 and 2026. Joining forces with Factorial Energy to jointly
develop next-generation solid-state battery technology.
cxviii cxix cxx
Mitsubishi
25% carbon reduction by 2030, will focus on PHEVs
cxxi
Nissan
8 EVs on the road by the end of 2023. Nissan has promised 15 new all-
electric models and 8 more new “electrified” models by 2030. It also
wants to reach 40% “electrified” vehicles in the US by 2030, and a 50%
“electrified” mix globally by the same year.
cxxii cxxiii cxxiv
Rivian
Automotive
New factory in Georgia by 2024, capacity to produce 400K vehicles a
year; also expand Illinois factory. 6 New BEV models by 2025
cxxv
Stellantis
All models fully electric by 2028, BEVs and PHEVs will account for more
than 40 percent of sales in North America and 70 percent in Europe. 55
electrified cars and trucks for sale in the U.S. and Europe by 2025. $35.5
billion in EV spending through 2025
cxxvi cxxvii
Subaru
Electrify all models by 2030. Model year 2023 Solterra SUV is Subaru's first
EV
cxxviii cxxix
Tesla
Planning to sell 20 million vehicles a year by 2030
cxxx
Toyota
8 million electric vehicles by 2030, 40 percent electric by 2025 and 70
percent by 2030; plan to roll out 30 battery EV models by 2030, globally
offering a full lineup of battery EVs in the passenger and commercial
segments. 70 electrified models (BEVs/PHEVs) by 2025, 15 of them
battery EVs
cxxxi cxxxii
VinFast
All electric production by the end of 2022, targeting global electric
vehicle sales of 42,000 in 2022, new Gigafactory planned in the U.S. Two
SUV models in the U.S. are VF 8 and VF 9
cxxxiii cxxxiv
Volkswagen
Group
50% fully electric sales in the U.S. by 2030. By 2030, Volkswagen will have
launched about 70 all-electric models across the Group. Audi aims to have
30 electric models (BEVs and PHEVs) on sale by 2025; 20 of those being
pure BEVs. First Bentley BEV by 2025, and a total of five new electric
models between 2025 and 2030. Porsche to be carbon neutral by 2030,
with 80% of the cars and SUVs it makes either electric or plug-in hybrids.
cxxxv cxxxvi cxxxvii
Volvo
1 million total EV sales, by 2025, half of global sales are fully electric,
carbon neutral by 2040. All fully electric models will be available online
only
cxxxviii
Momentum has been building around electrification worldwide. Countries around the world
have already been taking action on 100% vehicle electrification commitments (or an outright
ban of gasoline sales) as early as 2025. In addition to these commitments, several large
markets where passenger vehicles are sold have adopted policies and regulations that will
additionally call for higher and higher volumes of electrified vehicles. On September 23,
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
2020, Governor Newsom signed Executive Order N-79-20 establishing a goal for 100 percent
of in-state sales of new passenger cars and trucks to be zero-emission by 2035.
42
Such an
ambitious goal is the first in the United States and complements what others are doing
around the world. The specifics of each national target vary slightly in that some explicitly
require 100 percent sales of electric vehicles while others require the opposite of no new
gasoline, diesel, or fossil fuel vehicles. Timelines for these targets also vary widely. Norway
has the most aggressive target of 100 percent electric vehicle sales by 2025, while other
countries such as Costa Rica and Germany are aiming for these levels by 2050 (see Table 5
for full listing of countries and target dates). These are a combination of announcements,
alongside policy documents and binding agreements/laws. Such targets send strong policy
signals to the market. France and Spain have codified these targets as formal laws that would
make these targets legally binding and enforceable requirements.
Table 5. Jurisdictions with 100% ZEV Sales or Phase-Outs of Gasoline, Diesel, or Fossil
Fuels
43 44
Target Year
Country/Jurisdiction (target type)
2025
· Norway (EV only)
2030
· Austria (no gasoline/diesel vehicles)
· Denmark (no gasoline/diesel vehicles; PHEVs until
2035)
· Iceland (no gasoline/diesel vehicles)
· Ireland (no fossil fuel vehicles)
· Israel (no gasoline/diesel vehicles)
· Netherlands (EV only)
· Slovenia (no gasoline/diesel vehicles; includes
PHEVs)
· Sweden (no gasoline/diesel vehicles)
· United Kingdom (no gasoline/diesel vehicles)
2035
· California (no ICE vehicles)
· Canada (no ICE vehicles)
· Cape Verde (no ICE vehicles)
· New York (no ICE vehicles)
· Japan (no ICE vehicles, mid-2030s; includes HEVs)
· Thailand (ZEV only)
42
Governor Gavin Newsom, Executive Order N-79-20
43
International Council for Clean Transportation. 2021. Global passenger car market share of countries planning
to phase out new sales of internal combustion engine vehicles. October. Accessed March 1, 2022.
https://theicct.org/sites/default/files/publications/pvs-global-phase-out-FS-oct21.pdf.
44
IEA. 2021. Global EV Policy Explorer: Electric vehicle deployment policies and measures. International Energy
Agency, Paris. Accessed March 1, 2022. https://www.iea.org/articles/global-ev-policy-explorer.
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
Target Year
Country/Jurisdiction (target type)
2040
· Egypt (no ICE vehicles)
· France (no fossil fuel vehicles)
· Singapore (no ICE vehicles; includes PHEVs)
· Sri Lanka (EV/HEV only)
· Spain (EV only)
· Taiwan (no gasoline/diesel vehicles)
2050
· Costa Rica (EV only)
· Germany (EV only)
· Portugal (no ICE vehicles)
B. Increase in All Electric Range
Industry is expanding its BEV and PHEV product offerings with more range than previously
anticipated. In the 2012 ACC rulemaking, CARB staff assumed that all BEVs produced in
compliance (from 2018 through 2025 model year) would have a 100-mile test cycle range
45
(approximately 70 mile ‘label range’), all PHEVs would have 22-40 miles of test cycle range
(~14-30 mile label range), and all FCEVs would have at least 350 miles of test cycle range
(maxing out the number of credits that could be earned within the program).
46
Since then,
manufacturers have announced 300-mile (or more) label range BEVs and multiple PHEVs at
various ranges. Vehicle all-electric range has been steadily increasing since 2012 due to
decreased batteries costs, battery pack capacity increases, and efficiency improvements
made to drivetrains and associated components.
The jump in BEV range since the 2012 rulemaking is large. The median driving range of 2021
model year BEVs was 239 miles compared to a median range of 68 miles in 2011.
Additionally, the maximum range for any BEV offered in the 2021 model year was 405 miles,
and there are already BEV models offered for the 2022 model year achieving a maximum
range of 520 miles. While the median range for gasoline vehicles was 403 miles, as more long
range BEVs become available the discrepancy in range between gasoline powered vehicles
and BEVs is likely to continue to narrow.
47
Figure 5 below shows the trend in median and
maximum BEV EPA label ranges from model year 2011 to 2022. The maximum BEV range in
model year 2021 is attributed to the Tesla Model S Long Range (405 miles) while the max
BEV range in model year 2022 is attributed to the Lucid Air Dream (520 miles).
45
Test cycle range means all electric range on the urban dynamometer drive schedule (UDDS).
46
California Air Resources Board. 2011. Initial Statement of Reasons: 2012 Proposed Amendments to The
California Zero-Emission Vehicle Program Regulations. December 7. Accessed February 11, 2021.
http://www.arb.ca.gov/regact/2012/zev2012/zevisor.pdf
47
U.S. DOE. U.S Department of Energy Vehicle Technologies Office. 2022. “FOTW #1221, Model Year 2021 All-
Electric Vehicles Had a Median Driving Range about 60% That of Gasoline Powered Vehicles” January 17.
Accessed February 24, 2022. https://www.energy.gov/eere/vehicles/articles/fotw-1221-january-17-2022-model-
year-2021-all-electric-vehicles-had-median.
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
PHEVs with increased ranges are also anticipated due in part to consumer demand for a
more all-electric driving experience. Second generation PHEVs that are now in the market
offer more range than earlier generation vehicles. The maximum PHEV all-electric range in
model year 2021 and 2022 is attributed to the Karma GS-6 (61 all-electric miles). While the
maximum PHEV all-electric range increased in a stepwise pattern from 35 miles in 2011 to 61
miles in 2022, the median range for PHEVs has decreased from 35 miles to 23 miles in the
last 11 years due to an increase in PHEV model availability. Figure 6 below shows the trend in
median and maximum PHEV EPA label ranges from model year 2011 to 2022.
Figure 5. Battery Electric Vehicle Maximum and Median Ranges from Model Year
2011 to 2021
68
76
85
84
90
218
205
213
239
259
239
256
94
265 265 265
270
315
335 335
370
402
405
520
0
50
100
150
200
250
300
350
400
450
500
550
2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022
EPA Label Range
Model Year
Range of BEVs Offered for Sale in the United States,
Model Years 2011-2022
Median Range Maximum Range
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
Figure 6. Plug-in Hybrid Electric Vehicle Maximum and Median Ranges from Model Year
2011 to 2022
48
C. Battery Electric Vehicle Improvements
BEV technology has progressed quickly since the market introduction of the Nissan Leaf in
2010. The Leaf itself has increased in range by 310 percent since its first model year.
49
Range
increases have come from several technology advancements, including manufacturers
moving to dedicated BEV platforms that have further improved total vehicle efficiency, mass,
and available space for larger battery packs. Details of these trends are described below.
1. Increase in Battery Pack Energy Capacity
Battery pack capacities continue to increase in BEVs, supporting longer range and faster
recharge times, replacing more miles of range per hour. Battery packs as large is 200 kWh
have now entered in the market in larger vehicles like the GMC Hummer EV truck with a 329-
mile range.
50
Other models like the Tesla Model 3 Long Range have increased battery
capacity on an existing product in the market as battery energy density (Wh/liter) improved,
48
The BMW i3 Range Extender and BMW i3S Range Extender models were excluded in this analysis since they
are not true PHEVs.
49
U.S. Department of Energy and the U.S. Environmental Protection Agency. n.d. Fueleconomy.gov - 2011 and
2022 Nissan Leaf. Accessed February 25, 2022.
https://www.fueleconomy.gov/feg/Find.do?action=sbs&id=30979&id=44447.
50
Edelstein, Stephen. 2021. Motor Authority - 2022 GMC Hummer EV Edition 1 to have 329 miles of range, too
heavy for official EPA rating. November 24. Accessed February 25, 2022.
https://www.motorauthority.com/news/1134272_2022-gmc-hummer-ev-edition-1-to-have-329-miles-of-range-
too-heavy-for-official-epa-rating.
35
33
20
19
16 16
16
16
19
19 19
23
35 35
38 38 38
53 53 53 53
61 61 61
0
10
20
30
40
50
60
70
2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022
EPA Label Range
Model Year
Range of PHEVs Offered for Sale in the United States, Model Years
2011-2022
Median Range
Maximum Range
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
enabling the battery pack to expand from 75kWh to 82kWh partway through the 2021 model
year. Nissan has introduced a 62kWh battery option for the 2021 model year Leaf and
Chevrolet has increased its Bolt battery packs from 60kWh to 64kWh even though the vehicle
platform did not change.
51
2. Dedicated BEV platforms
Earlier in the development of plug-in electric vehicles (PEVs, representing both BEVs and
PHEVs), manufacturers used both shared and dedicated platforms for their PEV offerings;
however, most manufacturers have shifted to dedicated platforms as they electrify their
fleets. Use of a global shared platform allows commonality across models and international
markets for increased volumes and reduced costs, while a dedicated platform allows for a
higher level of optimization specifically for the PEV technology.
Dedicated BEV platforms eliminate provisions for ICE powertrain, exhaust emissions,
evaporative emissions, and fuel systems that would otherwise need to be accommodated on
platforms that are shared between BEV, PHEV, hybrid electric vehicle (HEV), and
conventional ICEV models. This dedicated BEV platform approach typically allows integration
of the battery pack entirely within the vehicle floor structure, reduces vehicle weight, reduces
manufacturing costs, increases available passenger and cargo volume, and in some cases, has
the battery pack integrated as part of the vehicle's crash mitigation structure.
Manufacturers have recently introduced a growing number of dedicated battery electric
vehicle platforms, such as the GM Ultium platform, the VW MEB platform, and the Hyundai
E-GMP platform which underpin products like the GMC Hummer EV, VW iD.4, and Hyundai
Ioniq 5, respectively.
52
The VW Group is continuing to expand its BEV specific platforms
under the name Project Artemis for Audi, Project Trinity for VW, and the jointly developed
Premium Platform Electric (PPE) platform between Audi and Porsche.
53 54 55
Nissan has also
51
Nissan USA. n.d. 2022 Nissan LEAF Range, Charging & Battery. Accessed January 25, 2022.
https://www.nissanusa.com/vehicles/electric-cars/leaf/features/range-charging-battery.html.
52
Oreizi, Darya. 2021. Charged Future - Overview of Electric Vehicle Platforms in 2021. February 9. Accessed
February 25, 2022. https://www.chargedfuture.com/electric-vehicle-platforms-in-2021/.
53
Volkswagen AG. 2020. Markus Duesmann launches “Artemis” project. May 29. Accessed February 25, 2022.
https://www.volkswagenag.com/en/news/2020/05/Artemis.html#.
54
Audi AG. 2021. "UBS Investor Meeting." Audi.com. January 7. Accessed February 25, 2022.
https://www.audi.com/content/dam/gbp2/company/investor-relations/events-and-presentations/investor-
presentations/2021/2021-07-07-UBS-PPE-deep-dive.pdf.
55
Volkswagen AG. 2021. “Project Trinity: With high range, extremely short charging times and revolutionary
production, the sedan will launch in 2026.March 5. Accessed March 4, 2022. https://www.volkswagen-
newsroom.com/en/press-releases/project-trinity-with-high-range-extremely-short-charging-times-and-
revolutionary-production-the-sedan-will-launch-in-2026-6879.
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
debuted a new all-electric platform that will be introduced with its Ariya.
56
Daimler has
introduced its new Electric Vehicle Architecture (EVA) that underpins the new EQS sedan.
57
BEV specific platforms allow for further integration of battery packs into dedicated platforms
such that battery modules can be eliminated and battery cells themselves can become an
integrated structural member of the vehicle chassis. Those developments enable even
greater vehicle efficiencies by reducing structural material in the chassis and battery pack and
by increasing battery cell packing efficiency without the need for battery module-specific
materials. Tesla, during their 2020 Annual Shareholder Meeting and Battery Day, presented a
breakdown of what they think their advanced batteries can contribute to vehicle efficiency,
battery cost on a dollar per kilowatt-hour (kWh) basis, and the investment required on a
$/GWh basis to produce those new batteries.
58
The structural battery shown was projected
by Tesla to increase vehicle range by 14 percent which would equate to an additional 46
miles on a 2022 Tesla Model Y Long Range on 19” wheels.
59
Efficiency increases from a
structural battery pack are only fully realized on a BEV-specific platform and demonstrates
that there are further efficiency improvements to be had over existing vehicles.
D. Plug-in Hybrid Electric Vehicle Improvements
PHEV technology continues to evolve as manufacturers introduce different architectures
and all electric capabilities. Toyota increased the equivalent all-electric range of the Prius
plug-in hybrid that was introduced for the 2012 model year (MY) by 127 percent in five
years with the introduction of the 2017 MY Prius Prime that is also capable of completing
the US06 drive cycle under electric power alone. Four model years later, Toyota
introduced the larger 2020 MY RAV4 Prime with a 68 percent equivalent all-electric range
(EAER) improvement over the Prius Prime and 281 percent improvement over the original
Prius Plug-in Hybrid.
60
The RAV4 Prime also includes all-wheel drive (AWD) and even more
all-electric power than the Prius Prime.
Ford has also improved their PHEVs with their second-generation products. The C-MAX
and Fusion Energi plug-in hybrids both debuted for the 2013 MY with 20 miles of EAER.
The larger Ford Escape PHEV debuted for the 2020 MY with 37 of EAER, an increase of 85
56
Nissan Motor Corporation. 2021. Nissan Ariya world debut: an all-electric crossover for a new era. Accessed
February 25, 2022. https://usa.nissannews.com/en-US/releases/2021-nissan-ariya-press-kit#.
57
Randall, Chris. 2021. Daimler to exclusively introduce EV platforms from 2025. electrive.com. July 22.
Accessed February 25, 2022. https://www.electrive.com/2021/07/22/daimler-to-exclusively-introduce-ev-
platforms-from-2025/.
58
Tesla. 2020. Tesla Battery Day. Fremont, CA, September 22. Accessed March 3, 2022. https://tesla-
share.thron.com/content/?id=96ea71cf-8fda-4648-a62c-753af436c3b6&pkey=S1dbei4
59
Motley Fool Transcribing. 2022. Tesla (TSLA) Q4 2021 Earnings Call Transcript. January 27. Accessed March 3,
2022. https://www.fool.com/earnings/call-transcripts/2022/01/27/tesla-tsla-q4-2021-earnings-call-transcript/.
60
U.S. Department of Energy and the U.S. Environmental Protection Agency. n.d. Fueleconomy.gov - 2012
Toyota Prius Plug-in Hybrid, 2017 Toyota Prius Prime, 2021 Toyota RAV4 Prime 4WD. Accessed February 25,
2022. https://www.fueleconomy.gov/feg/Find.do?action=sbs&id=32484&id=38531&id=42793.
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
percent.
61
The much larger Lincoln Aviator PHEV also debuted for the 2020 MY with three
rows of seating and 21 miles of EAER. Other manufacturers have also increased range in
their PHEV offerings, like Volvo with their T8 variants (XC60, XC90, V60, S60, and S90
vehicles), Karma with its Revero GT, BMW with its ‘e’ variants of the X5, 3 series, and 7
series, Hyundai with its Ioniq, Santa Fe, and Tucson, and Kia with their Sorento and Niro.
Jaguar Land Rover also recently announced the Range Rover P440e with 48 miles of EAER
for the 2023 MY.
62
Those improvements stem from some of the same areas that BEVs have benefited from.
Improved electric motors and power electronics are being utilized to further enhance all-
electric operation efficiency to extend range. Heat pumps have also been integrated into
PHEV designs like with the Toyota Prius Prime and RAV4 Prime to increase all-electric
efficiency in inclement weather.
63 64
PHEVs have also gained from many of the same
battery improvements that BEVs have. As PHEV batteries increase in energy capacity,
power to energy ratio becomes less of a factor, and PHEVs can use more energy dense
cells which further increase capacity for a given volume which will assist in packaging those
packs onto future vehicle designs.
E. Fuel Cell Electric Vehicle Improvements
FCEVs are full electric drive vehicles where the propulsion energy is supplied by hydrogen
and a fuel cell stack that transforms the chemical energy stored in hydrogen into electricity as
needed for motive power. The inputs of the electrochemical process for the fuel cell stack
are oxygen and hydrogen, with the byproducts being electricity, water, and heat. The major
components of the fuel cell system include the fuel cell stack, the hydrogen storage tank,
balance of plant (valves, safety release, vent, fill tubes, etc.), and a battery pack for dynamic
load balancing/response, moving the motor directly, capturing braking regeneration, and
energy storage. Additionally, the system includes coolant subsystems, an air handling
subsystem with compressor-expander module (CEM) precooling, and humidification.
The fuel cell stack is much like a battery in that it consists of an anode, a cathode, and
dividing electrolyte membrane (thus the name of the type used for light-duty applications:
proton exchange membrane fuel cell).
65
Additional stack components include the gas
61
U.S. Department of Energy and the U.S. Environmental Protection Agency. n.d. FuelEconomy.gov - 2013 Ford
C-MAX Energi Plug-in Hybrid, 2013 Ford Fusion Energi Plug-in Hybrid, 2020 Ford Escape FWD PHEV. Accessed
February 25, 2022. https://www.fueleconomy.gov/feg/Find.do?action=sbs&id=33336&id=33398&id=42743.
62
Land Rover. 2022. New Range Rover: Orders Open for Flagship SV Model and Extended Range Plug-In
Hybrid With 48 Miles of EV Range. January 27. Accessed February 25, 2022. https://media.landrover.com/en-
us/news/2022/01/new-range-rover-orders-open-flagship-sv-model-and-extended-range-plug-hybrid-48-miles.
63
Szymkowski, Sean. 2017. How does the heat pump work in a Toyota Prius Prime plug-in hybrid? Green Car
Reports. May 24. Accessed February 25, 2022. https://www.greencarreports.com/news/1110627_how-does-the-
heat-pump-work-in-a-toyota-prius-prime-plug-in-hybrid.
64
Halvorson, Bengt. 2020. 2021 Toyota RAV4 Prime first drive review: The way a plug-in hybrid should be.
Green Car Reports. July 1. Accessed February 25, 2022.
https://www.greencarreports.com/news/1128706_2021-toyota-rav4-prime-first-drive-review-the-way-a-plug-in-
hybrid-should-be.
65
EPA, NHTSA, and CARB, Draft Technical Assessment Report.
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
diffusion layer (GDL) that helps transport hydrogen and oxygen from flow channels to the
anode and cathode surfaces, as well as bipolar plates that divide each individual cell,
integrate the channels through reactant and product gases flow, and conduct the electricity
generated by the fuel cell stack to the vehicle’s battery and motor.
An on-board hydrogen storage system for LDVs consists of a 700 bar (70MPa or 10,000psi)
hydrogen pressure vessel and the balance of plant (BOP). The tank is typically wound carbon
fiber construction with a polymer liner. The BOP consists of devices such as the fill tube and
port, temperature sensor, pressure gauge, pressure relief device, rupture disc, solenoid
control valve, primary pressure regulator, manual ball valve, a check valve, and related data
communications hardware.
At the time of the ACC rulemaking in 2012, there were no light-duty mass-produced fuel cell
vehicles available on the market, but that quickly changed with introduction of the Hyundai
Tucson Fuel Cell in the 2015 model year. It was subsequently followed by the releases of the
Toyota Mirai and Honda Clarity Fuel Cell.
Fuel cell systems utilized in FCEVs have significantly improved in recent years. The DOE
reports that fuel cell stack costs have fallen 70 percent since 2008 (at high production
volumes).
66
Hyundai Motor Group reports a similar cost reduction of 98 percent between
prototype systems developed in 2003 and their next-generation fuel cell systems set for
commercial introduction in the near future.
67
Durability of Hyundai fuel cells are also reported to have increased from 3,000 hours/100,000
km (62,000 miles) in their first-generation system to a target 500,000 km (310,000 miles) in
their next-generation fuel cell system for commercial applications. Durability across the FCEV
fleet has also improved over the past 15 years. The National Renewable Energy Lab (NREL)
assessed data from FCEVs to measure progress and compared it to the durability targets set
by the DOE.
68
NREL revealed that 22 percent of the vehicles had over 2,000 operation hours
and a maximum operation time of 5,648 hours. It was also shown that from 2006 through
2016 the average fleet durability went from 1,000 hours to 2,000 hours and the maximum
fleet average durability saw an increase from 2,000 hours to 4,000 hours. Using this data,
NREL projected 4,130 hours as a maximum fleet average durability with a 10 percent voltage
degradation. The increase in durability hours is an indicator that technology advancements
are enabling higher durability times in FCEVs; however, as indicated by NREL, meeting the
targets set by DOE may take a few years. For fuel cell power systems, the DOE targeted
durability for 5,000 hours, which is approximately 150,000 driving miles, with 10 percent
66
Satyapal, Sunita. 2021. “2021 AMR Plenary Session” presentation, 2021 US Department of Energy Hydrogen
Technology Office Annual Merit Review, Online, June 7.
67
Hyundai Motor Group. 2021.Hyundai Motor Group’s next-generation fuel cell system, a key technology for
popularizing hydrogen energy.” September 7. Accessed February 17, 2022.
https://tech.hyundaimotorgroup.com/article/hyundai-motor-groups-next-generation-fuel-cell-system-a-
keytechnology-for-popularizing-hydrogen-energy/.
68
Kurtz, Jennifer, Sam Sprik, Genevieve Saur, and Shaun Onorato. 2019. “Fuel Cell Electric Vehicle Durability
and Fuel Cell Performance”. Golden, CO: National Renewable Energy Laboratory. NREL/TP-5400-73011.
https://www.nrel.gov/docs/fy19osti/73011.pdf.
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
degradation by 2020.
69
Ultimately, the DOE aims for 8,000 hours with 150,000 driving miles
and 10 percent degradation.
70
The fuel cell systems have also increased total power over time while becoming more
compact due to increasing system power density. Toyota has reported similar gains between
its first and second generation Mirai. The second-generation model, released in model year
2021, is 20 percent smaller, 50 percent lighter, and 12 percent more powerful than the fuel
cell in the first generation Mirai
71
. The second-generation Mirai list price was also
approximately $9,000 less than its predecessor.
III. Battery Technology for ZEVs and PHEVs: Status and Trends
Lithium-ion batteries are used in virtually every ZEV and PHEV application. Lithium-ion
technology provides the best balance of energy density and cost of any rechargeable battery
technology available today, allowing manufacturers to pack more energy into a battery pack
at a lower cost.
A. Lithium-ion Battery Overview
Lithium-ion batteries consist of the following main components: a cathode, an anode, current
collectors, a separator, electrolyte, and a case of some kind to contain those components.
Lithium-ion encompasses several different technologies and variations that use lithium ions as
the transport mechanism for electrons. Ions shuttle between the cathode and anode during
charging and discharging. Upon discharge, the oxidation of the anode occurs (loss of
electrons), and the cathode is reduced (gains electrons). The reverse of those phenomena
takes place during charging.
72
Battery cells typically account for most of the total battery
weight and contain a number of minerals in the active cathode material (e.g., lithium, nickel,
cobalt, and manganese), anode (e.g., graphite), and current collector (e.g., copper).
73
The
remaining modules and pack components consist mostly of aluminum, steel, coolants, and
electronic parts.
It is important to highlight the individual components of lithium-ion batteries because
increases in energy or power density often are not from equal improvements in each
69
Kurtz, Jennifer, Sam Sprik, Genevieve Saur, and Shaun Onorato. 2019. “On-Road Fuel Cell Electric Vehicles
Evaluation: Overview”. Golden, CO: National Renewable Energy Laboratory. NREL/TP-5400-73009.
https://www.nrel.gov/docs/fy19osti/73009.pdf.
70
U.S. Department of Energy. 2017.Hydrogen and Fuel Cell Technologies Office Multi-Year Research,
Development, and Demonstration Plan.” Section 3.4: Fuel Cells. May. Accessed March 4, 2022.
https://www.energy.gov/sites/prod/files/2016/06/f32/fcto_myrdd_fuel_cells_0.pdf.
71
Toyota. 2020.Toyota Introduces Second-Generation Mirai Fuel Cell Electric Vehicle as Design and
Technology Flagship Sedan.” Toyota Pressroom. December 16. Accessed February 17, 2022.
https://pressroom.toyota.com/toyota-introduces-second-generation-mirai-fuel-cell-electric-vehicle-as-design-
and-technology-flagship-sedan/.
72
Battery University. 2022. "BU-204: How do Lithium Batteries Work?" February 22. Accessed March 4, 2022.
http://batteryuniversity.com/learn/article/lithium_based_batteries.
73
IEA. 2021. The Role of Critical Minerals in Clean Energy Transitions, International Energy Agency, Paris.
https://www.iea.org/reports/the-role-of-critical-minerals-in-clean-energy-transitions.
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
component. Improvements from technology advancements most often occur within an
individual component and result in corresponding changes made to the other components to
appropriately handle that change. Batteries need advancements in the capacity of the
cathode, capacity of the anode, and specific mass of all the other components for energy
density and specific energy to increase at a rate similar to increases in energy capacity of the
individual components. If one component sees several large increases and the other two
portions do not, those large increases become less and less effective at increasing the total
cell energy density or the specific energy of the battery cell. Increases in cell energy density
and specific energy result in reductions to the mass and volume of a battery pack for a given
range which would improve vehicle efficiency. Or, those density or specific energy
improvements could be used to increase battery energy capacity of a battery pack relative to
one with older cells without growth in volume or mass.
Lithium-ion batteries used in electric vehicles are composed of battery cells manufactured in
various formats and contained in battery modules within a battery pack. Lithium-ion batteries
for electric vehicles are packaged in cylindrical, prismatic, and pouch formats. Typically,
cylindrical cells come in the ‘18650’ format, which is an industry adopted cell standard that
has the nominal dimensions of 18 millimeters (mm) in diameter and 65.0mm in length (for
reference, a conventional AA size alkaline battery is typically 14mm in diameter by 50mm in
length). Consumer electronics, particularly laptops and battery-operated power tools, have
made the ‘18650’ battery cell the most widely produced lithium-ion battery format. The
demand has driven development, optimization, and volume cost reductions for those cells,
which helped the ‘18650’ cells in Tesla’s Model S and Model X vehicles achieve some of the
highest energy density and specific energy measurements on the market at the time of their
introduction.
Tesla has iterated on the cylindrical format starting with the Tesla Model 3 by codeveloping a
larger ‘2170’ cell that is 21mm in diameter and 70mm long with Panasonic. That cell is also
used in the more recently introduced in the Model Y. Rivian announced that their R1T and
R1S truck and SUV products also utilize the 2170 cell format and Lucid Motors is another
manufacturer that is using 2170 cylindrical cells in its new Air large sedan.
74
Other battery
manufacturers like Samsung and LG Chem Power have also announced 2170 cells.
75 76
During its Battery Day in 2020, Tesla announced that it was working on an even bigger cell,
the ‘4680’, which is 46mm in diameter and 80mm long.
77
Tesla claims that the format has the
best blend of energy density and cost. Tesla is also working on several other enabling
74
Halvorson, Bengt. 2021. Are cylindrical cells the reason Lucid, Tesla, and Rivian lead in range? October 15.
Accessed February 28, 2022. https://www.greencarreports.com/news/1133877_cylindrical-cells-advantages-
tesla-lucid-rivian-range.
75
Abuelsamid, Sam. 2021. LG Chem Commits $4.5 Billion to Expand EV Battery Production In U.S. Forbes.
March 11. Accessed February 28, 2022. https://www.forbes.com/sites/samabuelsamid/2021/03/11/lg-chem-
commits-45b-to-expand-ev-battery-production-capacity-in-us-by-70-gwh/?sh=7974735ca026.
76
Samsung SDI. 2017. Samsung SDI Presents an Innovative Next Generation Battery with Fast Charging
Capability and High Energy Density that enables Electric Vehicles (EV) to Drive 600km. SDI News. January 9.
Accessed February 28, 2022. https://www.samsungsdi.com/sdi-
news/1502.html?pageIndex=3&idx=1502&searchCondition=0&searchKeyword=.
77
Tesla, Tesla Battery Day.
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
technologies for the larger cells like tab-less electrodes for lower resistance, so the cell
generates less internal heat, which is important on a larger diameter cylindrical cell because
the larger size makes the removal of internal heat more difficult.
Figure 7. Cylindrical and Prismatic lithium-ion battery
78 79
Prismatic battery cells have been designated as such due to their rectangular prismatic
shape, as seen in Figure 7. Prismatic cells have been used in cell phones and some low-
profile laptops, but also have seen implementations in HEVs, PHEVs, and BEVs. The prismatic
container is designed in such a way that it manages the natural swelling of the components
of the cell during charging and discharging.
80
Pressure build-up due to gassing of the
components that may occur during cycling of the cell is usually managed through a vent of
some kind. While prismatic cells are generally considered to be the safest cell containment
design, they give up both specific energy capacity and energy density to cylindrical and
pouch cells.
Pouch cells can be described just like their name indicates. The contents of the cell are
sealed within a foil pouch. The pouch is designed to handle the swelling of the components
and outgassing, but its external dimensions will change in doing so. This creates additional
challenges for packaging considerations when designing battery modules and packs. LG
Chem designed and manufactured pouch cells that are more exposed within the pack to
allow for higher packing density and to better accommodate the liquid cooling design
General Motors implemented in the Volt's battery pack. Since then, General Motors has
continued to codevelop cells with LG Chem and announced a more holistic approach to
78
Marshall, Brain. 2021. "How Lithium-ion Batteries Work" HowStuffWorks.com. February 11. Accessed March
4, 2022. http://electronics.howstuffworks.com/everyday-tech/lithium-ion-battery.htm.
79
Battery University. 2019. BU-301a: Types of Battery Cells. Compare the pros and cons of the cylindrical cell,
button cell, prismatic cell and pouch. April 24. Accessed March 3, 2022.
https://batteryuniversity.com/article/bu-301a-types-of-battery-cells
80
Landini, Stefano. 2019. A Review of Phase Change Materials for the Thermal Management and
Isothermalisation of Lithium-Ion Cells. The Journal of Energy Storage. 25. 1000887. 10.1016/j.est.2019.100887.
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
platform and battery cell design with its Ultium platform.
81
A common cell format of 23
inches long by 4 inches tall by 0.4 inches thick will be used in all of GM’s Ultium-based EV
products. The packs can range from 50kWh to 200kWh and the common cell will allow for
higher cell volume throughput at manufacturing centers. Many vehicle manufacturers and
battery manufacturers are continuing to develop the pouch style cell.
Current lithium-ion technologies are mostly agnostic to physical cell design. However, it is yet
to be seen if advanced lithium-ion batteries like those with lithium or silicon-based anodes,
solid state-based systems, lithium-sulfur, or even sodium-ion will remain agnostic to physical
cell design. For example, possible issues could arise with solid-state separators conforming to
the tight bend radii required of separators within a cell or dimensional constraints that arise
from battery cell’s tendency to swell during charging. For instance, Tesla noted that lithium
iron phosphate is better suited to formats other than 4680 due to edge case physics-based
differences to other chemistries.
82
These considerations could dictate the physical formats of
batteries that incorporate advanced battery technologies.
Manufacturers must decide on battery pack topologies, specifically in terms of the number of
cells connected in parallel and series. This can be dependent upon several factors.
Understanding what manufacturers chose to do is critical to knowing what power demands
the drivetrain will place on individual battery cells, and the voltage range that the battery
pack will operate within. Equipment that will operate on the high voltage bus must interface
with that voltage, which will affect the cost of that equipment. Increasing the voltage on
packs could require voltage isolation specifications of existing equipment to be upgraded to
handle the higher voltage.
B. Battery Durability
BEVs rely on lithium-ion batteries to operate; however, these batteries do not have an
unlimited lifespan. To measure the lifespan of these batteries, battery durability is considered
for assessing the useful life of a battery and how different elements impact the battery
degradation process. The DOE Vehicle Technologies Office (VTO) has put forth electric
vehicle targets and goals for batteries at the pack and cell level including: 15 years of
calendar life, 1,000 cycles of deep discharge cycle life, and greater than 70 percent of
useable energy for nominal capacity discharged over three hours at20 degrees Celsius (C)
for low temperature performance.
83
The United States Advanced Battery Consortium
subsequentially put forth a battery test procedure to verify battery performance in
comparison to the DOE VTO targets for electric vehicles for an equivalent electric range of
81
Morris, Charles. 2021. Charged Electric Vehicles Magazine - GM reveals more technical details of its Ultium
battery packs. July 12. Accessed February 28, 2022. https://chargedevs.com/newswire/gm-reveals-more-
technical-details-of-its-ultium-battery-packs/.
82
Motley Fool Transcribing, Tesla (TSLA) Q4 2021 Earnings Call Transcript
83
U.S. Department of Energy. 2020. “Batteries: 2020 Annual Progress Report.” Office of Energy Efficiency &
Renewable Energy Vehicle Technologies Office.
https://www1.eere.energy.gov/vehiclesandfuels/downloads/VTO_2020_APR_Batteries_compliant_.pdf
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
200 miles based on an Urban Dynamometer Driving Schedule (UDDS) cycle operating at 30
degrees Celsius.
84
To define battery durability and degradation, metrics such as cycle life, range, usable energy,
and capacity provide explanations as to how these factors impact battery life. Cycle life is the
number of charge and discharge cycles that can occur before a battery begins to fail meeting
performance needs. Cycle life is dependent on the depth of discharge, which is the
percentage of the battery that has been discharged, with higher depth of discharges
resulting in a lower cycle life.
85
Battery capacity of a vehicle is the accumulated electric
charge a battery has and is measured in ampere-hours whereas usable energy is the energy a
battery has available to use for vehicle operations and is measured in kilowatt-hours.
Capacity is the measure of charge independent of voltage, while usable energy depends on
the voltage the battery operates at. Usable energy and capacity impact vehicle rangeas
these factors decrease, the available range of a vehicle decreases as well. When a battery has
80 percent usable energy, it is considered to have reached its end-of-life. Capacity fade can
be further categorized into calendar and cycle capacity loss.
Battery degradation can be separated into two categories which both can be affected by
several factors. The first is cycle based aging where a battery degrades from energy in and
out of the battery. Cycle capacity loss is dependent on the frequency of use of the battery,
the level of charging the battery experiences, and electrochemical aging due to the growth
of an internal solid-electrolyte interphase (SEI) layer caused by various factors such as high
temperature and high current.
86 87
The second is calendar aging where a battery degrades
based on the conditions the battery experiences over a period of time when the battery is
storing energy rather than charging or discharging. Calendar capacity loss is significant to
battery durability as electric vehicles are generally idling for longer periods of time rather
than operating. Calendar aging contributes more to capacity loss than cycle aging, with an
average capacity loss of 31 percent after 10 years with most of the loss occurring in earlier
years.
88
Some factors that contribute to calendar capacity loss include state of charge,
temperature the vehicle battery is exposed to, and time. One of the primary degradation
mechanisms is the time a battery spends at elevated temperatures. Another is the time a
battery spends close to its upper and lower voltage limits. These degradation factors are
84
U.S. Department of Energy Vehicle Technologies Program. 2020. “United States Advanced Battery
Consortium Battery Test Manual for Electric Vehicles.” U.S. Department of Energy: Energy Efficiency and
Renewable Energy (EERE). October 2020.
85
MIT Electric Vehicle Team. 2008. “A Guide to Understanding Battery Specifications.” December.
https://web.mit.edu/evt/summary_battery_specifications.pdf
86
Yang, Fan, Yuanyuan Xie, Yelin Deng, and Chris Yuan. 2018. "Predictive modeling of battery degradation and
greenhouse gas emissions from U.S. state-level electric vehicle operation." Nature Communications.
doi:10.1038/s41467-018-04826-0.
87
Edge, Jacqueline S, Simon O'Kane, Ryan Prosser, Niall S Kirklady, Anisha N Patel, Alastair Hales, Abir Ghosh,
et al. 2021. "Lithium ion battery degradation: what you need to know." Physical Chemistry Chemical Physics 23
(14): 8200-8221. doi:10.1039/d1cp00359c.
88
Yang, Fan, Yuanyuan Xie, Yelin Deng, and Chris Yuan. 2018. “Considering Battery Degradation in Life Cycle
Greenhouse Gas Emission Analysis of Electric Vehicles.” 25th CIRP Life Cycle Engineering (LCE) Conference
505-510. doi:10.1016/j.procir.2017.12.008
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
constantly being evaluated to better understand how to mitigate them and improve battery
durability.
1. Factors Impacting Battery Durability and Degradation
Battery durability and degradation are dependent upon various factors, such as fast charging,
ambient temperature, state of charge of the battery, driving cycles, battery thermal
management, and vehicle-to-grid connectivity.
The level of charging a vehicle battery receives can accelerate battery degradation. Studies
have shown that more DC fast charging use, particularly in hot climates, could lead to quicker
degradation and decreased usable energy compare to BEVs that do not use fast charging.
89
90
When two 2012 Nissan Leaf battery packs rated at 24 kWh were tested for charging
impacts on the battery, the pack charged with a Level 2 charger showed a capacity fade of
23.1 percent and the DC fast charged pack had a capacity fade of 28.1 percent.
91
Optimization of charging can help mitigate the impacts of fast charging to the battery, which
can help reduce capacity fade.
92
Ambient temperature also has an influence on battery durability and degradation both for
calendar and cycle aging. Environmental, charging, and operating temperatures
independently and combined can affect the longevity of vehicle battery life. To increase
battery life, batteries should operate between 25C and 30C as the rate of degradation tends
to increase with temperature increase.
93 94
Other studies have shown that operating
temperatures can impact aging, and battery operating temperatures should be between 15C
and 35C to minimize battery degradation. Charging the battery at low temperatures can also
lead to lithium deposition which can accelerate degradation of the battery. As for calendar
aging, environmental temperatures also have a significant impact, as storing the battery at
temperatures outside the range of 15C to 35C can be harmful to battery life.
95
With
increasing temperatures, battery cycle life is significantly impacted and reduced, as
89
Argue, Charlotte. 2020. “What can 6,000 electric vehicles tell us about EV battery health?” Geotab. July 7.
Accessed July 16, 2021. https://www.geotab.com/blog/ev-battery-health/.
90
Transport Canada. 2017. “Electric Vehicle Battery Durability Testing and Evaluation.” October. Accessed
March 3, 2022. https://wiki.unece.org/download/attachments/51973240/EVE-24-09-rev1e.pdf?api=v2.
91
Tanim, Tanvir R., Matthew G. Shirk, Randy L. Bewley, Eric J. Dufek, and Bor Yann Liaw. 2018. The implications
of fast charge in lithium ion battery performance and life: cell vs. pack. Study, Energy Storage and Advanced
Vehicles Department, Idaho National Laboratory, Idaho Falls, Idaho.
92
Hoke, Anderson, Alexander Brissette, Kandler Smith, Annabelle Pratt, and Dragan Maksimovic. 2014.
"Accounting for Lithium-Ion Battery Degradation in Electric Vehicle Charging Optimization." IEEE Journal of
Emerging and Selected Topics in Power Electronics 691-700. doi:10.1109/JESTPE.2014.2315961.
93
Eider, Markus, and Andreas Berl. 2018. "Dynamic EV Battery Health Recommendations." e-Energy '18:
Proceedings of the Ninth International Conference on Future Energy Systems. New York, NY: ACM. 586-592.
doi:10.1145/3208903.3213896.
94
Yanh, Fan, Yuanyuan Xie, Yelin Deng, and Chris Yuan. 2018. "Predictive modeling of battery degradation and
greenhouse gas emissions from U.S. state-level electric vehicle operation." Nature Communications, June 21.
doi:10.1038/s41467-018-04826-0.
95
Han, Xuebing, Languang Lu, Yuejiu Zheng, Xuning Feng, Zhe Li, Jianqiu Li, and Minggao Ouyang. 2019. "A
review on the key issues of the lithium ion battery degradation among the whole life cycle." eTransportation 1.
doi:10.1016/j.etran.2019.100005.
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
increasing the number of charge and discharge cycles reduces battery capacity which is
further impacted by increasing temperatures.
96
Other research has shown that a combination
of low temperature and high state of charge shows highest capacity fade, with moderate
temperatures of 25C showing the lowest capacity fade.
97
Both low and high temperature
extremes can therefore adversely impact vehicle range.
98 99 100
Battery degradation is further impacted by driving patterns, storage, and charging. Pulling
too much current from a battery over a certain amount of time such as through aggressive
driving patterns can have detrimental effects on battery life.
101
Current flow through a battery
creates heat and can cause side reactions that reduce battery life. The smaller the current
flow, the longer the battery life.
102
Battery state of charge (SoC) can also impact battery life.
A higher SoC indicates higher terminal voltage and a lower anode potential relative to a
higher cathode potential, which can result in solid-electrolyte interphase thickening. This SEI
thickening causes the battery to age quicker. Cycle aging occurs when the battery is charging
or discharging and can be induced by current flow and SoC levels and is accelerated by high
internal temperatures. To maximize battery life, batteries should not be stored at high SoC,
but rather be maintained at 80 percent or lower while minimizing the depth of discharge.
103
104
In other words, draining most of a battery’s capacity frequently, or completely draining a
battery, reduces battery capacity over time. Similarly, charging an electric vehicle beyond its
voltage limit can cause internal resistance in the battery; however, most batteries have built-
in battery management systems, so overcharging is rarely an issue. When combined with
temperature impacts, SoC can aggravate battery degradation further.
105
While temperature can greatly impact battery degradation, battery thermal management can
provide some aid in battery longevity with a system that can engage and disengage in
thermal management when needed. Thermal management systems are important for
batteries since temperature impacts various parameters related to battery longevity,
performance, and discharge rate of the battery. Vehicles with a liquid cooling system, such as
the 2015 Tesla Model S, have shown a lower average degradation rate than vehicles with a
96
Carnovale, Andrew, and Xianguo Li. 2020. "A modeling and experimental study of capacity fade for lithium-
ion batteries." Energy and AI. doi:10.1016/j.egyai.2020.100032.
97
Keil, Peter, and Andreas Jossen. 2015. "Aging of Lithium-Ion Batteries in Electric Vehicles: Impact of
Regenerative Braking." World Electric Vehicle Journal 7.
98
Argue, “What can 6,000 electric vehicles”
99
American Automobile Association, Inc. 2019. AAA Electric Vehicle Range Testing. AAA.
https://www.aaa.com/AAA/common/AAR/files/AAA-Electric-Vehicle-Range-Testing-Report.pdf.
100
Sacramento Metropolitan Air Quality Management District. 2020. “Electric vehicle charging and extreme
heat.” Urban Heat Island Project. Accessed March 15, 2022.
https://www.airquality.org/LandUseTransportation/Documents/UHI%20EV%20charging%20and%20extreme%2
0heat.pdf.
101
Eider et al., “Dynamic EV Battery Health Recommendations”
102
Han et al., “A Review of lithium-ion battery degradation”
103
Eider et al., “Dynamic EV Battery Health Recommendations”
104
Keil, Peter, Simon F. Schuster, Jӧrn Wilhelm, Julian Travi, Andreas Hauser, Ralph C. Karl, and Andreas Jossen.
2016. "Calendar Aging of Lithium-Ion Batteries." Journal of the Electrochemical Society 163 (9)
105
Kostopoulos, Emmanouil D., George C. Spyropoulos, and John K. Kaldellis. 2020. "Real-world study for the
optimal charging of electric vehicles." Energy Reports 6: 418-426. doi:10.1016/j.egyr.2019.12.008.
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
passive air-cooling system, such as the 2015 Nissan Leaf.
106
Batteries with adequate thermal
management can provide the battery with needed cooling to decrease operating
temperatures as well as battery degradation.
Lastly, implementing vehicle-to-grid (V2G) connectivity or bidirectional charging with electric
vehicle batteries can further deplete battery life while the vehicle odometer or vehicle age
may not reflect this utilization. A recent study assessed costs and impacts of V2G on battery
degradation in 20 new Nissan Leaf vehicles with optimization that ran over three years in 1-
hour intervals. The projected remaining battery capacity after three years ranged from 67.8
to 75.6 percent.
107
Another experiment conducted laboratory testing of commercial 18650 Li-
ion cells which included cycling experiments for V2G impacts and calendar aging
experiments for temperature and SoC impacts. Results showed that V2G use can increase the
capacity loss by 33 percent when V2G charging is performed once a day.
108
Batteries with
lower SoC limits of 50-90 percent could reduce battery degradation.
109
These results indicate
that V2G could decrease battery life when not properly managed.
2. Battery Electric Vehicle Durability Improvements
Electric vehicles on the road today are already able to maintain 80 percent of the vehicle’s
original battery capacity for 10 years or 150,000 miles. When looking at the United States
Advanced Battery Consortium electric vehicle battery goals for battery life of 15 years, an
analysis conducted on lithium-ion cells of Panasonic NCR18650PD revealed capacity loss was
well within the 80 percent benchmark even at different temperatures.
110
Tesla’s fleet of over
1 million Tesla Model S and X vehicles have also shown less than 15 percent battery
degradation for vehicles that drove between 150,000 and 200,000 miles.
111
Tesloop, which is
a Tesla rental company in Southern California, operated a Tesla Model X 90D with 350,000
miles on an original battery while only experiencing a 13 percent capacity fade, which
translated to a range reduction from 247 miles to 215 miles at 95 percent charge.
112
Similarly, state of health data for Nissan Leaf’s from the 2013 through 2019 model years have
shown that the Nissan Leaf has improved state of health throughout the years. The 2013
model had 3 percent degradation the first year and 8.9 percent degradation by the third year
whereas the 2016 model had 2.3 percent degradation the first year and 6.9 percent
106
Argue, “What can 6,000 electric vehicles”
107
Gowda, Shashank Narayana, Basem Eraqi, Hamidreza Nazaripouya, and Rajit Gadh. 2021. "Assessment and
Tracking Electric Vehicle Battery Degradation Cost using Blockchain." Innovative Smart Grid Technologies
Conference (ISGT). Virtual: IEEE Power & Energy Society. 1-5. doi:10.1109/ISGT49243.2021.9372218.
108
Dubarry, Matthieu. 2017. Electric Vehicle Battery Durability And Reliability Under Electric Utility Grid
Operations. Hawaii Natural Energy Institute. http://publications.energyresearch.ucf.edu/wp-
content/uploads/2018/06/FSEC-CR-2064-17.pdf.
109
Tchagang, Alain, and Yeong Yoo. 2020. "V2B/V2G on Energy Cost and Battery Degradation under Different
Driving Scenarios, Peak Shaving, and Frequency Regulations." World Electric Vehicle Journal 11 (1): 14.
doi:10.3390/wevj11010014.
110
Keil et al., “Aging of Lithium-Ion Batteries in Electric Vehicles”
111
Tesla. 2019. Impact Report. Tesla. https://www.tesla.com/ns_videos/2019-tesla-impact-report.pdf.
112
Kane, Mark. 2019. Insideevs.com - Tesloop Explains Various Causes For Tesla Battery Degradation. April 22.
Accessed March 2, 2022. https://insideevs.com/news/345589/tesloop-reasons-cause-battery-degradation/.
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
degradation by the third year.
113
The 2017 model had 2 percent degradation the first year
showing improvement from previous years. An average decline across 21 vehicle models
indicated a 2.3 percent degradation per year, which can translate to a 150-mile range vehicle
losing 17 miles after 5 years.
114
From these real-world examples, 80 percent battery
degradation can support vehicles that have travelled up to 150,000 miles before reaching a
critical point of excessive range loss. And with automakers putting forth vehicles with higher
battery capacity, the degradation should be less when compared to a smaller battery size.
Furthermore, electric vehicle batteries may be able to provide necessary range even after 70-
80 percent battery degradation.
115 116
C. Battery Trends and Future Improvements
Conventional lithium-ion batteries like those with nickel manganese cobalt (NMC), nickel
cobalt aluminum (NCA), and nickel manganese cobalt aluminum (NMCA) cathodes have
continued to improve year over year trending towards reductions in cobalt and increases in
nickel for higher energy density.
117 118
Some of those improvements have slowed recently due
to impacts in material availability. Several companies, including Tesla, have prioritized lithium
iron phosphate (LiFePO4) chemistries, despite the lower energy density relative to nickel and
cobalt based chemistries to meet demand in the lower range versions of vehicles.
Although the technology and cost analysis for the ACC II proposal relied on conventional
lithium-ion batteries, the 2021 National Academies of Sciences, Engineering, and Medicine
report on light-duty vehicle technologies identified several pathways for advanced battery
technologies that go beyond conventional lithium-ion based systems including lithium
anodes, solid-state separators, lithium sulfur designs, lithium air designs, and magnesium-
based batteries.
119
With these advanced battery technologies possible reduction in mass,
charging times, and cost for future ZEVs has the potential to be transformative for the
industry. Several companies have moved some advanced technologies out of the lab phase
and are now working on making the batteries durable, manufacturable, and cheap enough
for the light-duty automotive market.
113
Argue, “What can 6,000 electric vehicles”
114
Argue, “What can 6,000 electric vehicles”
115
Casals, Lluc Canals, Marta Rodriguez, Cristina Corchero, and Rafeal E. Carrillo. 2019. "Evaluation of the End-
of-Life of Electric Vehicle Batteries According to the State-of-Health." World Electric Vehicle Journal 10 (4): 63.
doi:10.3390/wevj10040063.
116
Saxena, Samveg, Caroline Le Floch, Jason MacDonald, and Scott Moura. 2015. "Quantifying EV battery end-
of-life through analysis of travel needs with vehicle powertrain models." Journal of Power Sources 282: 265-276.
doi:10.1016/j.jpowsour.2015.01.072.
117
Tesla, Tesla Battery Day.
118
GM. 2020. GM Reveals New Ultium Batteries and a Flexible Global Platform to Rapidly Grow its EV Portfolio.
March 4. Accessed March 4, 2022.
https://media.gm.com/media/us/en/gm/home.detail.print.html/content/Pages/news/us/en/2020/mar/0304-
ev.html.
119
National Academies of Sciences, Engineering, and Medicine. 2021. Assessment of Technologies for
Improving Light-Duty Vehicle Economy - 2025-2035. Consensus Study, Washington D.C.: The National
Academies. doi:10.17226/26092.
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
The International Council on Clean Transportation (ICCT) identified three advanced battery
companies and their announced cell energy densities in Table 6, and there are many other
companies working to create next generation battery technologies.
120
Many of those
companies have announced partnerships with vehicle manufacturers, new breakthroughs in
preproduction cells, or even cells that are going into production in consumer products with
durability requirements that are lower than the light-duty automotive sector. But those
consumer product batteries provide an important steppingstone to demonstrate
manufacturing capability while the companies work to improve cycle durability and calendar
life.
Table 6. Energy Density of Battery Technologies
Company
Technology
Energy density
(Wh/kg)
Reference
Existing
Lithium-ion
(various)
100-260
121
SES
Lithium metal
417
122
Solid power
Lithium metal
440
123
Solid power
High content silicon
390
124
Quantumscape
Lithium metal
380-500
125
Silicon anode technologies can greatly improve energy density over conventional graphite
anodes. Graphite has a maximum theoretical specific capacity of 372 (mAh/g) while silicon
has a maximum of 3,600 (mAh/g).
126
Unfortunately, lithium alloys with silicon swells more than
300 percent, which severely limits the use of silicon as an anode without specific mitigation
methods to ensure appropriate cycle life. Several companies like Amprius Technologies, Inc
(Amprius), Enovix Corporation (Enovix), and Sila Nanotechnologies, Inc. (Sila) are
120
Slowik, Peter, Michael Nicholas, Anh Bui, Logan Pierce, and Stephanie Searle. 2021. Memorandum Re:
Advanced Clean Cars (ACC) II ZEV Cost Modeling Workbook. December 23.
121
Yang, Gene et al. (2020) Advances in Materials Design for All-Solid-state Batteries: From Bulk to Thin Films.
Journal of Applied Sciences.
https://www.researchgate.net/publication/342821920_Advances_in_Materials_Design_for_All-Solid-
state_Batteries_From_Bulk_to_Thin_Films
122
Business Wire. 2021. Business Wire - SES Unveils World’s First 100 Plus Ah Li-Metal Battery, Announces New
Gigafactory at First SES Battery World. November 3. Accessed March 4, 2022.
https://www.businesswire.com/news/home/20211103005931/en/SES-Unveils-World%E2%80%99s-First-100-
Plus-Ah-Li-Metal-Battery-Announces-New-Gigafactory-at-First-SES-Battery-World.
123
Solid Power. 2022. A New Breed of Battery. Accessed March 4, 2022. https://solidpowerbattery.com/.
124
Solid Power, A New Breed of Battery.
125
QuantumScape. 2021. Electric vehicles are here. The future is solid. Accessed March 4, 2022.
https://web.archive.org/web/20211224000843/https://www.quantumscape.com/
126
Scott, Alex. 2019. Chemical & Engineering News - In the battery materials world, the anode’s time has come.
April 7. Accessed February 28, 2022. https://cen.acs.org/materials/energy-storage/battery-materials-world-
anodes-time/97/i14.
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
demonstrating promising developments in silicon-based technologies towards the goal of
placing that technology into electric vehicles.
Amprius recently announced that they shipped their first commercially available 450 Wh/kg
and 1150 Wh/L cells for use in high-altitude pseudo-satellites. Enovix announced in
September of 2021 that they hit a major milestone with start of production of their first
battery cells from its automated manufacturing line and had shipped custom cells to a top-
tier consumer electronics company for augmented reality glasses.
127
Sila’s technologies are
being utilized in a health and fitness tracker, the WHOOP 4.0 wristband, that is now available
to consumers. The integration of Sila’s advanced battery technology improved energy
density by 17 percent and reduced the size of the WHOOP 4.0 over its previous
generation.
128
These announcements and products demonstrate that the technology is
developing according to the respective battery manufacturer’s plans towards mass
manufactured versions for light-duty automotive applications.
Solid state battery companies have received a lot of attention in the last few years. Solid
state batteries, which are generally lithium-ion based, replace the electrolyte and separator in
a battery cell with a solid material. That material is usually a type of polymer or ceramic. Solid
Power has stated that they intend to bring all solid-state designs to production.
129
SES and
QuantumScape have stated that they will be pursuing a hybrid pathway that has a solid-state
separator, but the cathode side utilizes a liquid or gel electrolyte, otherwise known as a
catholyte.
130 131
Other companies like Factorial and Prologium are pursuing an all-solid-state
approach and now have agreements and investments with several vehicle manufacturers.
Another battery company based out of Berkeley, California, PolyPlus Battery Company
(PolyPlus), has been working on solid state battery technology for some time with its glass-
protected lithium metal battery. PolyPlus signed a joint development agreement with SK
Innovation Co. Ltd. (SK) in 2019 to focus on solid-state lithium anode laminate that has the
potential to double the energy density and cycle life of rechargeable batteries.
132
Solid state
cells potentially can work with a variety of different anodes and cathodes and have several
potential technical advantages, including for battery safety.
127
Enovix Corporation. 2021. Enovix Achieves Major Milestones: U.S.-Based Factory Produces First Battery Cells
Off Its Automated Manufacturing Line and Ships Custom Design for AR Glasses. September 22. Accessed
February 15, 2022. https://ir.enovix.com/news-releases/news-release-details/enovix-achieves-major-milestones-
us-based-factory-produces-first.
128
Sila Nanotechnologies, Inc. 2021. Unlocking Radical Product Innovation from the Inside Out. September 7.
Accessed March 4, 2022. https://www.silanano.com/news/unlocking-radical-product-innovation-from-the-inside-
out.
129
Solid Power. n.d. Solid Power's All-Solid-State Battery Cell Technology. Accessed February 17, 2022.
https://solidpowerbattery.com/batteries/.
130
Donnelly, Grace. 2021. Emerging Tech Brew: SES says its next-gen battery could be in cars by 2025.
November 3. Accessed March 4, 2022. https://www.morningbrew.com/emerging-tech/stories/2021/11/03/ses-
says-its-next-gen-battery-could-be-in-cars-by-2025.
131
QuantumScape. 2021. Solid-State Battery Landscape. February 16. Accessed February 28, 2022.
https://www.quantumscape.com/resources/blog/solid-state-battery-landscape/.
132
PolyPlus Battery Company. 2019. PolyPlus Battery Company. February 18. Accessed February 11, 2022.
https://polyplus.com/polyplus-and-sk-enter-into-joint-development-agreement-for-glass-protected-lithium-
metal-battery/.
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
Battery and automotive manufacturers are continuing to further improve battery safety, and
new technologies like solid state batteries can bring significant improvements in this regard.
Liquid based electrolytes in most lithium-ion batteries are flammable under extreme
conditions and are likely the first part of a cell to ignite.
133
Solid electrolytes do away with that
hazard by replacing that electrolyte with a solid material that is not flammable, making the
batteries inherently safer. Solid Power has stated that third-party safety tests of its
development cells in 2021, which included a nail penetration test, demonstrated better
resistance to fire than conventional lithium-ion battery safety results.
134
While there have been incidences of vehicle battery fires and recalls for BEVs, this does not
mean that BEVs pose greater risks than hybrid and conventional vehicles.
135 136
Conventional
ICE and hybrid vehicles continue to have fire risks.
137
A recent study of recalls and on-road
incidents demonstrated that hybrid and conventional ICE vehicles have much higher fire
related incidence rates than BEVs.
138
While BEVs arguably pose similar or less risk of fire than
hybrid and conventional vehicles, solid-state batteries could help to further reduce battery
related fire risks altogether. This may make future BEVs even safer than the data suggests
current BEVs already are.
D. Energy Efficiency Improvements
In conjunction with increases in battery pack energy capacity, the energy efficiency of BEVs is
also increasing. Several vehicle models that have been in the market for more than one or
two model years have seen year-over-year energy efficiency increases since they were first
introduced. Tesla’s Model 3 long range AWD model variants started in 2018 with 116 MPGe
and in less than four years are now achieving an efficiency of 131 MPGe.
139
The Model S has
increased 35 percent from 89 MPGe to 120 MPGe in the ten years since it was first
introduced for the 2012 model year.
140
New models like the 2022 model year Lucid Motors
133
Hess, Steffen, Margret Wohlfahrt-Mehrens, and Mario Wachtler. 2015. "Flammability of Li-Ion Battery
Electrolytes: Flash Point and Self-Extinguishing Time Measurements." Journal of The Electrochemical Society
162: A3084.
134
Solid Power. 2021. Are Solid-State Cells Safer? December 8. Accessed February 28, 2022.
https://solidpowerbattery.com/solid-state-safety/.
135
NHTSA. 2021. Consumer Alert: GM Expands Recall, All Chevrolet Bolt Vehicles Now Recalled. August 20.
Accessed February 17, 2022. https://www.nhtsa.gov/press-releases/recall-all-chevy-bolt-vehicles-fire-risk.
136
NHTSA. 2021. "Part 573 Safety Recall Report 21V-127." NHTSA. March 1. Accessed March 4, 2022.
https://static.nhtsa.gov/odi/rcl/2021/RCLRPT-21V127-1095.PDF.
137
Barry, Keith. 2022. Nissan Rogue Recalled for Fire Risk and Electrical Issues. January 26. Accessed February
17, 2022. https://www.consumerreports.org/car-recalls-defects/nissan-rogue-recalled-for-fire-risk-and-electrical-
issues-a4879259490/
138
Bodine, Rachel. 2022. AutoInsuranceEZ.com: Gas vs. Electric Car Fires [2021 Findings]. January 21. Accessed
February 17, 2022. https://www.autoinsuranceez.com/gas-vs-electric-car-fires/.
139
U.S. Department of Energy and the U.S. Environmental Protection Agency. n.d. Fueleconomy.gov - 2018
Tesla Model 3 Long Range AWD and 2022 Tesla Model 3 Long Range AWD. Accessed March 1, 2022.
https://www.fueleconomy.gov/feg/Find.do?action=sbs&id=40385&id=45011.
140
U.S. Department of Energy and the U.S. Environmental Protection Agency. n.d. Fueleconomy.gov - 2012
Tesla Model S, 2022 Tesla Model S. Accessed March 1, 2022.
https://www.fueleconomy.gov/feg/Find.do?action=sbs&id=32557&id=45014.
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
Air large sedan are also debuting with impressive efficiencies for the vehicle’s size and
power, indicating that further gains in efficiency can be achieved by better reducing mass
and better optimizing for efficiency rather than performance. Lucid Motors submitted
comments in response to CARB’s May 2021 Workshop stating that their Air sedan is “17
percent more efficient than other leading electric cars and gets an additional 100 miles out of
the same sized battery pack as a leading competitor.”
141
The ICCT submitted comments concerning CARB’s ZEV cost modeling used for generating
incremental costs in the ACC II SRIA demonstrating CARB’s estimates of BEV efficiencies
were too conservative.
142
The ICCT provided an extensive table of existing models’
efficiencies like the Tesla Model 3 and Kia EV6 which shows those vehicles to be more
efficient than what CARB was projecting for similar vehicles starting in the 2026 model year.
The ICCT additionally analyzed Argonne National Laboratory’s (ANL) outputs from its
Autonomie model runs completed for ANL’s 2021 Light-Duty Vehicle Technology report to
the DOE.
143 144
Their analysis showed that the Autonomie outputs for BEV efficiencies could
be representative of 2026 model year BEVs with an eleven percent upward adjustment to
those efficiencies to account for how far current vehicles have already come. In response to
those comments and presented data, CARB staff adjusted BEV efficiencies, which are
outlined in Section X.A.1.a of the Initial Statement of Reasons (ISOR).
Manufacturers have realized those full vehicle efficiency improvements through several areas,
some of which are specific to electrical components. Further optimizations in electric motors
have increased both their power density and efficiency. Inverter efficiencies have benefited
appreciably from the introduction of silicon carbide (SiC) based semiconductors into the
industry. Additional efficiency gains have also come from high levels of integration. Munro’s
Model 3 and Model Y teardown reports demonstrated that Tesla has maintained its strategy
of continual improvements that are forcing other manufacturers to be nimbler and iterate on
their products more quickly than many have historically done. Ford is planning several
incremental changes to its Mustang Mach-E prior to a standard mid-cycle refresh cadence
that will increase range and efficiency.
145
Other improvements in efficiency have come from vehicle level design decisions, many of
which have been made possible by BEV specific platforms. Manufacturers continue to iterate
141
Witt, Daniel - Lucid Motors. 2021. RE: Lucid Comments on May 6, 2021 Advanced Clean Cars II Workshop.
Comment letter submitted to CARB by Lucid Motors. June 11, 2021.
142
Slowik, Peter et. al., 2021.
143
Islam, Ehsan Sabri, Ram Vijayagopal, Ayman Moawad, Namdoo Kim, Benjamin Dupont, Daniela Nieto Prada,
and Aymeric Rousseau. 2021. ANL/ESD-21/10 - A Detailed Vehicle Modeling & Simulation Study Quantifying
Energy Consumption and Cost Reduction of Advanced Vehicle Technologies Through 2050. Energy Systems
Division, Argonne National Laboratory, October. Accessed March 1, 2022. https://vms.es.anl.gov/case-
studies/u-s-doe-vto-hfto-r-d-benefits/.
144
Autonomie is a computer model for assessing the energy consumption and cost of multiple advanced
powertrain technologies, developed by ANL and partners.
See Autonomie Vehicle System Simulation Tool |
Argonne National Laboratory (anl.gov) for more information.
145
Edelstein, Stephen. 2022. CEO: Ford Plans to "Reengineer" Mustang Mach-E Incrementally, Won't Save
Improvements for Mid-Cycle Refresh. Green Car Reports. February 7. Accessed February 15, 2022.
https://www.greencarreports.com/news/1134986_ceo-ford-plans-to-reengineer-mustang-mach-e-incrementally-
wont-save-improvements.
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
on those BEV platforms and bodies to improve aerodynamic efficiency. It has been reported
that Lucid Motors’ new Air sedan achieves a drag coefficient of 0.200.
146
Mercedes claims
that its EQS sedan has a coefficient of drag of 0.20.
147
Tesla states a drag coefficient of 0.208
for its latest Model S sedan iteration.
148
These gains in aerodynamic efficiency demonstrate
that manufacturers are leveraging BEV-specific platforms to further enhance range and
overall vehicle efficiency and will likely do so across all vehicle types.
Manufacturers have also developed innovative drivetrain strategies to mitigate potential
efficiency losses from adding a second motor for AWD capability. Tesla, with its AWD
versions of its vehicles, introduced the Model 3 with a permanent magnet motor at the rear
axle, and an AC induction electric motor at the front axle such that when the motor is not
powered there is no inherent magnetism of a permanent magnet motor to overcome. Lucid
Motors has developed a front axle disconnect for their Air large sedan which disconnects the
front permanent magnet motor when it is not being utilized by the vehicle for tractive power
or regeneration, thereby reducing any magnetic drag.
As discussed, battery developments are also moving forward. Should advanced battery
technologies like solid state designs, silicon anodes, lithium anodes, or others become viable
for light-duty automobile use, those technologies will likely reduce the total vehicle mass
significantly. In a vehicle like the Tesla Model Y, an advanced battery cell with an energy
density of 400 Wh/kg would likely result in a reduction of battery pack mass of about 35
percent compared to the current battery pack without counting any of the additional
downstream mass reduction effects from moving to a solid-state cell, like the ability to utilize
bipolar stacking.
149
E. Critical Materials for Electric Vehicle Batteries
Lithium batteries depend on a short list of materials with unique properties and few
substitutes. As mentioned, lithium-ion batteries typically combine lithium with nickel,
manganese, cobalt, aluminum, or iron for the cathode, use aluminum for packaging and the
cathode’s current collector, and have an anode consisting of graphite and a copper current
collector.
150
Of the materials used in lithium-ion battery cells, the US government deems
many to be critical. Because the supply of these materials is crucial for their performance but
may also be constrained or put at risk due to natural, geopolitical, and economic forces, they
are referred to as critical materials. In 2018, the U.S. Department of Interior identified a range
of lithium-ion battery materials as critical materials to the economic and national security of
146
Markus, Frank. 2021. How the Lucid Air’s Aerodynamic Tricks Gain It Access to the .200 Club. Motor Trend.
November 15. Accessed January 27, 2022. https://www.motortrend.com/news/2022-lucid-air-luxury-ev-design-
aero-tricks/.
147
Mercedes-Benz Group Media. 2021. The new EQS: Aerodynamics. April 15. Accessed March 1, 2022.
https://group-media.mercedes-benz.com/marsMediaSite/en/instance/ko/The-new-EQS-
Aerodynamics.xhtml?oid=49581781.
148
Tesla. 2022. Tesla Model S. Accessed January 27, 2022. https://www.tesla.com/models.
149
With cell mass of 69g and assumed 18.25Wh per cell.
150
Union of Concerned Scientists. 2021. Electric Vehicles Batteries: Addressing Questions about Critical
Materials and Recycling. February. Accessed March 3, 2022. https://www.ucsusa.org/sites/default/files/2021-
02/ev-battery-recycling-fact-sheet.pdf.
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
the United States, including lithium, cobalt, manganese, and aluminum.
151
In 2022, the final
list of critical minerals was revised, which maintained that many of the minerals used in
electric vehicle batteries are critical minerals.
152
Of those, lithium and cobalt are generally
considered to have the most significant supply risk due to the high geographic concentration
of production.
153
Recycling batteries reduces the need for extracting, refining, and
transporting new minerals, recycling batteries domestically presents an opportunity to
recover critical materials while reducing reliance on imports and mitigating supply risk and
reducing the environmental and social burden of raw material production.
154
F. Battery Recycling and Reuse
As described earlier, ZEVs and PHEVs are powered by high-voltage traction batteries. As
electric vehicles retire from service, retired traction batteries will be created. Traction
batteries are large format, long-lived, rechargeable devices which contain a range of high-
value materials with limited natural availability.
Automakers in the U.S. market typically warrant traction or high-voltage batteries for BEVs
for 8 years or 100,000 miles.
155
Meanwhile, the traction batteries on PHEVs certified to
CARB’s transitional ZEV standard are warranted for 10 years or 150,000 miles. As battery
technology progresses, and to maximize BEV benefits, increasing the battery warranty on
these vehicles to cover more vehicle mileage for an extended period ensures the vehicles
have a reliable battery for a longer period of the vehicles’ lifespan. Once battery capacity
drops below 70 percent of the initial range, or if the vehicle is out of warranty and the battery
pack or individual modules are replaced, those batteries would enter end of life management
processes. Retired traction batteries can be reused, repurposed, recycled, or ultimately
discarded in a hazardous waste landfill.
1. Battery Reuse and Repurposing
Electric vehicle batteries will be retired from their primary application either when the vehicle
itself is physically damaged or when the range and/or performance is no longer acceptable
to the driver. Retired battery systems are likely to enter a range of applications based on
151
U.S. Department of the Interior. 2018. “Final List of Critical Minerals 2018.” Office of the Secretary, Interior.
Federal Register Vol. 83, No. 97. May 18. Accessed March 3, 2022. https://www.govinfo.gov/content/pkg/FR-
2018-05-18/pdf/2018-10667.pdf.
152
Burton, Jason. 2022. U.S. Geological Survey Releases 2022 List of Critical Minerals. U.S. Geological Survey,
Department of the Interior. February 22. Accessed March 7, 2022. https://www.usgs.gov/news/national-news-
release/us-geological-survey-releases-2022-list-critical-minerals.
153
Olivetti, Elsa A., Gerbrand Ceder, Gabrielle G. Gaustad, Xinkai Fu. 2017. “Lithium-Ion Battery Supply Chain
Considerations: Analysis of Potential Bottlenecks in Critical Metals.” Joule 2017, 1 (2), 229243.
https://doi.org/10.1016/j.joule.2017.08.019.
154
Kendall, Alissa, Margaret Slattery, and Jessica Dunn. 2021. Lithium-ion Car Battery Recycling Advisory Group:
DRAFT Report. AB 2832 Advisory Group. December 1. Accessed March 3, 2022.
https://www.calepa.ca.gov/wp-content/uploads/sites/6/2021/12/Materials-Meeting-16-Lithium-ion-Car-Battery-
Recycling-Advisory-Group-AB-2832-Draft-Policy-Recommendations-as-of-12.01.2021.pdf.
155
Office of Energy Efficiency & Renewable Energy, 2016. “Fact #913: February 22, 2016 The Most Common
Warranty for Plug-In Vehicle Batteries is 8 Years/100,000 Miles”. Posted February 22, 2016.
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
their physical characteristics, state of health, and performance. Some modules with minimal
degradation and absent defects or damage could likely be refurbished and reused directly as
replacement battery packs for the same model vehicle. Major automakers, including Nissan
and Tesla, have offered rebuilt or refurbished battery packs for purchase or warranty
replacement of original battery packs.
156
When retired after its vehicle life, electric vehicle
batteries are expected to retain as much as 80 percent of their initial capacity, though the
actual condition will vary from vehicle to vehicle.
157
After use in a vehicle, lithium battery packs could deliver an additional 5-8 years of service in
a stationary application. To be used as stationary storage, used batteries must undergo
several processes that are currently costly and time intensive. Each pack must be tested to
determine the remaining state of health of battery modules, as it will vary for each retired
system depending on factors that range from climate to individual driving behavior. The
batteries must then be inspected, fully discharged, and reconfigured to meet the energy
demands of their new application. In many cases, packs are disassembled before modules
are tested, equipped with a battery management system, and re-packaged. The key barrier
to the second-life battery industry stems from the process of testing and repurposing used
battery systems, which makes it difficult for used systems to compete with new battery
storage given the rapidly falling cost and improving performance of new lithium-ion battery
systems.
Given the growing market for electric vehicles, second-life batteries could represent an
important resource for stationary energy storage applications. Examples of stationary energy
storage applications include backup power for homes or cellular towers, or, in larger arrays,
for large buildings like arenas or even in utility grid applications.
158
Second-life batteries may
be 30 to 70 percent less expensive than new ones in energy storage applications in 2025.
159
By 2030, the second-life battery supply from the burgeoning PEV market could exceed 200
gigawatt-hours per year, which could exceed demand by almost 25 percent.
160
Second-life
batteries would also reduce the demand for virgin materials used in the production of new
energy storage batteries.
161
156
Avarts, Eric C. 2018. Nissan begins offering rebuilt Leaf battery packs. Green Car Reports. May 14. Accessed
March 1, 2022. https://www.greencarreports.com/news/1116722_nissan-begins-offering-rebuilt-leaf-battery-
packs.
157
Hossain et al. 2019. “A Comprehensive Review on Second-Life Batteries: Current State, Manufacturing
Considerations, Applications, Impacts, Barriers & Potential Solutions, Business Strategies, and Policies.” IEEE.
June 18. Accessed March 3, 2022. https://ieeexplore.ieee.org/stamp/stamp.jsp?tp=&arnumber=8718282
158
158
Wentworth, Adam. 2018. Amsterdam Arena installs major new battery storage. ClimateAction. July 02.
Accessed March 1, 2022. https://www.climateaction.org/news/amsterdam-arena-installs-major-new-battery-
storage.
159
Engel, Hauke, Patrick Hertzke, and Giulia Siccardo. 2019. Second-life EV batteries: The newest value pool in
energy storage. McKinsey & Company. April 30. Accessed April 30, 2022.
https://www.mckinsey.com/industries/automotive-and-assembly/our-insights/second-life-ev-batteries-the-
newest-value-pool-in-energy-storage.
160
Engel, Second-life EV batteries
161
Casals, Lluc Canals, B. Amante Garcia, and Camille Canal. 2019. "Second life batteries lifespan: Rest of useful
life and environmental analysis." Journal of Environmental Management, February 15: 354-363.
https://www.sciencedirect.com/science/article/pii/S0301479718313124.
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
The economic potential for battery second life could help to further decrease the upfront
costs of electric vehicle batteries by increasing the value of a used electric vehicle. In a
stationary setting, distributed energy storage resources can provide a range of services both
behind and in-front of the electricity meter. For private customers, battery energy storage
can provide back-up power and decrease electricity costs. For utility customers, storage can
provide a range of services including frequency regulation, deferral of investments in
transmission and distribution infrastructure, and energy arbitrage.
2. Battery Recycling
Recycling is the process of taking packs and reducing them to their base materials. Lithium-
ion battery recycling can be broken down into three general stages:
· Pre-treatment, which primarily consists of mechanical shredding and sorting out plastic
fluff, metal-enriched liquid, and metal solids.
162
· Secondary treatment, which involves separating the cathode from the aluminum
collector foil with a chemical solvent.
· Recovery of the cathode materials through hydrometallurgy, which relies on chemical
leaching, or pyrometallurgy, which relies on high temperatures to enable electrolytic
reaction processes.
There are a limited number of large-scale facilities that recycle lithium batteries today and the
technological approaches can be broken down into three general categories:
Pyrometallurgical Recycling
A smelting process is used to heat the batteries to high temperatures, driving off organics
like separators and plastics as waste gases. Pyrometallurgical plants (i.e., smelters) use high
temperatures (~1500°C) to burn off impurities and recover cobalt, nickel, and copper. The
remaining nickel, cobalt, and copper is recovered in a mixed alloy that can be further
separated using hydrometallurgy. The lithium and aluminum remain in a slag by-product. It is
not economically viable to separate out the lithium via hydrometallurgy, so instead, it is
typically sold for use as an additive in concrete or as an insulation material.
163
There is no
ability to recycle the electrolyte or plastics. Pyrometallurgy is energy intensive and costly and
can potentially emit hazardous gases. However, it has been an economically viable way to
recover cobalt and nickel from batteries with high contents of one or both metals.
Hydrometallurgical Recycling
This process dissolves battery constituents or alloys in acid to produce metal sulfates. It can
be used to recover metals after a mechanical process or from the pyrometallurgy alloys or
162
Zhang, Xiaoxiao, Li Li, Ersha Fan, Qing Xue, Yifan Bian, Feng Wu, and Renjie Chen. 2018. "Toward
sustainable and systematic recycling of spent rechargeable batteries." Chemical Society Reviews, October 7:
7183-7496.
163
Engel, Jan, and Gretchen A. Macht. 2016. “Comparison of Lithium-Ion Recycling Processes.Conference
Proceedings, Kingston, RI: The University of Rhode Island.
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
slag by-products with high recycling efficiencies.
164
Hydrometallurgy requires less energy, but
because of the cost of chemicals and purification, the process is complex and costly. It also
generates a lot of wastewater.
165
Hydrometallurgical recovery methods focus on leaching,
removal of impurities, and separation. Leaching can occur through both solvent extraction
and chemical precipitation to recover lithium, nickel, and cobalt.
Hydro- and pyro- metallurgical recycling are commercially available technologies. Both can
recover lithium-containing materials, but further processing is needed to get them to a
usable form. This involves refining the constituent material to a sufficiently high quality for
use in a new cathode as done with primary mined products, as well as the synthesis of the
cathode compound or alloy.
Direct Recycling
The goal of direct recycling is to recover electrode materials in a suitable condition to be
used as direct inputs in battery production, without separating each individual material.
Direct recycling resynthesizes cathode materials through various chemical processes, yielding
an alloy with similar if not identical properties to the new cathode material.
The benefit of recovering usable cathode material is that it preserves the embedded energy
and economic investment by avoiding the need to resynthesize cathode materials (e.g.,
lithium, nickel, cobalt, or manganese) into a cathode compound. Unlike the other two
processes, it does not break down the crystalline structure of the cathode into its constituent
elements, but instead allows a degraded cathode to be regenerated through a process
called cathode relithiation. Typically, direct recycling involves physical separation of the
cathode material from other components, washing of the binder, thermal treatment, lithium
replenishment of the active material, and a final thermal treatment step. This is the least
energy intensive of the processes but does not work with mixed battery chemistries and is
furthest from full commercialization.
166
Additional information on battery reuse and recycling can be found in Appendix E, including
details on ongoing state actions and draft battery recycling recommendations for the
Legislature as required under Assembly Bill 2832.
167 168
164
Larouche, François et al. 2020. "Progress and Status of Hydrometallurgical and Direct Recycling of Li-Ion
Batteries and Beyond." Materials 13, no. 3: 801. https://doi.org/10.3390/ma13030801.
165
Pavón, Sandra, Doreen Kaiser, Robert Mende, and Martin Bertau. 2021. "The COOL-Process—A Selective
Approach for Recycling Lithium Batteries" Metals 11, no. 2: 259. https://doi.org/10.3390/met11020259
166
ReCell Center, U.S. Department of Energy Office of Science, UChicago Argonne LLC. n.d. Direct Cathode
Recycling. Accessed March 1, 2022. https://recellcenter.org/research/direct-cathode-recycling/.
167
Assembly Bill 2832 (Dahle, 2018) codified in Article 3 (commencing with § 42450.5) of Chapter 8 of Part 3 of
Division 30 of the Public Resources Code, required the Secretary of the California Environmental Protection
Agency (CalEPA) to convene a Lithium-Ion Car Battery Recycling Advisory Group to review and advise the
Legislature on policies pertaining to the recovery and recycling of lithium-ion batteries sold with motor vehicles
in the state. The Advisory Group is to submit policy recommendations to the California Legislature, on or before
April 1, 2022, aimed at ensuring that as close to 100 percent as possible of lithium-ion vehicle batteries in the
State are reused or recycled at end-of-life in a safe and cost-effective manner.
168
Kendall, Slattery, and Dunn, Lithium-ion Car Battery Recycling Advisory Group
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
IV. Battery Assumptions and Costs
A. BEV and PHEV Efficiencies
Based on battery and energy efficiency trends, CARB staff developed efficiency assumptions
used in cost modeling for ACC II. Usable battery energy (UBE) is derived from the assigned
range and projected efficiency of the technology package for a vehicle class in a specific
model year for BEV and PHEV technologies. Total battery energy (TBE), used to obtain the
battery pack cost, is derived from the UBE with the state-of-charge (SoC) utilization
percentage. CARB staff used data from ANL’s 2021 Light Duty Vehicle Technology report to
develop charge depleting energy efficiencies for the BEV and PHEV technologies.
169
The
2021 ANL report contains the most up-to-date modeling information from U.S. DOE and
ANL which better represents BEV, PHEV, and FCEV attributes than previous reports and is a
consistent comparison of attributes between ZEV types. Staff updated BEV and PHEV charge
depleting efficiencies based on the more recent 2021 ANL report for this final analysis. Staff
used the data from the report with the following guidelines:
1. Low vs high technology case - The report presented a low technology and a high
technology pathway. CARB staff found that 2021 ANL Autonomie report’s low
technology pathway best matched expected vehicle attributes due to its less
aggressive light weighting, aero efficiency gains, and tire rolling resistance reductions
over time. CARB staff view this as a more likely scenario in the timeframe of the
regulation.
2. Base vs. premium model - The report also presented a “base” version, and a higher
performing “premium” version of each vehicle type. Except where towing packages
are generated for the medium SUV, large SUV, and pickup, the report’s “base” vehicle
attributes are used. This is to preserve performance neutrality with the ICEVs in the
fleet today that the BEVs are replacing.
3. Lab year - Best in class BEVs available by vehicle manufacturers today were compared
to the modeled vehicle attributes from the report. ANL lists their modeled vehicle
packages in what they call a “lab year” instead of a model year. Inspection of the ANL
report’s outputs showed that ANL 2015 “lab year” vehicles align with the initial model
year ZEV attributes projected by CARB staff.
Taking this into account, a summary of the modifications to the charge depleting efficiencies
used from the 2021 ANL Autonomie report are listed in Table 7. These changes lead to a
change in costs for these technology packages.
169
Islam et al., A Detailed Vehicle Modeling & Simulation
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
Table 7. BEV and PHEV Efficiency Modifications to 2021 ANL Autonomie Report Data for
Use in Development of CARB Staff Projected Battery Pack Sizes
ANL
Lab
Year
CARB
Model
Year
Vehicle Class
BEV300/400s
PHEVs
2015
2025
Small Car
No modification
EREV PHEV50 Charge
Depleting Adjusted Value
(Wh/mi)
Medium and
Large Car
105%
Small SUV
90%
Medium and
Large SUV
95%
Pickup
No modification
Both BEV and PHEV efficiencies are improved 0.5 percent year over year from the initial year
across the 2026 to 2035 model years (MY) that the proposed regulation covers. The SoC
utilization used to calculate total battery energy from usable battery energy is 92.5 percent
for BEVs and 80 percent for PHEVs. The modifications to that data and calculations based on
SoC utilization percentages result in charge depleting efficiencies and total battery energy
for an example vehicle class of small SUVs in Table 8 and Table 9, respectively.
Table 8. Small SUV Charge Depleting Energy Efficiency (Wh/mi)
Technology
2026
2030
2035
BEV300
223
219
214
BEV400
248
243
237
PHEV
323
316
308
Table 9. Small SUV Total Battery Energy (kWh)
Technology
2026
2030
2035
BEV300
72.5
71.0
69.3
BEV400
107.2
105.1
102.5
PHEV
20.2
19.8
19.3
B. BEV and PHEV Battery Assumptions and Costs
Congress, in 2007, requested the National Academies of Sciences, Engineering, Medicine
(NAS), a panel of academics, scientists, engineers, and other experts in the field conduct a
periodic review of fuel economy standards. More recently, NHTSA contracted the NAS to
form the Committee on Assessment of Technologies for Improving Fuel Economy of Light-
Duty VehiclesPhase 3 to update on requested technologies, consumer behavior, and policy
analysis for vehicle efficiency technologies for 2025-2035. The Committee released a report
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
entitled Assessment of Technologies for Improving Light-Duty Vehicle Fuel Economy 2025-
2035 in 2021.
170
Part of the report focuses on battery technology, particularly those that would be used in
BEVs. The Committee extensively researched the automotive battery landscape and
projected battery costs to fall between $90-$115/kWh by 2025 and further decrease to $65-
$80/kWh by 2030.
They credit falling prices to improved and simplified battery cell and pack
designs, lower raw material input costs, adjustments to cathode technologies, and new
manufacturing techniques in addition to increasing production volumes.
171 172
The Committee
also notes that for costs to go below roughly $60/kWh, new advanced lithium-ion battery
technologies like silicon anodes, lithium anodes, or lithium-sulfur based chemistry would
need to become commercially viable at high production volumes and with the ability to meet
the durability requirements of the light-duty automotive sector.
Other recent findings also indicate a continuing trend of declining battery costs. Bloomberg
New Energy Finance (BloombergNEF) industry surveys indicate that prices of automotive
battery packs were $137/kWh by the end of 2020, representing a nearly 90 percent decline
from 2010.
173
Additional analyses from BloombergNEF project that average battery pack
costs for the transportation sector may reach as low as $101/kWh by 2023 and $58/kWh by
2030, but those analyses include less energy dense batteries used in the heavy-duty sector,
where packaging volume or range may not be some of the primary design criteria as is the
case for light-duty vehicles.
174
Taking all this information into consideration, staff developed battery pack costs for this
regulatory analysis of $95.3/kWh in 2026 and $72.5/kWh in 2030 for BEVs using the midpoint
presented in the NAS study due to the robustness and transparency of the analysis.
175
CARB
staff estimates that cost reduction rates will slow somewhat after 2030 and applied a lower 5
percent year-over-year reduction from 2030 to 2035 to get the resulting pack costs shown in
Figure 8. As discussed, future advancements in new battery chemistries are showing promise,
but these are not counted on for staff’s battery pack cost estimates. If future battery
advancements are realized, they could deliver up to a 50 percent reduction in battery pack
weight. That potential significant reduction in battery pack weight would further reduce
vehicle weight and increase overall efficiency, decreasing the energy required for a targeted
range or increasing range while maintaining the same battery energy capacity.
Battery cells and packs for PHEVs have traditionally differed from those used in BEVs. The
energy requirements for BEVs and PHEVs dictate different battery pack configurations,
170
National Academies of Sciences, Engineering, and Medicine, Assessment of Technologies
171
BloombergNEF. 2020. Battery Pack Prices Cited Below $100/kWh for the First Time in 2020, While Market
Average Sits at $137/kWh. December 16. Accessed March 1, 2022. https://about.bnef.com/blog/battery-pack-
prices-cited-below-100-kwh-for-the-first-time-in-2020-while-market-average-sits-at-137-kwh/.
172
National Academies of Sciences, Engineering, and Medicine, Assessment of Technologies
173
BloombergNEF, Battery Pack Prices
174
BloombergNEF, Battery Pack Prices
175
Battery pack costs are representative of the direct manufacturing costs for each ZEV technology’s battery
pack for each year of the regulation and are inclusive of everything contained within that pack. The pack
includes thermal systems and hook ups, battery management system components contained within the pack,
and connectors and wiring internal to the pack.
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
physical dimensions, and energy contents for the two technologies. There are some common
components, like the battery management system, safety disconnects, power wiring, and
thermal management systems that could be shared between the two types of vehicles.
However, the battery packs between the two vehicle technologies will be different in many
ways including the battery cells and the count and configuration of the battery cells due to
the electric topology. PHEVs, generally, use different battery cells than BEVs due to the
power requirements compared to the battery pack size – BEVs require high specific energy
from a battery while PHEVs require a balance of energy and power. Not only are the physical
cell designs and energy capacities different, the variation of lithium-ion chemistry for each
vehicle technology may also be different. Some vehicle manufacturers may use the same cell
in the future if battery manufacturers are able to meet specific targets; however, such
solutions appear to be less common, requiring compromise on the optimization of the cell to
one or both applications.
For the SRIA, CARB staff used a 40 percent cost markup for battery costs in PHEVs compared
to BEVs based on analysis in the 2017 Total Battery Consulting xEV Insider Report.
Stakeholders commented the cost premium was too high and not representative of future
PHEV battery costs. The proposed regulations require a minimum of 50 miles of all-electric
range which necessitates larger energy capacity battery packs than the PHEVs required for
the analysis completed in the 2017 xEV Insider Report. CARB staff adjusted the cost markup
downward to 30 percent based on the stakeholder feedback. The resulting specific PHEV
battery costs are shown with the BEV battery costs in Figure 88. Total battery costs for small
SUVs in several example years are shown in Table 10.
Figure 8. Battery Pack Costs for BEVs and PHEVs for Model Years 2026 through 2035
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
Table 10. Total Battery Pack Costs for Small SUVs
Technology
2026
2030
2035
BEV300
$6,909
$5,151
$3,887
BEV400
$10,222
$7,620
$5,750
PHEV
$2,499
$1,863
$1,406
C. FCEV Battery Assumptions and Costs
The batteries used for the fuel cell vehicle analysis completed by ANL are like conventional
ICE based HEV batteries, both in energy capacity and power capability and are like what is
currently being used in the industry.
176
For the SRIA, battery costs were derived from ANL’s
2020 report and displayed in terms of cost per unit energy. Similar to the fuel cell stack
power and hydrogen tank capacity, FCEV battery energy capacities are updated to those
from the ANL’s 2021 report’s Fuel Cell 300 technology packages with a few differences.
177
The battery power and sizes are used in the same way other vehicle attributes are being used
such that they are from the low-technology pathway and the base version of the vehicle.
Additionally, the model year the technology is applied to is the lab year it is identified in plus
ten years. Following the SRIA analysis, the specific costs for FCEV batteries were changed
and are now calculated in dollars per kilowatt ($/kW). Staff determined that the cost curves
ten years out from the lab year were not as appropriate to use as was done with the vehicle
attributes. Subsequently, the staff has used the approach of the model year those specific
costs are applied to are the lab year the specific cost is connected to plus five years. For the
lab years that the ANL 2021 report does not model, the battery power and specific costs are
linearly interpolated.
176
Ventricular.org. 2015. “It's Electric - 2015 Review: The Toyota Mirai Hydrogen Fuel Cell Sedan.” October.
Accessed March 4, 2022. https://ventricular.org/ItsElectric/2020/05/07/first-drive-report-2016-toyota-mirai-
hydrogen-fuel-cell-sedan/.
177
Islam, et al., Detailed Vehicle Modeling & Simulation
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
Figure 9. FCEV Battery Pack Specific Costs
D. Fuel Cell System Assumptions and Costs
Fuel cell and hydrogen storage tank system costs for FCEVs were based on cost studies and
methodologies in ANL’s 2021 publication
178
, which was developed in close collaboration with
staff at Strategic Analysis. ANL, in partnership with manufacturers and suppliers, has long
been at the forefront of automotive fuel cell vehicle research. Strategic Analysis is a long-
standing consultant to the United States Department of Energy on FCEV cost projections and
annually publishes authoritative estimates of system costs. Strategic Analysis studies and
ANL's Autonomie model are research efforts funded by U.S. DOE to capture accurate
pictures of current technology status and vetted methods for projecting future
advancements.
FCEVs are very early in their commercial development with significant remaining opportunity
for future cost reduction due to economies of scale and technology advancement. Accurate
estimates of present and future costs for fuel cell and hydrogen storage systems need to
reflect cost reductions that will occur as more FCEVs are produced each year and more
advanced manufacturing processes and FCEV technology is developed. Strategic Analysis
cost models account for cost reductions due to production volume, while past ANL reports
accounted for cost reductions due to technology advancement over time.
In the 2021 analysis, ANL adjusted their cost estimation methodology by integrating the
production volume effects of Strategic Analysis’ cost models and assuming growth from low
production volume in the near-term to high production volume in the long-term.
Communications between CARB, ANL, and U.S. DOE staff confirmed that the revised cost
178
Islam, et al., Detailed Vehicle Modeling & Simulation
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
estimates assumed annual production rates of 10,000, 50,000, and 100,000 vehicles per year
in model years 2025, 2030, and 2035, respectively
179
. This assumed trend in production
volume is similar to CARB’s estimates published in the draft SRIA.
180
The comprehensiveness
of the revised ANL method and agreement with CARB’s prior analysis allowed for a simpler
process to utilize vehicle specification and cost model results reported by ANL.
ANL’s analysis implements the Autonomie
vehicle modeling platform and provides estimates
of vehicle design, fuel efficiency, and cost of several types of light-duty vehicles in future
years. In addition to updated cost models, the analysis for the 2021 report accounts for
updated electric motor performance, high-durability fuel cells (8,000-hour useful lifetime),
and other advancements made in the past year. The model assumes certain vehicle
performance specifications and determines the set of component specifications (such as fuel
cell system power, motor power, battery power and energy capacity, etc.) that allow the
vehicle to achieve the desired performance. Component weight is a key factor in identifying
the set of parameters for each vehicle.
CARB’s cost estimation for FCEVs relied heavily on the ANL report data with some minor
adjustments. The average ratio between motor power and vehicle curb weight for all vehicle
types other than pickups (which did not need this adjustment, considering they are typically
designed to have higher power for towing applications), was observed to be roughly
75kW/kg. To maintain performance neutrality between the vehicle types (other than pickups),
CARB adjusted motor power for FCEVs to the average between those vehicle types to 75
kW/kg. In the Autonomie evaluation process, the fuel cell stack is sized to provide sufficient
power for the motor after accounting for the battery power. The battery is itself sized for
performance considerations, such as the time to accelerate from 0 to 60 mph. CARB
therefore adjusted the fuel cell system power by the same amount as the motor power such
that the delta between the motor power prior to the 75 kW/kg adjustment and after the
adjustments was added to the fuel cell stack power. In addition, based on the observed
vehicle weight trends in the Autonomie results, CARB assumed all vehicle specifications for a
given lab year (the basis of vehicle technology in Autonomie results) should be applied to
vehicles of a model year 10 years later. All other component specifications were taken
directly from the Autonomie results reported by ANL.
For most vehicle types (small car, medium car, etc.), the vehicle component specifications
were based on the Autonomie results for Base model vehicles. The only exceptions were for
pickup trucks and medium SUVs that include towing capability. CARB assumed that all pickup
trucks would include towing capability, and based FCEV pickup specifications on Autonomie
results for Premium pickups. Premium pickups are modeled in Autonomie to have more
power than their Base model counterparts, as expected for vehicles with towing capabilities.
Similar results are observed for Premium medium SUVs so the same assumption was made
for these vehicles. Table 11 shows the resulting fuel cell system power by vehicle class and
179
Rustagi, Neha. ‘Assumptions for 2021 Autonomie Energy Consumption Study’. Email, 2022.
180
California Air Resources Board. 2022. Advanced Clean Cars II Proposed Amendments to the Low Emission,
Zero Emission, and Associated Vehicle Regulations Standardized Regulatory Impact Assessment (SRIA). January
26. Accessed March 15, 2022. https://dof.ca.gov/wp-
content/uploads/Forecasting/Economics/Documents/ACCII-SRIA.pdf
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
model year. Table 12 shows the amount of hydrogen stored in the hydrogen storage system
by vehicle class and model year.
Table 11: Fuel Cell System power (kW)
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
Small Car
74
73
72
71
70
70
70
70
70
70
Med Car
81
79
77
74
72
72
72
72
72
73
Small SUV
92
90
88
87
85
84
84
83
83
83
Med SUV
97
95
93
90
88
87
87
87
86
86
Pickup
168
164
160
155
151
151
151
150
150
150
Table 12: Hydrogen Fuel Tank Size (kg)
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
Small Car
3.9
3.8
3.7
3.6
3.6
3.6
3.6
3.6
3.6
3.5
Med Car
4.2
4.1
4.0
3.9
3.8
3.8
3.8
3.8
3.8
3.8
Small SUV
5.1
5.0
4.8
4.7
4.6
4.6
4.6
4.6
4.6
4.5
Med SUV
5.4
5.2
5.1
5.0
4.8
4.8
4.8
4.8
4.8
4.8
Pickup
7.1
6.9
6.7
6.5
6.3
6.3
6.2
6.2
6.2
6.2
To estimate the costs of the fuel cell and hydrogen storage systems, CARB then applied the
cost estimates provided by the ANL report’s high technology advancement case. CARB
assumed that the costs per kilowatt of fuel cell power and per kilogram of hydrogen stored
on-board followed the same trajectory recommended in the Autonomie results. That is, a
difference of 5 years was assumed between lab and model years in terms of costs. This was
necessary in order to maintain the proper growth rate in annual production volumes. For the
fuel cell system, this resulted in costs of $111/kW, $66/kW, and $52/kW in model years 2025,
2030, and 2035, respectively. For the hydrogen storage system, the costs are modeled with a
constant portion and variable portion that scales with the amount of hydrogen stored. Table
13 shows the variation by model year in the coefficients for each portion of the hydrogen
storage system cost model. Linear interpolation was used for all model years 2026-2029 and
2031-2035. Full fuel cell system and hydrogen storage system costs are shown by vehicle
class and model year in Table 14 and Table 15, respectively.
Table 13: Hydrogen Storage System Cost Model Coefficients
Model
Year
Constant Portion:
Hydrogen Storage
System Cost ($)
Variable Portion:
Hydrogen Storage
System Cost ($/kg)
2025
1946
352
2030
1849
236
2035
981
191
Table 14: Fuel Cell System Cost ($/vehicle)
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
Small Car
7,543
6,790
6.053
5,334
4,632
4,431
4,231
4,031
3,832
3,633
Med Car
8,241
7,318
6,433
5,586
4,776
4,569
4,362
4,156
3,950
3,744
Small SUV
9,334
8,361
7,417
6,502
5,616
5,340
5,068
4,799
4,533
4,271
Med SUV
9,936
8,832
7,771
6,755
5,783
5,515
5,250
4,987
4,725
4,466
Pickup
17,166
15,254
13,418
11,659
9,977
9,536
9,097
8,659
8,223
7,788
Table 15: Hydrogen Tank Cost ($/vehicle)
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
Small Car
3,207
3,078
2,949
2,819
2,690
2,484
2,279
2,073
1,867
1,662
Med Car
3,317
3,174
3,032
2,889
2,747
2,539
2,331
2,123
1,915
1,708
Small SUV
3,602
3,435
3,268
3,101
2,945
2,720
2,505
2,290
2,075
1,860
Med SUV
3,699
3,520
3,342
3,163
2,984
2,768
2,551
2,334
2,117
1,900
Pickup
4,264
4,029
3,795
3,560
3,326
3,096
2,866
2,636
2,406
2,176
V. Non-Battery Component Assumptions and Costs
Understanding both battery and non-battery technology is critical to understanding the
status of PEVs and where the technology may be headed. Key technologies include battery
cells and packs, battery management systems, drive motors, inverters, on-board chargers
(OBC), direct current to direct current (DC-DC) converters, PEV specific HVAC components,
and high voltage wiring and interconnects. While batteries account for the greatest portion
of vehicle cost, non-battery components are essential to the operation of the vehicles.
In understanding economies of scale and applicability of advancements in individual
technologies, it is important to note where PHEVs and ZEVs use the same or different
components. Additionally, while PHEV and ZEV powertrains use similar components, vehicle
integration layouts can be quite different. ZEVs on the market use single speed gear
reduction transmissions to transmit electric machine power to the wheels. The designs tend
to be relatively simple and compact compared to PHEVs. ZEVs locate the combined electric
motor and gearbox at either the front or rear axle, or in the case of the dual-motor ZEVs at
both axles. PHEVs, in contrast, come in a variety of different formats and configurations.
Some have two electric motors that are packaged in a transaxle assembly designed for a
front-wheel drive vehicle, while other PHEV systems being utilized include electric motors
located between the engine and transmission, at the axle, or at a combination of these
locations. These basic differences in layout influence the types and designs of motors,
transaxles, battery cells, and power electronics that are used in each technology.
Additionally, PHEVs typically have a lower power on-board charger to support lower energy
capacity battery packs.
There are many categories of non-battery costs that contribute to the ZEV and PHEV
technology incremental costs. Non-battery component costs are applied to each ZEV and
PHEV technology combination either as a dynamic cost based on the motor power or as a
fixed cost. The non-battery costs were derived from extensive third- party vehicle teardown
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
studies of many different types of hybrid electric vehicles, PHEVs, and BEVs. Those studies
include:
· CARB contracted Ricardo hybrid electric vehicle component teardowns
181
· Munro Model 3 teardown
· Munro i3, Bolt, and Model 3 comparison
· UBS Chevrolet Bolt teardown
182
· Munro 12 Electric Motor comparison
· Munro 6 Inverter comparison
· Munro Model Y teardown
Those studies showed that the leading manufacturers on both cost and performance were
taking a very integrated approach to designing and manufacturing their non-battery
components. This led to three main areas that needed to be accounted for in the CARB staff
analysis:
· The electric motor and housing
· A penthouse or housing with heavily integrated power electronics, many of which
share the same circuit boards
· The rest of the supporting items like high voltage cabling and cooling components
From that approach, the non-battery components were broken down into specific
component sets and cost curves and/or fixed costs were developed using the best-in-class
costs from the tear down studies listed above.
Motor Power
The motor of an electric vehicle converts electrical energy into mechanical energy and power
on the axle. This mechanical power is typically defined in kilowatts, here referred to as
electric motor power.
In most cases, both ZEVs and PHEVs use permanent magnet electric machines. While most
electric machines in ZEVs and PHEVs are of the permanent magnet variety, they generally
differ in design for many reasons. ZEV electric machines are responsible for providing all of
the motive power for the vehicle. PHEV systems can be split into two different groups:
blended and non-blended. Blended PHEVs do not have an electric drive powertrain that can
meet all the motive power requirements of the vehicle on electric power only. On the other
hand, non-blended PHEVs are capable of driving on electric power over the entire range of
driving conditions. Non-blended PHEVs require an electric machine(s) that can deliver power
levels roughly equal to that of the ICE.
181
Ricardo Strategic Consulting, Munro & Associates Inc., and ZMassociates Environmental Corp. 2017.
Advanced Strong Hybrid and Plug-In Hybrid Engineering Evaluation and Cost Analysis - CARB Agreement
15CAR018. Teardown Cost Analysis, California Air Resources Board.
https://ww2.arb.ca.gov/sites/default/files/2020-
04/advanced_strong_hybrid_and_plug_in_hybrid_engineering_evaluation_and_cost_analysis_ac.pdf.
182
UBS. 2017. UBS Evidence Lab Electric Car Teardown - Disruption Ahead? Vehicle Teardown Costing, New
York: UBS. https://neo.ubs.com/shared/d1wkuDlEbYPjF/.
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
PHEV electric motors are a little less powerful than their BEV counterparts. They are assumed
to be capable of all-electric operation throughout their charge-depleting mode, but do not
assume full performance capability while in charge depleting mode relative to charge-
sustaining mode.
With current power densities of electric machines and the size of single gear reduction
transaxles, ZEV electric machines can be relatively powerful. PHEVs are generally more
limited by the space constraints available in a vehicle that also has a gasoline engine and
conventional transmission. This leads to differences in sizing and power densities of the
motors. Additionally, cooling electric machines in a PHEV when they are packaged in a
transaxle that is connected to an ICE can be more complicated due to the heat produced by
the ICE.
Electric motor sizing for both ZEVs and PHEVs better reflect what industry is doing.
Manufacturers have been able to realize more accelerative performance out of lower power
electric motors than what was expected a decade ago. Due to the electric motors ability to
make full torque off idle, electric motors with lower nominal power ratings can achieve
equivalent vehicle performance.
CARB staff used data from ANL’s 2021 Light Duty Vehicle Technology report to develop the
motor sizes for the ZEV and PHEV technologies.
183
The 2021 ANL report contains the most
up-to-date modeling information from U.S. DOE and ANL which better represents BEV,
PHEV, and FCEV attributes than previous reports and is a consistent comparison of attributes
between ZEV types. Staff updated BEV, PHEV, and FCEV sizing based on the more recent
2021 ANL report for this final analysis with the guidelines for the cases used described in
Section IV.
Taking this into account, a summary of the modifications to the eMotor power used from the
2021 ANL Autonomie report are listed in Table 16. These changes lead to a change in costs
for these technology packages.
Table 16. Modifications to Electric Motor Power from 2021 Autonomie Report Data
ANL
Lab
Year
CARB
Model
Year
Vehicle Class
eMotor Power Modification
BEV300/400s
FCEVs
PHEVs
2015
2025
Small Car
Rescaled to
75W/kg
Rescaled to
75W/kg
Average EREV
PHEV50
eMotor Power
to Weight
(66W/kg)
Applied to Par
PHEV50 Turbo
Vehicle Mass
Medium and
Large Car
Small SUV
Medium and
Large SUV
Pickup
No
modification
No
modification
183
Islam, et al., Detailed Vehicle Modeling & Simulation
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
CARB staff project that technological improvements will result in lower overall vehicle mass,
like improved batteries. To account for that projection, BEV and PHEV motor powers are
improved 0.5 percent year over year from the initial year across the 2026 to 2035MYs that
the proposed regulation covers. FCEV motor powers are taken in the reference model years
from the 2021 Autonomie Report (2015, 2020, 2025 lab years for 2025, 2030, and 2035
model years, respectively) with the model years between those points calculated using linear
interpolation.
The resultant motor power for Small SUVs in several example years for BEVs, FCEVs, and
PHEVs are shown in Table 17.
Table 17. Electric Motor Power for Small SUVs
Technology
2026MY
2030MY
2035MY
BEV300
138
135
132
BEV400
155
152
148
PHEV
136
134
130
FCEV
124
115
112
Non-Battery Cost Categories
The specific component sets are listed here:
· Traction motors, inclusive of the rotor and stator, are the primary motor for all ZEV
applications. The traction motor costs consist of both the permanent magnet
synchronous machine (PMSM) and the rest of the motor components, such as the case,
mounts, and resolver. The PMSM is assumed to be $3.9/kW eMotor Power, whereas
the other components are assumed as a 0.1 multiplier based on the traction motor
cost such that the total motor cost inclusive of those other components is 1.1 times
the $3.9/kW eMotor Power cost. These additional components are only applicable to
BEVs and FCEVs since PHEV have transmission-integrated eMotors.
· Induction motors are used for second motors on those vehicles with an electric all-
wheel-drive (eAWD) package, except for truck-based PHEVs. Induction motor costs
are $2.4/kW eMotor Power, and the rest of the motor components (i.e., case, mounts,
and resolver) are assumed as a 1.3 multiplier to the traction motor cost such that the
total motor cost inclusive of those other components is 1.3 times the $2.4/kW eMotor
Power cost. The induction motor costs are only applicable for eAWD packages on
BEVs, FCEVs, and car-based PHEVs.
· Single-speed gearbox costs include the gears and housing and are applicable to all
BEVs and FCEVs with a $400/vehicle fixed cost.
· Traction inverters that are integrated in the electric motor housing vary based on the
ZEV technology. The power requirements for PHEVs (particularly blended PHEVs) and
BEVs will require different drive motor inverters due to the differences in electric
power capability of the drivetrains. Designs may be able to be scaled up in power, but
the inverters will likely not be the same component. For BEVs and FCEVs, traction
inverters are assumed to be silicon carbide (SiC) at a cost of $3.8/kW eMotor Power.
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
For primary motors on PHEVs and for second motors in eAWD packages the traction
inverter is assumed to be a conventional silicon based insulated-gate bipolar transistor
(IGBT) type with a cost of $2.5/kW eMotor Power.
· A 32 Amp Level 2 convenience cord set and adapter for BEVs and PHEVs are a
$200/vehicle fixed cost.
· The onboard charger is integrated with other power electronics circuit boards and is
applicable for BEVs and PHEVs. The integrated onboard AC charger power is ratioed
to the useable battery energy of the vehicle such that the vehicle is capable of fully
charging in eight hours with the appropriate electric vehicle supply equipment for
BEVs. (kilowatts of onboard charger power equals the useable battery energy divided
by 8). For PHEVs, the OBC power is based on a four-hour recharge time. The onboard
charger is combined with the DC-DC converter circuitry. The integrated DC-DC
converter is the high voltage to low voltage DC-DC converter that is integrated with
other power electronics. It is based on a three kilo-Watt converter and is the same
across all vehicle technologies – BEVs, PHEVs, and FCEVs. PHEVs and BEVs have
different battery pack energy capacities and often do not use OBCs with the same
power level. Potentially, smaller OBCs could be operated in parallel to provide more
power. This could allow an identical lower power level PHEV OBC component to be
used in a BEV to provide the power level needed but necessarily results in a less
optimized solution. The combined OBC and DCDC power is assumed to be
$39.75/kW and where no OBC is required in the case of FCEVs, the $39.75/kW applies
only to the three kilo-Watt DC-DC converter.
· The integrated onboard DC fast charge (DCFC) circuitry includes components like
contactors, additional controls integrated with other circuitry, and additional parts and
wiring that allows for the vehicle to DC fast charge. The DCFC circuitry costs are only
applicable to BEVs at a $156.28/vehicle fixed cost.
· The power management and distribution include the rest of the penthouse-like
components like the housing and components to connect, integrate, and house the
OBC and DCDC converter, and DCFC circuitry. This applies to all BEVs, PHEVs, and
FCEVs at a fixed cost of $719.22/vehicle.
· High voltage “orange cables” that that carry power between the motor, inverter,
battery, and other components are applicable to all technologies (BEVs, PHEVs, and
FCEVs) at a $187.44/vehicle fixed cost.
· Powertrain cooling costs of $302.22 per electric motor, which include conduits,
pumps, fans, and other components that cool the powertrain are applicable to BEVs
and FCEVs. This cooling is assumed to be integrated PHEVs with existing ICE coolant
loops and electric HVAC controls.
· Second motor high-voltage (HV) cables are the additional orange cabling for when a
second electric motor is added with an eAWD package. This is applicable to eAWD
packages for BEVs, FCEVs, and car-based PHEVs at a $25/vehicle fixed cost.
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
Non-battery components and their costs are summarized in Table 18Table below.
Table 18. Non-battery Component Costs
Nominal component set
Tech Application
$/x
Fixed
cost
Scale by (x)
BEV
PHEV
Car-
Based
PHEV
Truck-
Based
FCEV
Traction motor (PMSM)
Y
Y
Y
Y
$3.90
Motor kW
Traction motor (Induction)
Y
Y
N
Y
$2.40
Motor kW
Rest of motor (PMSM)
Y
N*
N*
Y
1.10
Multiplier
Rest of motor (Induction)
Y
N*
N
Y
1.30
Multiplier
Single-speed gearbox
Y
AWD
N
Y
$413.44
-
Traction inverter (IGBT)
N
Y
N
N
$2.50
Motor kW
Traction inverter (Si-C)
Y
N
N
Y
$3.80
Motor kW
Charging cord and adapters
Y
Y
Y
N
$200.00
-
OBC and DCDC Circuitry
Y
Y
Y
N
$39.75
OBC
kW
+
DCDC
kW
DC Fast Charge Circuitry
Y
N
N
N
$156.28
-
Power Management and
Distribution
Y
Y
Y
Y
$719.22
-
HV "orange cables"
Y
Y
Y
Y
$187.44
-
Powertrain cooling
Y
Y
Y
Y
$302.22
per motor
Second motor HV cables
Y
Y
N
Y
$25.00
Total non-battery costs (not inclusive of fuel cell stack and hydrogen storage tank) for the
different ZEV and PHEV technologies for a small SUV in the identified model years are shown
in Table 19. These are calculated by aggregating the total non-battery costs for each vehicle
class and technology type. Staff projects that the non-battery costs will continue to fall over
time based on the learnings observed in the teardown reports and expected continued
development of relatively young technologies and have applied a 1 percent year-over-year
cost reduction/learning value.
Table 19. Small SUV Non-Battery Costs
Technology
2026MY
2030MY
2035MY
BEV300
$3,537
$3,373
$3,171
BEV400
$3,851
$3,671
$3,451
PHEV
$2,504
$2,382
$2,232
FCEV
184
$2,727
$2,548
$2,393
184
Not inclusive of fuel cell system and hydrogen storage tank costs
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
VI. Delete Costs
A. Background and methodology for standard ICEVs to convert to
ZEVs
Conventional ICEVs utilize many components that are not included on BEVs or FCEVs. To
compare the incremental cost of BEVs and FCEVs, those ICEV component costs must be
deleted.
B. ICE and Transmissions Removal Costs
Both BEVs and FCEVs do not have internal combustion engines (ICE). Developing ZEV
technology cost packages that are incremental to ICE technologies requires accounting for
the ICE cost and removing that from the total ZEV package cost. ICEs remain on PHEV
technologies, so this cost is not removed.
The basis for the ICE removal costs is the 2018 NHTSA CAFE Model technology input costs
and 2021 EPA costs.
185 186
For car-based vehicle classes (small car, medium/large car, and base
medium SUVs), a base 2015 model year inline 4-cylinder dual overhead cam (DOHC) engine
was identified in the 2018 CAFE model technology input file and was used for the removal
cost. For the truck-based SUVs and pickups, a base 2015 model year DOHC V8 was chosen
to be the base engine. Since the NHTSA costs were expressed as a retail price equivalent
(RPE) with a markup of 1.5 to convert from direct manufacturing cost (DMC) to RPE, the
engine cost values were converted to DMC by dividing by 1.5. When averaged with the EPA
work, those cost values came to $3,500 for the 4-cylinder car-based engines and $5,000 for
the truck based 6-cylinder engines. Those costs are meant to be inclusive of all supporting
content including components like fuel tanks, lines, calibration costs, etc.
These 2015 engine values do not have any additional technology and their associated costs
applied to them. As such, additional costs for compliance with current and future regulations
for ICEVs can be layered on.
Multi-speed transmissions are another key component of conventional ICE powertrains. Both
car-based and truck-based transmission removal costs were pulled from 2018 NHTSA CAFE
Model technology input costs and work released by EPA staff.
187 188
Similar to the engine
removal costs, since the NHTSA costs were expressed as a retail price equivalent with a
185
U.S. Department of Transportation National Highway Traffic Safety Administration. 2018. "CAFE Compliance
and Effects Modeling System." NHTSA.gov. Accessed March 2, 2022.
https://www.nhtsa.gov/filebrowser/download/119651. – Specific file: Central
Analysis\input\2018_NPRM_technologies_with_BEV_and_FCV_ref.xlsx
186
Safoutin, Michael. 2017. "Predicting the Future Manufacturing Cost of Batteries for Plug-In Vehicles for the
U.S. EPA 2017-2025 Light-Duty Greenhouse Gas Standards." EPA.gov. October. Accessed March 2, 2022.
https://www.epa.gov/sites/default/files/2018-10/documents/evs30-intl-symp-exhib-safoutin-2017-10.pdf.
187
U.S. Department of Transportation National Highway Traffic Safety Administration. 2018.
188
Safoutin, Michael. 2017.
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
markup of 1.5 to convert from direct manufacturing cost, the transmission cost values were
converted to back to DMC by dividing by 1.5.
For car-based powertrains, the transmission removal is assumed to be $1500 for a base 5-
speed automatic transmission. For truck-based powertrains, a cost of $2000 for a similar base
5-speed automatic transmission (that has costs added to handle the higher loads of the
bigger and more powerful truck-based powertrains) is assumed. These costs are removed for
BEV and FCEV technology combinations where the ICE powertrain is completely removed to
convert to that ZEV technology.
C. Criteria pollutant emissions technology removal costs
Estimated Advanced Clean Cars I LEV III criteria pollutant compliance costs are found in the
2012 ISOR for 2025 model year vehicles.
189
The removal of those costs has been applied to
BEVs and FCEVs and are assumed to be the same fixed cost from model years 2025 to 2035.
The costs were converted to 2021 dollars from 2010 dollars such that the car-based cost is a
fixed $68, and the truck-based cost is a fixed $145.
D. GHG reduction equipment technology removal costs
The U.S. EPA’s Revised 2023 and Later Model Year Light Duty GHG Emissions Standards:
Regulatory Impact Analysis
190
estimates the average cost per vehicle to be $1,000 for the
2026MY. The costs for an average 2020MY vehicle to comply with the 2022MY requirements
is estimated to be $455 which comes to $1455 for the average 2020MY vehicle in the fleet to
comply with the 2026MY regulation. Without the 1.5 RPE markup, the direct manufacturing
cost is $970 which has been rounded up to $1,000 to account for the small improvements in
technology to a 2017MY vehicle to get to the 2020MY standards in U.S. EPA’s cost
estimates.
E. ZEV Assembly Reductions
ZEV assembly cost reductions are cost savings due to a less complex assembly process and
lower associated indirect costs for ZEV technologies. BEVs are assigned a $1600 cost
reduction, as the International Council on Clean Transportation’s work on incremental BEV
costs found two $800 cost reductions for BEV manufacturing in 2025 for vehicle assembly
and associated indirect costs.
191
FCEVs, while more complex than BEVs, are still simpler than
conventional ICEVs and are assigned half the cost reduction that the BEVs get. PHEVs are
189
California Air Resources Board. 2011. Staff Report: Initial Statement of Reasons. Staff Report, Sacramento:
California Air Resources Board. Accessed March 2, 2022.
https://ww2.arb.ca.gov/sites/default/files/barcu/regact/2012/leviiighg2012/levisor.pdf.
190
U.S. EPA Final Rule to Revise Existing National GHG Emissions Standards for Passenger Cars and Light
Trucks Through Model Year 2026. 86 Fed. Reg. 74,434, Dec. 30, 2021. https://www.epa.gov/regulations-
emissions-vehicles-and-engines/final-rule-revise-existing-national-ghg-emissions
191
Lutsey, Nic, and Michael Nicholas. 2019. Update on electric vehicle costs in the United States through 2030.
Working Paper, The International Council on Clean Transportation. https://theicct.org/wp-
content/uploads/2021/06/EV_cost_2020_2030_20190401.pdf.
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
generally very similar to conventional hybrids in many ways, albeit with a larger battery and a
few extra components. PHEVs are assumed to have very little additional assembly costs
comparative to a conventional ICEV and are not assigned extra costs or cost reductions for
assembly.
VII. Rolled Up Incremental Technology Costs
A. Add-on Technologies (Cold, eAWD, Towing)
Acknowledging that the base ZEV and PHEV technologies are not fully representative of
consumers preferences for certain technology attributes, CARB staff developed additional
technology packages that are added on top of the base PHEVs, BEVs, and FCEVs to meet
the needs of consumers in higher market penetration ZEV scenarios.
Table 20. Applicability of Additive ZEV Technologies
Additive Technology
Package
Required for
Fleet Uptake % in
2035 Model Year
Cold Weather
BEVs in colder climates
8.8%
Towing
Larger BEVs with towing capability
4.7%
AWD/4WD
BEVs, FCEVs, and smaller PHEVs
where ICE equivalent had AWD/4WD
32.5%
1. Cold Weather Package
A single vehicle of each ZEV technology in each vehicle size class is not representative of the
diversity of the market. Consumers have preferences to operate their vehicles in various ways
which require additional technology. Passenger cabin heating and cooling needs as well as
battery thermal management systems can have a significant impact on BEV energy efficiency
and range. In response, industry has shifted to heat-pump based heating, ventilation, and air
conditioning (HVAC) systems in place of the more traditional resistive heating. This method
can be more efficient in energy management while satisfying cabin temperature needs. Some
manufacturers have also implemented features such as temperature preconditioning of the
cabin or battery while the vehicle is still plugged in and more targeted cabin heating systems
employing items like heated steering wheels and heated seats to meet driver demands for
comfort without expending as much energy to heat the entire cabin.
About 10 percent of California’s vehicle fleet resides in areas that experience at least one full
24-hour period with temperatures below 35 degrees Fahrenheit. While FCEVs and PHEVs
would not be as adversely affected by the temperature or could quickly refuel if required,
BEVs can be affected by the temperature and cannot be as quickly refueled. To address the
issue, a cold weather technology package was created for BEVs to assist in colder climates
which includes a more efficient heat pump and additional battery heating components. The
BEV cold weather package costs were determined for the 2025MY and the same 1 percent
year over year cost reduction that also applies to other non-battery component costs. The
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
BEV cold weather package cost is shown in Table 21 for all vehicle types in several model
years.
Table 21. BEV 300 and 400 Cold Weather Costs
Technology
2026MY
2030MY
2035MY
Small Car
$396
$380
$362
Medium and Large Car
$495
$475
$452
Small SUV
$495
$475
$452
Medium and Large SUV
$594
$571
$543
Pickup
$594
$571
$543
2. Towing Package
Consumers also sometimes buy larger SUVs and pickups to meet towing needs. Towing
adversely affects range of any vehicle due to the increased mass the powertrain must move,
additional tire rolling resistance of the trailer tires, and reductions in aerodynamic efficiency
to the vehicle from the trailer. This is not necessarily much of an issue with FCEVs and PHEVs
because they can fully refuel as quickly as conventional vehicles and would likely incur no
more refueling stops on a trip than a conventional vehicle. For BEVs, however, even charging
at a very high rate of 350 kilowatts, recharging times are lengthier and cannot restore the full
range quickly. To address consumer’s towing needs with towing-capable BEVs, CARB
modeled additive towing packages for BEVs that increases battery capacity such that the
vehicle can complete a 440-mile one-way trip when towing a load that cuts efficiency in half
and only requires one 20-minute charging stop at 350kW.
Towing-capable ZEVs and PHEVs also receive additional power to account for the heavier
loads the vehicles may carry. The increase in power comes from the 2021 ANL Autonomie
report. While the non-towing versions are derived from the “base” versions of the different
vehicles, towing package medium and large SUVs and pickups use the report’s “premium”
higher powered values for ZEVs and PHEVs. The FCEV towing variants also receive additional
power for their batteries and fuel cell stack as described in Section IV.D. The electric motor
power for those packages is shown in Table 22 and the additive costs of the towing package
are shown in Table 23.
Table 22. eMotor Power for Towing Packages
Vehicle Class
Technology
2026MY
2030MY
2035MY
Medium and
Large SUV
BEV300/400
217
212
207
FCEV
183
166
164
PHEV
170
166
162
Pickup
BEV300/400
273
267
260
FCEV
231
208
204
PHEV
206
202
197
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
Table 23. Towing Package Costs
Vehicle Class
Technology
2026MY
2030MY
2035MY
Medium and
Large SUV
BEV300
$9,519
$7,311
$5,696
BEV400
$7,362
$5,644
$4,389
FCEV
$5,763
$3,659
$3,087
PHEV
$395
$372
$345
Pickup
BEV300
$13,207
$9,997
$7,669
BEV400
$10,572
$7,952
$6,060
FCEV
$2,056
$1,380
$1,250
PHEV
$306
$288
$267
3. Electric All-Wheel-Drive (eAWD)
Lastly, consumers purchase many vehicles with all-wheel or 4-wheel drive. Staff put together
a corresponding electric AWD/4WD package for BEVs, FCEVs, and non-truck-based PHEV
cars and SUVs which add an additional electric motor at the undriven axle and all the
necessary components to go along with it. Larger PHEV SUVs and pickups do not require an
additional motor, because it is assumed that many will utilize a P2 style electric drive system
that will operate through a conventional truck-based 4-wheel drive system. P2 systems place
an electric motor between the ICE and transmission. Because a traditional mechanical
transfer cases that are utilized in truck-based 4WD systems are downline of the transmission,
the electric motor will operate through the transfer case to provide electric power to all four
wheels without the need for an additional electric motor.
ZEVs and PHEVs that require an additional electric motor to provide AWD functionality do
not require all the mechanical components that a conventional ICE-based AWD system does.
To estimate those costs, staff found two currently available vehicles that offer nearly identical
trims in both front-wheel drive (FWD) and AWD variants; the 2021MY Toyota RAV4 and 2021
MY Honda CR-V. Table 24 shows how the MSRP differences between the variants were used
to derive an estimate of the additional component costs required for AWD over FWD
drivetrains. A $500 removal cost is now applied to eAWD systems based on those vehicles’
price differences. Table 24 shows how the DMC for the mechanical AWD components was
calculated which is then used for the mechanical AWD component delete cost for eAWD
packages. The parenthetical values in Table 24 are to be subtracted from the respective cells
above them. The cost for eAWD packages for a small SUV in several example years is shown
in Table 25.
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
Table 24. AWD Mechanical Delete Costs Estimates
Category
2021 Toyota
RAV4 LE
192 193
2022 Honda CR-
V LX
194 195
AWD MSRP
$27,750
$27,900
FWD MSRP
($26,775)
($26,400)
MSRP Delta
$975
$1,500
Without RPE (/1.5)
$650
$1,000
Average
$825
Estimate of Component Costs
Common to AWD and eAWD
196
($325)
DMC Mechanical AWD Components
$500
Table 25. Small SUV eAWD Package Costs
Technology
2026MY
2030MY
2035MY
BEV300
$360
$336
$308
BEV400
$429
$400
$367
PHEV
$355
$331
$303
FCEV
197
$308
$263
$240
192
Toyota Motor Sales, U.S.A., Inc. n.d. Toyota RAV4 Configurator - AWD LE. Accessed March 2, 2022.
https://www.toyota.com/configurator/build/step/model:engine-drive-
transmission/year/2021/series/rav4/model/4432/.
193
Toyota Motor Sales, U.S.A, Inc. n.d. Toyota RAV4 Configurator - FWD LE. Accessed March 2, 2022.
https://www.toyota.com/configurator/build/step/model:engine-drive-
transmission/year/2021/series/rav4/model/4430/.
194
American Honda Motor Co., Inc. n.d. 2022 Honda CR-V 2WD LX. Accessed March 2, 2022.
https://automobiles.honda.com/tools/build-and-price-result?modelid=RW1H2NEW&modelseries=cr-
v&modelyear=2022&extcolorcode=NH-830M&tw-
type=fromvlp%3D1#section=Powertrain&group=Powertrain&view=Exterior&angle=0&state=TTpSVzFIMk5FVy
RFQzpOSC04MzBNJEhDOnVuZGVmaW.
195
American Honda Co., Inc. n.d. 2022 Honda CR-V AWD LX. Accessed March 2, 2022.
https://automobiles.honda.com/tools/build-and-price-result?modelid=RW1H2NEW&modelseries=cr-
v&modelyear=2022&extcolorcode=NH-830M&tw-
type=fromvlp%3D1#section=Powertrain&group=Powertrain&view=Exterior&angle=0&state=TTpSVzJIMk5FVyR
FQzpOSC04MzBNJEhDOnVuZGVmaW.
196
Includes items like half-shafts, different uprights and suspension components to accommodate drive axles,
etc.
197
Not inclusive of fuel cell system and hydrogen storage tank costs.
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
VIII. Direct Manufacturing Cost Results
The total incremental direct manufacturing cost (DMC) for each vehicle class and PHEV and
ZEV type by model year has been calculated in CARB’s ZEV Cost Workbook.
198
Those total
incremental DMCs reflect the cost of those packages relative to a compliant, conventional
ICE vehicle in each model year. The incremental DMC is the sum of the calculated non-
battery DMCs, battery DMCs, fuel cell system DMCs for FCEVs, eAWD, towing, or cold
weather package DMCs where applicable, minus the delete DMCs for the ICE, compliant
emissions systems, and ZEV assembly reductions. The rolled-up DMCs for small SUV ZEV and
PHEV packages without the delete DMCs are shown in Table 26. The delete DMCs for those
small SUV packages are shown in Table 27, and the incremental DMCs are show in Table 28.
Parenthetical values in the following tables are to be considered negative.
Table 26. Small SUV ZEV and PHEV Non-Incremental Technology DMC
Technology
2026MY
2030MY
2035MY
BEV300
$10,447
$8,524
$7,058
BEV400
$14,072
$11,291
$9,201
FCEV
$16,423
$11,797
$9,115
PHEV
$5,002
$4,244
$3,638
Table 27. Small SUV ZEV and PHEV Delete DMC
Technology
2026MY
2030MY
2035MY
BEV300
($7,668)
($7,668)
($7,668)
BEV400
($7,668)
($7,668)
($7,668)
FCEV
($6,868)
($6,868)
($6,868)
PHEV
($1,000)
($1,000)
($1,000)
Table 28. Small SUV Incremental DMC
Technology
2026MY
2030MY
2035MY
BEV300
$2,779
$856
($610)
BEV400
$6,404
$3,623
$1,533
FCEV
$9,555
$4,929
$2,247
PHEV
$4,002
$3,244
$2,638
The BEV300 package on small SUVs reaches cost parity with a conventional ICE vehicle in the
2033 model year and has the lowest incremental DMC. In the early years, the PHEV package
has the second lowest incremental DMC, but both the FCEV and BEV400 packages achieve
lower incremental DMC than PHEVs in the 2035 and 2032 model years, respectively.
198
California Air Resources Board. 2022. ZEV Cost Modeling Workbook. March. Accessed March 28, 2022.
https://ww2.arb.ca.gov/sites/default/files/2022-03/zev_cost_modeling_workbook_update_march2022_0.xlsx
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
The following tables summarize the incremental cost incurred by manufacturers to convert
gasoline vehicles to PHEV, BEV300, FCEV, and BEV400 vehicles, respectively.
Table 29. PHEV Incremental Cost by MY, Vehicle Class, Type, Drivetrain, and Towing
Capability ($)
Vehicle
Class
AWD /
4WD
Present
Towing
Capable
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
SmallCar
No
No
3,121
2,949
2,787
2,636
2,519
2,413
2,312
2,215
2,123
2,034
SmallCar
Yes
No
3,328
3,152
2,987
2,832
2,711
2,601
2,497
2,396
2,300
2,208
MedCar
No
No
3,372
3,189
3,017
2,856
2,731
2,619
2,511
2,408
2,310
2,215
MedCar
Yes
No
3,637
3,449
3,273
3,107
2,978
2,861
2,749
2,642
2,539
2,440
SmallSUV
No
No
4,002
3,785
3,582
3,392
3,244
3,112
2,986
2,865
2,749
2,638
SmallSUV
Yes
No
4,357
4,134
3,925
3,729
3,575
3,437
3,305
3,179
3,057
2,941
MedSUV
No
No
4,305
4,070
3,851
3,646
3,487
3,345
3,209
3,079
2,955
2,836
MedSUV
No
Yes
4,699
4,459
4,234
4,023
3,859
3,711
3,570
3,434
3,305
3,180
MedSUV
Yes
No
4,305
4,070
3,851
3,646
3,487
3,345
3,209
3,079
2,955
2,836
MedSUV
Yes
Yes
4,699
4,459
4,234
4,023
3,859
3,711
3,570
3,434
3,305
3,180
Pickup
No
No
5,340
5,052
4,782
4,530
4,335
4,161
3,995
3,836
3,684
3,539
Pickup
No
Yes
5,646
5,353
5,079
4,823
4,624
4,445
4,275
4,112
3,956
3,806
Pickup
Yes
No
5,340
5,052
4,782
4,530
4,335
4,161
3,995
3,836
3,684
3,539
Pickup
Yes
Yes
5,646
5,353
5,079
4,823
4,624
4,445
4,275
4,112
3,956
3,806
Table 30. BEV300 Incremental Cost by Model Year, Vehicle Class, Type, Drivetrain, and
Towing Capability ($)
Vehicle
Class
AWD /
4WD
Present
Towing
Capable
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
SmallCar
No
No
2,028
1,512
1,031
584
246
(53)
(338)
(608)
(866)
(1,112)
SmallCar
Yes
No
2,276
1,755
1,270
819
476
173
(116)
(391)
(652)
(902)
MedCar
No
No
2,358
1,824
1,327
865
515
206
(88)
(368)
(635)
(889)
MedCar
Yes
No
2,660
2,121
1,619
1,151
797
482
183
(102)
(373)
(632)
SmallSUV
No
No
2,779
2,222
1,703
1,221
856
533
226
(66)
(345)
(610)
SmallSUV
Yes
No
3,139
2,576
2,051
1,563
1,192
863
551
253
(31)
(302)
MedSUV
No
No
2,314
1,647
1,027
449
15
(369)
(734)
(1,081)
(1,412)
(1,726)
MedSUV
No
Yes
11,833
10,521
9,302
8,171
7,326
6,583
5,878
5,208
4,573
3,970
MedSUV
Yes
No
2,717
2,043
1,416
832
391
1
(371)
(724)
(1,061)
(1,381)
MedSUV
Yes
Yes
12,236
10,917
9,692
8,554
7,702
6,953
6,241
5,566
4,924
4,315
Pickup
No
No
5,348
4,498
3,708
2,972
2,419
1,931
1,467
1,026
606
207
Pickup
No
Yes
18,554
16,765
15,104
13,563
12,416
11,409
10,455
9,550
8,691
7,876
Pickup
Yes
No
6,042
5,181
4,379
3,634
3,070
2,571
2,097
1,645
1,215
806
Pickup
Yes
Yes
19,249
17,448
15,776
14,224
13,066
12,049
11,084
10,169
9,300
8,475
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
Table 31. FCEV Incremental Cost by MY, Vehicle Class, Type, Drivetrain, and Towing
Capability ($)
Vehicle
Class
AWD /
4WD
Present
Towing
Capable
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
SmallCar
No
No
6,965
6,045
5,143
4,258
3,389
2,949
2,508
2,068
1,629
1,190
SmallCar
Yes
No
7,168
6,244
5,337
4,447
3,574
3,132
2,691
2,250
1,809
1,369
MedCar
No
No
8,003
6,875
5,786
4,735
3,723
3,273
2,823
2,374
1,925
1,477
MedCar
Yes
No
8,261
7,124
6,025
4,964
3,942
3,491
3,041
2,591
2,142
1,693
SmallSUV
No
No
9,555
8,354
7,183
6,041
4,929
4,385
3,845
3,308
2,776
2,247
SmallSUV
Yes
No
9,866
8,657
7,477
6,327
5,205
4,659
4,117
3,578
3,044
2,513
MedSUV
No
No
12,340
10,314
8,354
6,461
4,635
3,851
3,069
2,290
1,514
741
MedSUV
No
Yes
20,985
18,127
15,365
12,697
10,125
9,159
8,212
7,265
6,318
5,372
MedSUV
Yes
No
12,839
10,790
8,808
6,893
5,046
4,255
3,467
2,683
1,901
1,123
MedSUV
Yes
Yes
21,483
18,603
15,819
13,129
10,535
9,564
8,611
7,658
6,705
5,753
Pickup
No
No
25,277
21,922
18,683
15,562
12,557
11,455
10,355
9,258
8,165
7,075
Pickup
No
Yes
28,362
24,751
21,258
17,883
14,627
13,461
12,333
11,205
10,077
8,950
Pickup
Yes
No
26,234
22,841
19,566
16,408
13,368
12,252
11,140
10,031
8,924
7,822
Pickup
Yes
Yes
29,319
25,670
22,140
18,730
15,438
14,259
13,118
11,977
10,837
9,697
Table 32. BEV400 Incremental Cost by MY, Vehicle Class, Type, Drivetrain, and Towing
Capability ($)
Vehicle
Class
AWD /
4WD
Present
Towing
Capable
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
SmallCar
No
No
5,387
4,637
3,939
3,291
2,805
2,377
1,970
1,583
1,216
866
SmallCar
Yes
No
5,687
4,932
4,229
3,576
3,084
2,651
2,240
1,848
1,476
1,122
MedCar
No
No
5,837
5,061
4,340
3,669
3,167
2,724
2,303
1,903
1,522
1,161
MedCar
Yes
No
6,193
5,411
4,684
4,008
3,499
3,050
2,624
2,218
1,832
1,465
SmallSUV
No
No
6,404
5,596
4,845
4,147
3,623
3,161
2,723
2,306
1,910
1,533
SmallSUV
Yes
No
6,833
6,017
5,259
4,554
4,023
3,555
3,110
2,686
2,283
1,900
MedSUV
No
No
8,227
6,876
5,569
4,307
3,090
2,567
2,046
1,527
1,009
494
MedSUV
No
Yes
13,990
12,085
10,243
8,465
6,750
6,106
5,475
4,843
4,212
3,581
MedSUV
Yes
No
8,563
7,199
5,881
4,607
3,378
2,854
2,331
1,810
1,292
775
MedSUV
Yes
Yes
14,325
12,409
10,555
8,765
7,038
6,393
5,760
5,127
4,495
3,862
Pickup
No
No
16,851
14,615
12,456
10,375
8,372
7,636
6,903
6,172
5,443
4,716
Pickup
No
Yes
18,908
16,500
14,172
11,922
9,751
8,974
8,222
7,470
6,718
5,967
Pickup
Yes
No
17,496
15,240
13,062
10,962
8,940
8,201
7,465
6,730
5,998
5,267
Pickup
Yes
Yes
19,552
17,126
14,778
12,510
10,320
9,539
8,783
8,028
7,273
6,518
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
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Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
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Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
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Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
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Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
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Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
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Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
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Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
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Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
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Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
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f
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Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
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Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
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Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
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Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
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Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
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Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
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Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
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Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
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Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
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Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
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Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
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Date of Hearing: June 9, 2022
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Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
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Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
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Oliva, Jacob. 2021. “Leaked Alfa Romeo Tonale Specs Reveal Plug-In Hybrid's Power Output.” Motor1.
December 11. Accessed March 2, 2022. https://www.motor1.com/news/553939/alfa-romeo-tonale-specs-
leaked/.
ii
Errity, Stephen. 2021. Driving Electric - Aston Martin DBX hybrid spotted testing. September 7. Accessed
March 2. 2022. https://www.drivingelectric.com/aston-martin/40826/aston-martin-dbx-hybrid-spotted-testing.
iii
Rodríguez, Jr., José. 2021. Jalopnik - Aston Martin Says Its Fully-Electric Cars Are For Real This Time. July 21.
Accessed March 2, 2022. https://jalopnik.com/aston-martin-says-its-fully-electric-cars-are-for-real-1847330490.
iv
Oliva, Jacob. 2021. “Audi A6 E-Tron Production Version Likely Debuting In 2022.” Motor1.com. August 1.
Accessed March 2, 2022. https://www.motor1.com/news/523785/audi-a6-etron-production-2022/.
v
U.S. Department of Energy and U.S. Environmental Protection Agency. 2022. “Fuel Economy Guide 2022.”
February 24. Accessed March 2, 2022. https://www.fueleconomy.gov/feg/pdfs/guides/FEG2022.pdf.
vi
Parikh, Sagar. 2021. Audi A4 e-tron EV in the works, to rival Tesla Model 3 [Update]. Electric Vehicle Web.
December 27. Accessed March 2, 2022. https://electricvehicleweb.com/audi-a4-e-tron-range-details/.
vii
Sison, 2021. Sison, Reggie. 2021. “Automobili Pininfarina Battista Is “Hyper GT of the Year.” Supercars.net.
Accessed March 2, 2022. https://www.supercars.net/blog/automobili-pininfarina-battista-is-hyper-gt-of-the-
year/.
viii
Carter, Marc. 2021. “2022 Bentley Flying Spur plug-in hybrid revealed with 536 hp.” The Torque Report. July
6. Accessed March 2, 2022. https://www.thetorquereport.com/bentley/2022-bentley-flying-spur-plug-in-
hybrid-revealed-with-536-hp/.
ix
Vijayenthiran, Viknesh. 2021. “2022 BMW iX3 revealed with new look, no additional range.” Motor Authority.
August 11. Accessed March 2, 2022. https://www.motorauthority.com/news/1133191_2022-bmw-ix3-revealed-
with-new-look-no-additional-range.
x
Mihalascu, Dan. 2021. “BMW iX5 Hydrogen Coming To IAA, Small Series Made from Late 2022.” Inside EVs.
August 17. Accessed March 2, 2022. https://insideevs.com/news/527145/bmw-ix5-hydrogen-iaa-2021/.
xi
Bell, Sebastien. 2021. Electric BMW i5 Caught Again, Revealing More of Its Design. Carscoops. July 15.
Accessed March 1, 2022. https://www.carscoops.com/2021/07/electric-bmw-i5-caught-again-revealing-more-
of-its-design/.
xii
van Oostvoorne, Nick Lette. 2022. New BMW i7 EV rendered: price, specs and release date. Carwow. January
7. Accessed March 1, 2022. https://www.carwow.co.uk/bmw/news/4770/bmw-i7-ev-electric-car-price-specs-
release-date#gref.
xiii
Chugh, N. 2021. Car Indigo - 2024 BMW i8 M, Based On The Vision M Concept. October 27. Accessed March
2, 2022. https://www.carindigo.com/news/2024-bmw-i8-m-based-on-the-vision-m-concept.
xiv
Pappas, Thanos. 2021. Buick Trademarks the Electra Name, Does It Hint At Upcoming Electric Crossover?
Carscoops. December 23. Accessed March 2. 2022. https://www.carscoops.com/2021/12/buick-trademarks-
the-electra-name-might-hint-at-upcoming-electric-crossover/.
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
xv
Lambert, Fred. 2021. “Cadillac Lyriq is in final steps before production, new video footage of latest
prototype.” Electrek. November 22. Accessed March 2, 2022. https://electrek.co/2021/11/22/cadillac-lyriq-
final-steps-before-production-video-footage-latest-prototype/#more-212402.
xvi
Szymkowski, Sean. 2022. Cadillac Celestiq EV flagship first in line for GM's Ultra Cruise hands-free driving
system. Road Show. January 5. Accessed March 1, 2022. https://www.cnet.com/roadshow/news/cadillac-
celestiq-ev-flagship-gm-ultra-cruise-hands-free-driving/.
xvii
Ravi, Anjan. 2022. Top Electric SUV - Cadillac Escalade EV to enter production in Jan 2024Report [Update].
February 5. Accessed March 2, 2022. https://topelectricsuv.com/news/cadillac/cadillac-escalade-ev-electric/.
xviii
Canoo Lifestyle Vehicle website. Accessed March 2, 2022.
https://www.canoo.com/canoo/#:~:text=PREORDER%20YOUR%20LIFESTYLE%20VEHICLE.
xix
Markus, Frank. 2021. Future Cars: The 2023 Canoo Electric Pickup Truck and Van Are Funky-Cool EVs.
Motortrend. August 27. Accessed March 1, 2022. https://www.motortrend.com/news/2023-canoo-electric-
pickup-truck-can-future-cars/.
xx
Ravi, Anjan. 2022. Mary Barra confirms Chevrolet Blazer EV debut for 2022 [Update]. Top Electric SUV.
January 12. Accessed March 1, 2022. https://topelectricsuv.com/news/chevrolet/chevrolet-blazer-ev-details/.
xxi
Dorr, Bryon. 2022. Chevy to Bring Battery Electric Versions of Equinox, Blazer in 2023. Gear Junkie. January
6. Accessed March 1, 2022. https://gearjunkie.com/motors/chevy-electric-version-equinox-blazer.
xxii
Weintraub, Seth. 2022. 2024 Chevy Silverado EV unveiled: 400-mile range, Multi-Flex Midgate,
worksite/home backup power and more. Electrek. January 5. Accessed March 1, 2022.
xxiii
Borrás, Jo. 2022. Electrek - Chrysler officially reveals Airflow concept, vows to go all-electric by 2028. January
5. Accessed March 2, 2022. https://electrek.co/2022/01/05/chrysler-officially-reveals-airflow-concept-vows-to-
go-all-electric-by-2028/#more-218343.
xxiv
Priddle, Alisa. 2021. Motortrend - An All-Electric Dodge Muscle Car Is Coming In 2024. July 8.
Accessed March 2, 2022. https://www.motortrend.com/news/dodge-electric-muscle-car-ev-2024/.
xxv
EVcompare.io. 2022. ”EVcompare.io: Faraday Future FF 91 concept.” Accessed March 2, 2022.
https://evcompare.io/cars/faraday/faraday_future_ff_91/.
xxvi
Doll, Scooter. 2021. “Fisker officially unveils Ocean SUV in three price tiers and lots of unique features.”
Electrek. November 17. Accessed March 2, 2022. https://electrek.co/2021/11/17/fisker-officially-unveils-ocean-
suv-in-three-price-tiers-and-lots-of-unique-features/.
xxvii
Seabaugh, Christian. 2021. “Future Cars: The 2022 Ford E-Transit Is an Electric Van, Man.” Motortrend.
August 23. Accessed March 2, 2022. https://www.motortrend.com/news/2022-ford-e-transit-electric-cargo-
delivery-van-future-cars/.
xxviii
Hoffman, Connor. 2021. “Ford Confirms 2022 F-150 Lightning EV Battery Specs.” Car and Driver. December
17. Accessed March 2, 2022. https://www.caranddriver.com/news/a38552140/2022-ford-f-150-lightning-
battery-specs-revealed/.
xxix
Parikh, Sagar. 2022.Top Electric SUV - Icon Ford Explorer Electric (Explorer EV) pushed back to 2024
Report.February 14. Accessed March 2, 2022. https://topelectricsuv.com/news/ford/ford-explorer-electric-
ev/.
xxx
Hyundai Motor Company. 2022. “Electrified G80.” Accessed March 2, 2022.
https://www.genesis.com/worldwide/en/models/luxury-sedan-genesis/electrified-g80/specs.html.
xxxi
Hyundai Motor Company. 2022.Electrified GV70: Coming Soon." Accessed March 2, 2022.
https://www.genesis.com/worldwide/en/models/luxury-suv-genesis/electrified-gv70/highlights.html.
xxxii
Doll, Scooter. 2022. “22 of the most anticipated electric vehicles coming in 2022.” Electrek. January 10.
Accessed March 2, 2022. https://electrek.co/2022/01/10/22-of-the-most-anticipated-electric-vehicles-coming-
in-2022/#h-fisker-ocean.
xxxiii
Edelstein, Stephen. 2021. “2022 GMC Hummer EV Edition 1 to have 329 miles of range, too heavy for
official EPA rating.” Motor Authority. November 24. Accessed March 2, 2022.
https://www.motorauthority.com/news/1134272_2022-gmc-hummer-ev-edition-1-to-have-329-miles-of-range-
too-heavy-for-official-epa-rating.
xxxiv
Mihalascu, Dan. 2021. “GMC Teases Sierra Denali Electric Pickup, Will Reveal It In 2022.” Inside EVs.
December 15. Accessed March 2, 2022. https://insideevs.com/news/554830/gmc-sierra-denali-ev-teased/.
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
xxxv
O’Hare, Ben. 2021. 2023 GMC Sierra Denali EV Rendered Based Off Teaser. Inside EVs. December 18.
Accessed March 1, 2022. https://insideevs.com/news/555500/2023-gmc-sierra-denali-render/.
xxxvi
Dow, Jameson. 2021. Electrek - GM’s Hummer EV has 329-mile range, ‘Edition 1’ deliveries start in
December. November 23. Accessed March 2, 2022. https://electrek.co/2021/11/23/gms-hummer-ev-has-329-
mile-range-edition-1-deliveries-start-in-december/#more-212629.
xxxvii
Fink, Greg. 2021. Car and Driver - Acura's Ultium-Based Electric SUV May Bear the Name ADX. December
27. Accessed March 2, 2022. https://www.caranddriver.com/news/a38621118/acura-adx-ev-suv-trademark/.
xxxviii
Dorian, Drew. Car and Driver - 2024 Honda Prologue. Accessed March 2, 2022.
https://www.caranddriver.com/honda/prologue.
xxxix
Hirons, Ryan. 2022. “Hyundai Ioniq 6 EV spotted: price, specs and release date.” Carwow. January 11.
Accessed March 2, 2022. https://www.carwow.co.uk/hyundai/news/4681/hyundai-ioniq-6-ev-electric-car-price-
specs-release-date#gref.
xl
Stafford, Eric. 2024 Hyundai Ioniq 7. Car and Driver. Accessed March 2, 2022.
https://www.caranddriver.com/hyundai/ioniq-7.
xli
Edd, Hisham. 2021. The Infiniti QX Inspiration Electric Concept SUV Review. Electomo. September 20.
Accessed March 1, 2022. https://electomo.com/infiniti-qx-inspiration-electric-concept-suv-review/.
xlii
Edelstein, Stephen. 2022. 2023 Range Rover P440e: 48 electric miles expected for plug-in hybrid, $106,250
starting price. Green Car Reports. January 28. Accessed March 1, 2022.
https://www.greencarreports.com/news/1134891_2023-range-rover-p440e-48-electric-miles-expected-for-
plug-in-hybrid-106-250-starting-price.
xliii
Parikh, Sagar. 2022. “Jeep Compass gets a mild-hybrid engine for 2022 [Update].” Top Electric SUV. January
7. Accessed March 2, 2022. https://topelectricsuv.com/news/jeep/2022-jeep-compass-phev-4xe-changes/.
xliv
Tamautorumors.com. 2022. “2022 Jeep Renegade 4XeReview, Specifications, and Price.” Accessed March
2, 2022. https://www.tamautorumors.com/2022-jeep-renegade-4xe-review-specifications-and-price/.
xlv
Hall, Chris. 2021. The Jeep Magneto is a cheeky electric Wrangler concept. Pocket-Lint. June 23. Accessed
March 1, 2022. https://www.pocket-lint.com/cars/news/jeep/157430-the-jeep-magneto-is-an-electric-wrangler-
concept.
xlvi
Doll, Scooter. 2021. “Kandi America launches K32 off-road EV starting under $28k.” Electrek. November 10.
Accessed March 2, 2022. https://electrek.co/2021/11/10/kandi-america-launches-k32-off-road-ev-starting-
under-28k/.
xlvii
Armstead, Brian. 2021. “2021 Karma GS-6 Plug-In First Drive: New Name, Lower Price.” Forbes Wheels.
October 31. Accessed March 2, 2022. https://www.forbes.com/wheels/news/2021-karma-gs-6-plug-in-first-
drive/.
xlviii
Dorian, Drew. 2024 Kia EV9. Car and Driver. Accessed March 2, 2022.
https://www.caranddriver.com/kia/ev9.
xlix
Tech2. 2021. Lamborghini to Electrify Model Range By 2024, Launch All-Electric Model Before 2030. May 18.
Accessed March 1, 2022. https://www.firstpost.com/tech/news-analysis/lamborghini-to-electrify-model-range-
by-2024-launch-all-electric-model-before-2030-9631921.html.
l
Tech2, “Lamborghini to Electrify Model Range By 2024”
li
Tech2, “Lamborghini to Electrify Model Range By 2024”
lii
Ramey, Jay. 2021. “First Electric Land Rover Lands in 2024.” Autoweek. February 16. Accessed March 2, 2022.
https://www.autoweek.com/news/green-cars/a35520160/first-electric-land-rover-lands-in-2024/.
liii
Tucker, Sean. 2021. 2022 Lexus RZ 450e: Lexus Unveils First Electric Vehicle. Kelley Blue Book. December 15.
Accessed March 1, 2022. https://www.kbb.com/car-news/2022-lexus-rz-450e-lexus-unveils-first-electric-
vehicle/.
liv
Mihalascu, Dan. 2021. “Lincoln "Mark E" Electric SUV Will Probably Look A Lot Like This.” Inside EVs.
September 22. Accessed March 2, 2022. https://insideevs.com/news/534825/lincoln-electric-suv-accurately-
rendered/.
lv
Kane, Mark. 2021. “Lordstown Endurance Pickup Truck Battery Is 109 kWh.” Inside EVs. April 1. Accessed
March 2, 2022. https://insideevs.com/news/498138/lordstown-endurance-pickup-battery-capacity/.
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
lvi
O’Kane, Sean. 2021. Lordstown Motors stops work on electric van to focus on pickup truck. The Verge. June
15. Accessed March 1, 2022. https://www.theverge.com/2021/6/15/22535457/lordstown-motors-electric-van-
project-camping-world-work-stopped-endurance.
lvii
Clarke, Warren and Eric Stafford. 2022. “2022 Lotus Evija.” Car and Driver. Accessed March 2, 2022.
https://www.caranddriver.com/lotus/evija.
lviii
Banner, Justin. 2021. “Lotus's New Electric SUV (Really!) Is Codenamed "Type 132".” Motortrend. December
3. Accessed March 2, 2022. https://www.motortrend.com/news/lotus-type-132-suv-ev-teaser-preview/.
lix
Duff, Mike. 2021. Lotus Cars Confirms Four Electric Models Are Coming. Car and Driver. August 31. Accessed
March 1, 2022. https://www.caranddriver.com/news/a37445459/lotus-four-electric-cars-planned/.
lx
Duff, Lotus Cars Confirms Four Electric Models Are Coming.
lxi
EVcompare.io. 2022. ”EVcompare.io: Lucid Air Pure.” Accessed March 2, 2022.
https://evcompare.io/cars/lucid/lucid_air/.
lxii
Parikh, Sagar. 2021. “Maserati Grecale debuting in 2022, will get Hybrid – Report [Update].” Top Electric
SUV. January 25. Accessed March 2, 2022. https://topelectricsuv.com/news/maserati/electric-maserati-grecale-
details/.
lxiii
Ravi, Anjan. 2021. “Gen II Maserati Levante is the company’s 2nd electric SUV [Update].” Top Electric SUV.
April 2. Accessed March 2, 2022. https://topelectricsuv.com/news/maserati/maserati-levante-electric/.
lxiv
Ramey, Jay. 2021. Maserati GranTurismo EV Will Battle Tesla Roadster. Autoweek. June 15. Accessed March
1, 2022. https://www.autoweek.com/news/green-cars/a36728709/maserati-granturismo-ev-will-battle-tesla-
roadster/.
lxv
Ramey, Maserati GranTurismo EV.
lxvi
Parikh, Sagar. 2022. Maserati Grecale debuting in 2022, will get Hybrid Report [Update]. Top Electric SUV.
February 23. Accessed March 1, 2022. https://topelectricsuv.com/news/maserati/electric-maserati-grecale-
details/.
lxvii
Ravi, Anjan. 2021. Gen II Maserati Levante is the company’s 2nd electric SUV [Update]. Top Electric SUV.
April 2. Accessed March 1, 2022. https://topelectricsuv.com/news/maserati/maserati-levante-electric/.
lxviii
Bond Jr., Vincent. 2021. Maserati's lineup is growing with more electric power. Automotive News.
September 27. Accessed March 1, 2022. https://www.autonews.com/future-product/maserati-future-product-
more-electric-power.
lxix
Mazda. 2022. The 2022 Mazda MX-30 EV. Accessed March 2, 2022.
https://www.mazdausa.com/vehicles/electric/mx-30-electric-hybrid.
lxx
Capparella, Joel and Eric Stafford. 2022. “2022 Mercedes-Benz EQA.” Car and Driver. Accessed March 2,
2022. https://www.caranddriver.com/mercedes-benz/eqa.
lxxi
Lambert, Fred. 2021. “Mercedes-Benz launches EQB, up-to-7-seat electric SUV to compete against Tesla
Model Y.” Electrek. September 6. Accessed March 2, 2022. https://electrek.co/2021/09/06/mercedes-benz-
eqb-7-seat-electric-suv-compete-tesla-model-y/.
lxxii
Lambert, Fred. 2021. “Mercedes-Benz unveils EQE electric sedan with impressive 400-mile range.” Electrek.
September 5. Accessed March 2, 2022. https://electrek.co/2021/09/05/mercedes-benz-eqe-electric-sedan-
400-mile-range/.
lxxiii
Hirons, Ryan. 2021. Carwow - Mercedes Concept EQG electric G-Class revealed: price, specs and release
date. September 5. Accessed March 2, 2022. https://www.carwow.co.uk/mercedes/news/5577/new-mercedes-
eqg-electric-g-class-ev-revealed-price-specs-release-date#gref.
lxxiv
Doll, Scooter. 2022. Electrek - Mercedes-Benz unveils VISION EQXX prototype with over 620 mile range,
impressive drag coefficient, and a solar roof. January 3. Accessed March 2, 2022.
https://electrek.co/2022/01/03/mercedes-benz-unveils-vision-eqxx-prototype-with-over-620-mile-range-
impressive-drag-coefficient-and-a-solar-roof/#more-217756.
lxxv
Ravi, Anjan. 2022. Top Electric SUV - Next-gen Mercedes EQC U.S. launch confirmed Report [Update].
January 10. Accessed March 2, 2022. https://topelectricsuv.com/news/mercedes-benz/mercedes-eqc-usa-
launch-delayed-again/.
lxxvi
Nissan. 2022. “The All-New 2023 Nissan ARIYA.” Accessed March 2, 2022.
https://www.nissanusa.com/ariya.html.
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
lxxvii
Hodges, Ben. 2021. “New electric Polestar 3 SUV prototype officially teased.” Carbuyer. December 3.
Accessed March 2, 2022. https://www.carbuyer.co.uk/polestar/165016/new-electric-polestar-3-suv-prototype-
officially-teased.
lxxviii
Motortrend. 2021. Future Cars: The 2024 Polestar 4 Is the Sleek Electric Sedan. August 5. Accessed March
2, 2022. https://www.motortrend.com/news/2024-polestar-4-precept-future-cars/.
lxxix
Polestar. 2022. Polestar 5 to be faster, lighter and more dynamic thanks to brand-new UK-developed
bonded aluminium platform. February 15. Accessed March 2, 2022.
https://media.polestar.com/global/en/media/pressreleases/645729
lxxx
Hoffman, Connor. 2021. Porsche Macan EV Will Arrive in 2023 with More Range Than Taycan. Car and
Driver. May 8. Accessed March 1, 2022. https://www.caranddriver.com/news/a36355610/porsche-macan-
electric-prototype-revealed/.
lxxxi
Nedelea, Andrei. 2021. Inside EVs - Ram Teases Electric 1500 Pickup Truck Coming In 2024. July 8.
Accessed March 2. 2022. https://insideevs.com/news/518965/ram-1500-electric-2024-teaser/.
lxxxii
Lambert, Fred. 2021. Rolls-Royce unveils first electric car, Spectre, and will go all-electric by 2030. Electrek.
September 29. Accessed March 1, 2022. https://electrek.co/2021/09/29/rolls-royce-unveils-first-electric-car-
spectre-go-all-electric-2030/.
lxxxiii
Flieri, Denis. 2021. “How to Order the New Subaru Solterra EV and Complete Trim Guide.” Torque News.
December 11. Accessed March 2, 2022. https://www.torquenews.com/1084/how-order-new-subaru-solterra-
ev-and-complete-trim-guide.
lxxxiv
Vincent, James. 2022. Tesla delays Cybertruck to early 2023, says report. The Verge. January 14. Accessed
March 1, 2022. https://www.theverge.com/2022/1/13/22881646/tesla-cybertruck-production-date-2022-
removed-website.
lxxxv
Cars Direct. 2021. 2023 Tesla Roadster: Preview, Pricing, Photos, Release Date. December 22. Accessed
March 1, 2022. https://www.carsdirect.com/2023/tesla/roadster.
lxxxvi
Lambert, Fred. 2021. “Toyota unveils its first all-electric car: the bZ4X, an electric SUV packed with cool
features.” Electrek. October 29. Accessed March 2, 2022. https://electrek.co/2021/10/29/toyota-unveils-first-
all-electric-car-bz4x-an-electric-suv-packed-cool-features/.
lxxxvii
Manthey, Nora. 2022. “VinFast wins first US customer for electric cars shown at CES.” Electrive.com.
January 10. Accessed March 2, 2022. https://www.electrive.com/2022/01/10/vinfast-wins-first-us-customer-for-
electric-cars-shown-at-ces/.
lxxxviii
Lambert, Fred. 2021. “VW expands its electric vehicle offerings with the ID.5 electric SUV.“ Electrek.
November 3. Accessed March 2, 2022. https://electrek.co/2021/11/03/vw-expands-electric-vehicle-offering-
id5-electric-suv/#more-209575.
lxxxix
Traugott, Jay. 2022. Volkswagen Announces ID.Buzz Reveal Date. Car Buzz. January 6. Accessed March 1,
2022. https://carbuzz.com/news/volkswagen-announces-id-buzz-reveal-date.
xc
Kane, Mark. 2021. Volkswagen Prepares Emden Plant For ID.4 And ID.VIZZIONs. InsideEVs. May 6. Accessed
March 1, 2022. https://insideevs.com/news/505818/volkswagen-emden-plant-id4-idvizzion/.
xci
Kane, Volkswagen Prepares Emden Plant For ID.4 And ID.VIZZIONs.
xcii
Ravi, Anjan. 2021. Electric Vehicle Web - Under Biden’s EV shift, will the VW ID.6 head to the U.S. by 2023?
[Update]. November 1. Accessed March 2, 2022. https://electricvehicleweb.com/volkswagen-7-seat-electric-
suv-vw-id-6/.
xciii
Volkswagen. 2021. A look ahead to entry-level electric mobility: world premiere of the ID. LIFE. September 6.
Accessed March 2, 2022. https://www.volkswagen-newsroom.com/en/press-releases/a-look-ahead-to-entry-
level-electric-mobility-world-premiere-of-the-id-life-7490
xciv
Brodie, James. 2022. “New 2022 Volvo XC90 replacement could be called Embla.” Auto Express. January
18. Accessed March 2, 2022. https://www.autoexpress.co.uk/volvo/xc90/104003/new-2022-volvo-xc90-
replacement-could-be-called-embla.
xcv
Kane, Mark. 2021. “US: Polestar Announces 2022 Polestar 2 Specs and Prices.” Inside EVs. August 12.
Accessed March 2, 2022. https://insideevs.com/news/526062/us-2022-polestar2-specs-prices/.
xcvi
Car and Driver. 2022. Every Electric Vehicle That's Expected in the Next Five Years. January 6. Accessed
March 2, 2022. https://www.caranddriver.com/news/g29994375/future-electric-cars-trucks/.
Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
xcvii
BMW Group. 2022. “BMW Group Investor Presentation” February. Accessed February 24, 2022.
https://www.bmwgroup.com/content/dam/grpw/websites/bmwgroup_com/ir/downloads/en/2021/Investor-
Presentation/BMW_Investor_Presentation_2021.pdf.
xcviii
Forbes. 2021.Every Automaker's EV Plans through 2035 and Beyond.” October 4. Accessed March 2,
2022. https://www.forbes.com/wheels/news/automaker-ev-plans/.
xcix
Canoo. 2021. Canoo Increases Production Guidance and Targets for US Facilities. December 15. Accessed
March 3, 2022. https://investors.canoo.com/news-presentations/press-releases/detail/75/canoo-increases-
production-guidance-and-targets-for-us.
c
Canoo. 2021. Promises Kept Canoo Pricing For Lifestyle Vehicle Is Accessible For Everyone. May 17.
Accessed March 2, 2022. https://www.press.canoo.com/press-release/promises-kept.
ci
Randall, Chris. 2021. Electrive - Fisker to Release Two More Electric Cars by 2025.” Electrive.com, 13 October.
Accessed March 2, 2022. https://www.electrive.com/2021/10/13/fisker-to-release-two-more-electric-vehicles-
by-2025/.
cii
Forbes, Every Automaker's EV Plans”
ciii
Ford. 2022. Full Speed Ahead: Ford Planning to Nearly Double All-Electric F-150 Lightning Production To
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Appendix G
Date of Release: April 12, 2022
Date of Hearing: June 9, 2022
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