Climate Policy Engagement Analysis
Climate Policy Engagement Overview: ZETA has active, positive engagement with U.S. climate regulation in 2022-24. It has consistently advocated for ambitious regulatory measures to electrify transportation in the U.S, including for policies in line with 100% US electric vehicle (EV) sales by 2030.
Top-line Messaging on Climate Policy: ZETA appears very supportive of the need for policy to respond to climate change. ZETA supported 1.5 degree Celsius warming targets in a February 2022 joint letter that also expressed support for the Build Back Better Act. ZETA also supported the Paris Agreement in October 2023 US regulatory comments on CAFE (Corporate Average Fuel Economy) standards.
Engagement with Climate-Related Regulations: ZETA actively supports more ambitious climate-related regulations in the US. ZETA strongly supported the most stringent GHG emissions standards for light and medium-duty vehicles from 2027 onwards in July 2023 US federal regulatory comments. Similarly, ZETA advocated for more ambitious US GHG emissions standards for heavy-duty vehicles, in line with California's Advanced Clean Truck targets, in July 2023 comments to the EPA. In October 2023 US federal regulatory comments on proposed Corporate Average Fuel Economy (CAFE) standards, ZETA supported the most stringent possible alternative and advocated to phase-out off cycle and A/C credit systems that weaken the program’s stringency.
ZETA also strongly supported California waivers to grant the enforcement of the Advanced Clean Fleets, Advanced Clean Cars II, and Advanced Clean Trucks regulations in regulatory comments in 2023. In 2023, ZETA’s Executive Director, Albert Gore, wrote to policymakers in the states of New Jersey, Colorado, Rhode Island, Maine and Connecticut to advocate for the adoption of the Advanced Clean Cars II program, and to the states of Rhode Island, Maine and Connecticut to support the adoption of the Advanced Clean Trucks program.
Regarding US fuel economy standards, ZETA supported the most stringent CAFE (corporate average fuel economy) standards (PC6LT8 and HDPUV14) in 2023 regulatory comments to NHTSA in October 2023. ZETA also directly advocated for the most stringent CAFE standards for heavy-duty vehicles in a September 2023 public hearing. Moreover, ZETA advocated for adjusted Petroleum-Equivalent Fuel Economy Calculations for CAFE standards without credit multipliers for EVs and that do not favor plug-in hybrids vehicles over battery electric vehicles (BEVs) in 2023 comments.
Positioning on Energy Transition: ZETA strongly supports numerous regulatory measures towards the electrification of transportation and has consistently advocated for 100% EV sales in the US by 2030. In a statement on ZETA’s corporate website, ZETA’s executive director strongly endorsed the Inflation Reduction Act in July 2022.
ZETA strongly supported ambitious electrification targets for light and medium-duty vehicles from 2027 onwards in July 2023 US federal regulatory comments. Similarly, ZETA advocated for the ambitious electrification targets of 55% zero emission US heavy-duty vehicle sales by 2030 in line with California's Advanced Clean Truck targets, in July 2023 comments to the EPA. ZETA also strongly supported CARB's earlier proposed 2036 100% ZEV sales mandate under the Advanced Clean Fleets regulation, which includes a 2040 100% ZEV sales mandate for medium and heavy-duty vehicles in April 2023 regulatory comments.
Additionally, ZETA advocated for increased government funding to support the electrification of road transport in a March 2023 letter to the House and Senate Appropriations Committees. ZETA’s Executive Director Albert Gore strongly supported the wider implementation of several tax credits to drive the electrification of transportation in a February 2023 Twitter post. ZETA also supported 30C Alternative Fuel Vehicle Refuelling Property Credits in May 2023 regulatory comments, and Section 45X Advanced Manufacturing Production Credit in November 2022 regulatory comments.
More recently, ZETA supported regulatory measures encouraging the development of the electricity grid and EV charging infrastructure in a July 2023 policy brief. ZETA also recognised the role of critical minerals production and EV battery recycling in the U.S. to enable the energy transition and road transport electrification in a September 2023 white paper and advocated for regulatory measures supporting a US supply chain in September 2023 comments on National Environmental Policy Act Implementing Regulations (NEPA) Revisions Phase 2.