Why Colorado Needs a Zero Emission Vehicles Standard

August 9, 2019 | 1:06 pm
Photo: Tim Hurst/Flickr
David Reichmuth
Senior Engineer, Clean Transportation Program

Colorado is poised to enact requirements for automakers to sell “Zero Emission Vehicles” (ZEVs) in the state. In 2018, Colorado was already in the top 5 states in terms of percent of vehicle sales that are electric in the country, so why is this important? It’s because despite progress, Colorado could be moving even faster to switch from gasoline to electricity to power cars and trucks, if there were more models of electric vehicles available.

Colorado lacks a ZEV standard

Subaru wrote to Colorado’s regulators in October 2018 to “clarify” that the new plug-in model will be “available to all Subaru retailers nationally”, though to-date it’s not on Colorado dealers’ lots. Click to enlarge.

In 2018, Colorado ranked 4th in the nation in percent of new cars sold that were electric vehicles, at 2.6 percent. But that was less than half the rate of sales in California (7.9 percent sales), despite Colorado’s more generous electric vehicle (EV) rebate program. While there are many factors that lead to that sales difference, one key factor is the greater availability of EVs in California.

Automakers have argued that the ZEV standard is not needed to ensure EVs are available in Colorado. For example, Subaru said in a letter to the Colorado Air Quality Control Commission:

“Product mandates on manufacturers are not responsible for moving the ZEV market forward, cooperation and buy‐in from all stakeholders are the best course of action.”

And Subaru also “clarified” that its new plug-in hybrid Crosstrek SUV would be “available” to dealers in Colorado, a statement that seems targeted to assure the regulators that its ZEVs would be available in the state:

“Regarding the sale of the 2019 Subaru Crosstrek Hybrid (Plug‐in Hybrid Electric Vehicle or PHEV) in the State of Colorado, please allow us to clarify a possible misunderstanding. When the new Crosstrek Hybrid goes on sale in December of this year, it will be legal for sale in Colorado and available to all Subaru retailers nationally.”

Well, yes, the Subaru Crosstrek is technically legal for sale in Colorado, but that’s not the concern. The important question is: Is it available in the state for interested customers? What have we seen to date? Exactly 2 plug-in Crosstreks have been registered in Colorado in the first six months of 2019 because it’s not available at Subaru dealers in the state. A search on Edmunds.com of new cars available at dealers shows 0 cars available within 100 miles of Denver, CO, with the nearest one 800 miles away in Riverside, CA (as of August 6, 2019). By comparison, doing the same search 100 miles around Oakland, CA reports 23 Crosstrek plug-in hybrids available at dealers’ lots.


Subaru vehicles are very popular in Colorado and part of their brand is environmentalism. The CEO of Subaru of America told the website brandchannel: “We’ve been identified as granola-crunchers and tree-huggers, and people with lots of stickers on the backs of their vehicles, and it’s true. We’re proud of that. Why run away from that?”

But yet the only states with more than 10 new Crosstrek plug-in registrations in 2019 (so far) are California, Connecticut, Maryland, Massachusetts, New Jersey, New York, and Oregon. What do these states all share in common? They have all adopted the ZEV standard. Clearly the ZEV regulation is needed to move the market forward in Colorado.

I’ve singled out Subaru in this example, but there are other manufacturers that have also avoided bringing electric drive cars to Colorado and other states that aren’t part of the ZEV regulation. For example, the Volkswagen e-Golf, Fiat 500e, Kia Niro EV, and Honda Clarity are all virtually unavailable in Colorado. And in its own letter to regulators, Kia bragged about the Soul EV being available for sale in 13 states, but not Colorado. So, while Colorado has had more EV sales than much of the rest of the country, EV sales could potential be even higher if more models were available to car buyers in the state.

Colorado needs to send the right message on climate change

The air pollution from vehicles on Colorado’s roads today is significant. And the state is already experiencing the impact of climate change, driven by combustion of fossil fuels. Zero Emission Vehicles are a solution that will help address both air quality and climate change. While the impact will be small initially compared to the number of gasoline cars on the road, the most important part of adopting the ZEV regulation will be to put Colorado on a clear path forward towards moving away from gasoline and towards lower emissions.