On September 23, California Governor Gavin Newsom issued an executive order (“Order”) directing that “all new cars and passenger trucks sold in California be zero-emission vehicles by 2035.”[1] The order’s public announcement emphasizes concern over smog and toxic diesel emissions and notes that half of California’s carbon pollution originates from the transportation sector.[2] The Order prioritizes deploying zero emissions technologies to “reduce both greenhouse gas emissions and toxic air pollutants that disproportionately burden our disadvantaged communities of color.”[3]