Yes, they should at least put an asterisk next to it when making such a claim. Something like:
* Equine power has different characteristics to ICE power.
** All 0-30 measurements were taken with empty bowels, and a lump of sugar placed 1 foot in front of the muzzle."
*** This is not a ZEV vehicle. It will occasionally and randomly excrete large amounts of fecal matter which can be harmful to the driver.
The qualifications for ZEV credits are quite strict, with few exceptions. But there is a subcommittee of the CARB group known as a OATS (Older Autonomous Transport Solutions) that consults on exemptions, noting that all types of herbivore powered transport produce a major pollutant in the form of methane.
After years of tax payer funded research into alternative horse food they concluded that methane is unavoidable.
Due to the extremely explosive nature of methane they insist that a new law be put in place banning the drivers of OAT vehicles from smoking. They noted that the side effect of smoking behind a horse include momentary bursts of extreme acceleration when the horse self-ignites into a giant gas ball. The resulting force can destroy property 2 blocks away and leave 50 ft craters .. but they didn't recommend any fines or prison sentences since they cant be applied posthumously.
One solution to this is to provide kevlar gas capture bags for fitment to the rear of the horse, allowing the horse operator to sell the gas to utility companies.
(not sure what this has to do with 24" wheels !!)
