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Re: §1962.1 Zero Emission Vehicle Standards for 2009 through 2017
Model Year Passenger Cars, Light-Duty Trucks, and Medium Vehicles.
ZEV Credits.

Fast Refueling, especially at the UDDS/time rates identified, is a
metric that is irrelevant to Zero Emissions, and should not be part
of the requirements. I am the owner of a number of 100%-Battery
Electric Vehicles, and the vast majority of my charging is done
overnight. The rest of the time I can comfortably live with a
leisurely charge rate while doing something else. For most vehicles
there are very few situations when high energy replacement rates
are necessary, and, if needed, even those can be accommodated by
appropriate (although expensive) high power sources, but not at the
ridiculously-biased Fast Refueling rates identified in the
Qualification for ZEV Multipliers and Credits. Please shift your
paradigm away from the "gasoline station" concept - it belongs in
the last century!