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CARBs proposal for fixed cert fees is not unreasonable.
I would however urge that the level of fees be adjusted more in
line with the volumes to be sold rather than a fixed fee.
It is noted that a reduced fee is proposed for "carry over" and
"Small Businesses". There are some, a very few, manufacturers or
importers who may only be retailing some 100's of vehicles in
California but whom do not meet the "Small Business"
classification.

I should like to ask CARB to consider extending the reduced fees to
include these low volume manufacturers.
The volume limit could be set at the existing 4500pa low volume
limit or a reduced number, say 2250pa, if that was felt more
appropriate.

Thank you.