Comment Log Display

To the California Air Resources Board (CARB),

I'm reaching out to seek your interpretation and review of the term
'Car-Sharing' as defined in the Clean Vehicle Rebate Project (CVRP)
Implementation Manual and its Terms and Conditions. More
specifically, we are seeking clarity on the eligibility of
car-sharing businesses utilizing third-party platforms like Turo
for the rebate program.

Our company operates a full-time electric vehicle (EV) car-sharing
service on platforms such as Turo, providing vehicles for
short-term rental to pre-approved individuals and businesses. Turo
(The Platform) is providing the service by connecting individuals
and business to these approved members who's interested in
Car-Sharing.

Upon thorough review of the CVRP Implementation Manual and its
Terms and Conditions, we have found the following relevant
passages:

1. Page 18 of Implementation Manual states that "Traditional rental
and car share fleets, as defined in Section V., are subject to
limits of 20 rebates per calendar year."
2. Page 35 of Implementation Manual, Section V, defines 'Car
Sharing' as "a model of vehicle rental where users can rent
vehicles for short periods of time and users are members that have
been pre-approved to drive.

It is our belief that our business model aligns with this
definition, there by aligning with CARB and the CVRP's objective of
promoting the use of clean vehicles. However, it appears there may
be ambiguity regarding the eligibility of businesses such as ours
that operate via third-party platforms, which has given rise to
concerns regarding our application and denial of rebate, despite
within the limits of 20 rebates for Car-Sharing business.

To that end, we kindly request CARB's clarification and
interpretation on this matter. We would appreciate understanding
why car-sharing businesses that operate via third-party platforms
like Turo might be ineligible for the rebate, despite seemingly
complying with the car-sharing definition given in the CVRP
Implementation Manual.

Transparency on this issue would not only benefit our business but
also other small businesses operating in the car-sharing space. We
consider ourselves part of the solution towards a cleaner and more
sustainable California, and we seek to fully understand the rules
and regulations that govern our participation in this important
transition.

We sincerely appreciate your attention to this matter and eagerly
anticipate your response.

Best regards,

Yongbin Zhen (Barry)
Manager of i Quadrant LLC
415-360-3030
Barry@iquadrant.org