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1) Increase not decrease the minimum number of Pure ZEV required in
Phase III (2012-2015);

2) Eliminate the substitution of Pure ZEVs with Enhanced
AT-PZEVs;

3) Set the minimum ZEV requirements on a yearly basis rather than
for three years, thus preventing manufacturers from getting an
additional three year grace period and eliminating “blackout”
years;

4) Change the carry forward provision of gold ZEV credits earned
by any manufacturer that exclusively manufactures pure ZEVs to
expire 3 years from the date of transfer to another manufacturer.