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Comment for ZEV 2008 (zev2008) - 45 Day.

First NameRichard
Last NameKelly
Email Addressrichard@kelly.ws
Affiliation
SubjectStop Weakening the ZEV Program
Comment
The CARB ZEV program of 1990 was bold and relatively simple. It
required automakers to ramp-up production of ZEVs by 2%, 5%, then
10% of their fleets by 2003. This mandate resulted in 4,400 BEVs
being placed on the road, some of which are still being driven
today.

Since it's inception, the ZEV program has been "adjusted" four
times.  Each adjustment was a bit like a knife in the back.  The
current staff proposal is more of the same, except at this point,
there isn't much life left in the victim.  There won't be a need
for another adjustment, because if this one is approved, CARB will
lose relevancy with just about every stakeholder except the
automakers.

Each adjustment of the program has introduced more complexity, and
more accommodation for the automakers.  These two strategies have
not resulted in any new vehicles being placed on the roads of
California.

The current ISOR continues this fruitless trend by introducing yet
more complexity (enhanced AT PZEVs?, Silver+) and yet more
accommodation (travel provision extension).

The most unnecessary weakening of the program is the reduction of
the minimum number of Type IV ZEVs by 90% to 2,500.  That's 2,500
vehicles over three years, spread out over all automakers.

Directors, please recognize that this program needs to be
strengthened, not weakened. Reject the proposed amendments and ask
your staff to create proposals that will result in more ZEVs on the
roads of California.

Attachment
Original File Name
Date and Time Comment Was Submitted 2008-03-26 02:22:33

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