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To the California Air Resources Board:

The attached document is proposed amendments to one section of
California Code of Regulations, Title 13, Division 3, Chapter 1,
Article 2. The content was developed in consultation with
California Air Resources Board members. Immediate consideration and
adoption are respectfully requested.

SUMMARY

If adopted, the manufacturer of a qualifying ultra-fast refueling
zero-emission vehicle would receive two additional zero-emission
vehicle (“ZEV”) credits. To qualify, a ZEV must be able to
accumulate at least 150 miles of urban dynamometer driving cycle
(“UDDS”) range in 45 seconds or less. Also, the requirements set
forth within subdivision 1962.1(d)(5)(B) (that actual fast
refueling events be demonstrated) are incorporated by reference.

RATIONAL

These amendments would further the California Air Resources Board’s
ZEV mandate of rapidly expanding the number of electric vehicles
(“EVs” for plural, “EV” for singular) available to consumers.

Although one of the greatest impediments to EV adoption by
consumers is the unacceptably long timespan required for EV
refueling, the refueling speed impediment can be entirely
eliminated by technologies that reduce the length of refuel time to
a fraction of the time needed for a gasoline car to be refueled. 

By providing additional ZEV credits for such ultra-fast refueling
technologies, the California Air Resources Board incentivizes EV
manufacturers and vendors to adopt and these technologies,
consequentially making EVs more attractive to consumers.


I look forward to sharing with you this proposed amendment in
person and answering any questions you may have on Thursday,
October 23, 2014, in Diamond Bar, California.

Sincerely,

Donald MacAllister
President, Fast Swap Technologies, Inc.

Address: 2618 San Miguel Drive, Suite 133
Newport Beach, California, 92660-5437 USA
Tel: +1-310-924-1303
Email: donmacallister@mac.com
Web: fastswap.com