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Dear Chair Liane M. Randolph,

As a subsidiary of Ford Motor Company, Spin is an industry leader
in offering shared micromobility solutions, including e-scooters
and e-bikes. Over the last four years, Spin has greatly expanded
the availability of e-scooters and e-bikes for hire in over 113
cities and universities across North America and Europe. Each day,
hundreds of thousands of Americans rely on Spin e-scooters and
other microbility options to conveniently get to work, school, or
visit local retail businesses in their communities. In the context
of COVID-19, the value of micromobility as a vital transportation
option has also become more apparent. By eliminating the highest
risk factors for coronavirus transmission, electric scooters offer
two distinct safety advantages compared to other modes of shared
transportation: The ability to 1) ride alone and 2) stay outdoors.
These public-health advantages explain why many U.S. cities quickly
declared electric scooters an "essential service" and integral part
of their local transportation ecosystem.

Beyond the value to riders, shared micromobilty also offers broader
potential as a sustainable transportation alternative to
gasoline-based cars and motor vehicles. This is particularly true
in cities, where the majority of trips are short-distance (e.g.
less than 3 miles) and congestion and pollution from cars is a
persistent and growing issue. Fortunately, within the
micromobillity industry, there is a growing recognition that more
must be done to improve the underlying sustainability of all
elements of operations. At Spin, for example, these efforts include
using 100% renewable electricity to charge our fleets (i.e.
e-scooters and e-bikes), replacing gas vans with electric vans and
other sustainable vehicles such as e-cargo bikes and electric
low-speed vehicles to serve operational needs, and using swappable
and long-range batteries to reduce the need for transporting
scooters to our warehouses for charging, so e-scooters and e-bikes
can remain on the street available for use.

In reference to CARB's public workshop on changes to the LCFS
Program, we have included some relevant data (see attached file) to
help inform the development of new energy economy ratios (EERs) for
"battery-electric micromobility applications." Specifically, our
data includes a recent Life Cycle Analysis (LCA) of our latest
e-scooter vehicle completed by the Massachusetts Institute of
Technology, along with aggregated mode shift survey results from
our riders in California. These mode shift surveys shed light on
the decision making behind why people chose to use shared
e-scooters and e-bikes over other transportation options, including
private cars, rideshare Apps, public transportation, and walking.
Encouragingly, over 27% of our respondents said they decided to
ride an e-scooter rather than a private car or rideshare option
(e.g. Lyft or Uber). Still, we recognize that significantly more
mode shift away from cars is needed. Spin recently published a
report (see attached file) on the factors that we believe can
enable and encourage such mode shift and what we are doing to
promote greater mode shift.

Looking ahead, we strongly support the creation of new energy
economy ratings (EERs) for micromobility to help achieve CARB's
stated objective of accelerating the transition to zero-emission
vehicles (ZEVs). As your staff continues the consultation process,
we encourage you to reach out for additional data and technical
input as needed. At the moment, we are working with researchers
from UC Davis to conduct additional mode shift research based on
our data and to better understand what drives mode shift so we can
enable greater mode shift to happen in the future. Such inputs may
be useful for your team to inform the development of EERs for
micromobility by leveraging the latest industry and independent
research available.

Thank you for your consideration, and we look forward to continue
working with your team on this important issue. If you have any
follow up questions or additional data needs, please do not
hesitate to contact us directly.

Sincerely,

Brit Moller