Comment Log Display

(Attached via .pdf) 
								April 21, 2009

The Honorable Mary Nichols							
Chair, California Air Resources Board
1001 "I" Street
P.O. Box 2815
Sacramento, CA 95812

Response - Adoption of the Proposed AB 118 Air Quality Improvement
Program Funding Plan for Fiscal Year 2009-10 including the
Zero-Emission Vehicle (ZEV)
and Other Clean Vehicle Rebates Program

Dear Chairman Nichols,

Thank you for the opportunity to comment on the Adoption of the
Proposed AB 118 Air Quality Improvement Program Funding Plan for
Fiscal Year 2009-10 especially the ZEV and Other Clean Vehicle
Rebates Program.  We applaud the staff on their hard work on this
proposal.  Plug In America has reviewed this program in light of
the overall AB118 goals and we feel that there is a significant
opportunity to improve the program, especially in light of the
desired outcome – more ZEV and PHEV vehicles on the road.

The program was conceived to improve air quality by promoting the
deployment of non-polluting vehicles. This requires prioritizing
commercialization over R&D. We believe that there are still
compelling opportunities to make the program more results-oriented,
and propose that the following points be revisited:

First and foremost, we support the program but the Staff Proposal
is not ambitious enough in terms of baseline funding.  Plug In
America urges the ARB to increase the funding for the ZEV Clean
Vehicle Rebate program to $9.00M for FY2009-2010.  Funding this
part of the program is significantly more important than many of
the proposed research and demonstration projects, which could take
many years to have any true impact on the AB118 goals. These
rebates will put ZEVs on the road and immediately contribute to air
quality improvement.

This level of funding is necessary since we are at the very
beginning of the market penetration for many of these vehicles and
incentivizing the early adopters has proved to be one of the most
successful strategies for accelerating longer term market share.  

In addition, by providing significant incentives in the early
stage, California will be able to attract the early deployment of
several vehicles in late 2009 and the beginning of 2010, including
PHEVs from OEM automakers. The difference in being able to reach
4,000 potential vehicles rather than just 2,000 is truly
significant as California seeks to lead the nation in this area.

The staff has done an excellent job in making the ZEV Clean
Vehicle Rebate program more inclusive on the types of vehicles
eligible for the rebates.  By leveraging the successful AFIP
program and including rebates for highway capable Zero Emission
Motorcycles (ZEMs) and for OEM PHEV vehicles, you are opening up
significant opportunities for getting more clean vehicles on the
road.

Our proposal for the program would be:

Plug In America Proposed FY 2009-10 ZEV Funding 

Approximate
Number of Vehicles	Vehicle Rebate
Amount	Total FY 2009-10
Funding
Up to 1000 ZEVs	$5,000	$5,000,000 
Up to 500 PHEVs	$3,000	$1,500,000
Up to 1,000 ZEMs	$1,500	$1,500,000
Up to 1,000 NEVs	$1,000	$1,000,000
	TOTAL	$9,000,000

This table does not include funding for commercial ZEV vehicles,
which we also believe should receive increased funding to the level
of $5mm as a separate program. 

Innovative companies which are already shipping ZEV vehicles
approved for the AFIP program include: Tesla, Vectrix, GEM, Honda,
Miles, and ZENN.  In addition, the following companies have
announced they will have vehicles available in California during
2009: Aptera, Brammo, Electric Motorsport, Myers Motors, and Zero
Motorcycles.  Plus a number of automakers have announced plans for
early deployment of test fleets or consumer test programs:  GM,
Nissan, BMW, Toyota, Hyundai, Mitsubishi, Ford, and Chrysler.  The
rebates in this program will attract these vehicles to California
first.

There are many positive aspects to the proposed program, but now
is not the time to be conservative with funding a ZEV rebate
program.  We encourage the Board to consider the above changes to
make the program even better and more results-oriented. Now that
ZEVs are becoming available in showrooms where consumers can
purchase them, we need to accelerate their acceptance and make this
program truly a success. 

Thank you for your time, 

Jay Friedland
Legislative Director, Plug In America