Comment Log Display

As I understand the proposed rule, the CARB intends to require a
$200,000 test once a company has modified 10 vehicles.   

The costs of such testing spread over 10 vehicles make a "small"
company not viable.  At $20,000 / car for #1-#10 your rule will
prevent the innovation that a small company can bring.

Large companies that intend and have the resources to build
thousands of vehicles can amortize the cost of such testing over
the design cycle and initial manufacturing. 

I request consideration that 100 vehicles possibly emitting more
air pollution while definitively reducing their gasoline usage is
worth our efforts to support.   Note that POSSIBLY emitting more
air pollution, not guaranteed to do so.

I agree that the testing needs to be done once the design of the
modifications has stabilized.  I support the requirement for
testing at 100 vehicles, not the ten that the proposed rule would
require.

   David Lincer