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Dear CARB Directors,

The Community Environmental Council (CEC) is a 39 year old
organization based in Santa Barbara, CA.  We work exclusively on
sustainable transportation, energy efficiency, and renewable energy
issues.

My organization is working on a pilot grant to test products that
convert existing gasoline or diesel vehicles to PHEVs.  Numerous
companies have established proof of concept for this technology,
but no fleet testing has been done yet.  While we propose to test
the technology on a small number of vehicles, the testing and
waiver requirements are large.  The current requirements impose
significant financial hardships that will stifle innovation among
small companies.  

Please consider raising the Tier 1 ceiling to 100-1000 vehicles. 
This will enable smaller companies to test their products at a
reasonable scale and establish an income stream before investing in
expensive emission testing.  Raising the Tier 1 cap from 10
vehicles will not harm air quality as the current Tier 1
regulations require a company to show detailed engineering analysis
that its modifications will only reduce air pollution. 

Burdensome regulations have caused many innovative companies to
not be able to bring their technology to the market.  Please help
the nascent PHEV retrofit community survive and thrive.

Sincerely,

Michael Chiacos
Transportation Specialist
Community Environmental Council