Comment Log Display

July 25, 2008

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

Ms. Nichols, et. al.:

That CARB would dilute the ZEV mandate even further is beyond
comprehension. One would think it you might want to clean a bit of
the egg off its face from the past debacle, shockingly made public
in the documentary "Who Killed the Electric Car?" --and only
exacerbated at its March meeting.

I can only conclude that CARB must feel like it is between a rock
and a hard spot: the state has given it the charge of trying to
clean the air, yet its most outspoken "automotive expert," Dr.
Sperling, suffers from a blatant conflict-of-interest by his
professional and financial ties to the oil and auto companies that
fund his "Hydrogen Pathways Program" and "Institute of
Transportation Studies" at UC Davis.

What is sorely needed is for CARB to change tack completely. It
needs to simply assure that citizens are given every option
available, and then let the free market work its magic. More
specifically, it needs to forget about percentages (like before)
or numbers and different colors of "credits" (like now). The ZEV
mandate should simply require that, by 2012, the franchised
dealers of all the major auto manufacturers licensed in California
(and I would lower that "threshold" to include companies like
Mitsubishi, Subaru, Volvo, etc.) must comply with these
stipulations:

* They must have a ZEV vehicle in their showrooms, and at least
two more on the lot for customers to test drive at any given
time.

* Those ZEVs must be capable of a top speed of no less than 80
mph.

* They must have an emissions-free, EPA certified range of no less
than 100 miles.

* They must meet federal safety standards.

* They must cost no more than 125% of the average base price of
all the models in the same "class" sold by the parent company in
the previous year.

* They must be deliverable to customers who purchase them within
at least a 60-day period.

* For its part, CARB, with the help of the governor and the
legislature, will establish the very best government incentives
available to those who purchase the ZEVs to help offset their 25%
higher price tag (say, for example, tax deductions, waived
registration fees, no sales tax, carpool lane access, etc.,
etc.).

* What if the car manufacturers do not comply (again)? Suppose
they once again claim that they can't develop and produce the ZEVs
fast enough for their dealers to meet the 2012 deadline? Then
provide legal protection to the dealers so that they secure their
ZEVs from other sources without losing their franchises.

* And if the dealers do not comply? Then the state levies a hefty
fine on them, which increases every month, and after 6 months
revokes their business licenses until the requirement is met.
Period. THAT will get the auto companies moving, believe me. They
might not listen to CARB, or even to us consumers, but they most
certainly will listen to their own local dealers!

I do not think that such a mandate is unreasonable. After all, the
EV1 and the RAV4-EV were capable of that same speed and even
greater range back in 2002, so surely car manufacturers can do
even better nowadays. In point of fact, as you know, Tesla is
already producing in California its Roadster, with a 221-mile,
emissions-free range, and Governor Schwarzenegger has spearheaded
incentives so that the company can build its next all-electric
sedan, the Model S, in California as well. Aptera will start
selling its Typ-1e in November out of Carlsbad. Mitsubishi will
start testing its iMiEV in California in the next few months, and
has announced that it will go on sale one year earlier than
originally projected. Th!nk has set up offices for North America
in Menlo Park and will anticipates selling its City by 2009.
Phoenix will start selling its SUT and SUV models to fleets by the
end of this year. Subaru is even now testing out its R1e with power
companies in this country. ZENN has announced that it intends to
start selling its cityZENN by the end of 2009. Nissan has
committed to also produce an EV by 2010.

In short, with all these manufacturers jumping on the "green"
bandwagon, there is no longer ANY excuse for CARB not to implement
the mandate I have outlined above. It members will probably want to
debate the numbers suggested (range, speed, cost, etc.) to settle
on a definitive requirement, but the principle is much more sound
than anything CARB has attempted to mandate in the past. After
all, California has no authority to dictate to auto manufacturers
with factories in other areas, but it most certainly has power
over what the local dealers must provide inside the state's
boundaries. CARB needs to focus its energies where it has real
influence.

What kind of ZEV those dealers wish to provide should be left
entirely up to them --be it a battery electric car, a hydrogen
fuel-cell vehicle, a plug-in hybrid, or even one powered by a
flywheel or compressed air or a solar panel-- as long as it
produces _ZERO_ emissions for at least 100 miles. No more of CARB
favoring one technology over another: let the technology itself
decide.

And no more of this lame "no customer demand" excuse from the auto
manufacturers. If customers do not even KNOW about the option, if
they can't SEE it and TEST DRIVE it, how can they demand it? The
above ZEV mandate would assure that customers DO know --and can
decide accordingly. Get the ZEVs in the showrooms! Take advantage
of the free market system instead of trying to thwart it.

Do the RIGHT thing!

Mark D Larsen