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 Dear ARB, Azure Dynamics is pleased to offer the Transit Connect
Electric commercial vehicle with our partner Ford Motor Co. to the
California Fleet market.

The Transit Connect Electric is focused on the commercial fleet
business and has a 1000lb. payload capability. It is ideal for
fleets large and small with a need for urban or neighborhood radius
based delivery.

Range is 60-80 miles per charge depending upon payload and terrain.
It has a top speed of 75 so highway driving is not an issue and
best of all it is zero emission technology.

We have been demonstrating the vehicle to fleets like FedEx, UPS,
Frito Lay, Service Master, Hertz, LADWP,UC Campuses, PG&E,
Enterprise, and Apria with very limited success.

The Transit Connect Electric has been incentivized via the CVRP
program at $4000 level along with Nissan Leaf as the other EV
within the program. We believe since the Transit Connect BEV is
focused on the commercial market it should not be included in the
CVRP which is primarily a consumer based personal use program. For
the Transit Connect Electric, the CVRP level has not been
sufficient for fleets to adopt EV technology.

We believe that the Transit Connect BEV needs to be placed in the
HVIP program with an incentive at the $15,000 level such as an
8501lb.-10,000lb. GVWR commercial zero emission vehicles would be
currently.

Additionally some fleets are not able to take advantage of the
$7,500 Federal EV Tax credit due to a very low tax liability or
being a public fleet. Also many leasing companies do not have an
appetite for the EV tax credit due to how their company is
structured.

This leaves the CVRP program to incent the commercial vehicle
marketplace and it has not been enough to attract the volumes we
thought would happen. We wanted to allow enough time to see if the
CVRP program would be enough and with many customer demonstrations
and conversations we have learned it is not.

In summary, if we can ask the ARB to consider moving the Transit
Connect Electric from the CVRP program to the HVIP program and use
the $15,000 zero emission vehicle level, change the 8501-10,000 lb
GVW to include the Ford Transit Connect with a 5,000 lb GVWR we
will be able to displace many ½ ton, ¾ ton vans and pick-up with
all electric Transit Connects.

Thank you!

Regards,

Chris Abarca
Director of Sales
Azure Dynamics