Comment Log Display

Dear California Air Resources Board, 

Please support the California Plug-In Hybrid conversion industry
by raising the Tier 1 ceiling to 100 vehicles up from the currently
proposed 10.

The proposed Tier 1 tops out at just 10 units sold, forcing very
young companies into Tier 2, where they must spend close to
$200,000 on laboratory emissions testing among other requirements. 
Capping Tier 1 at 10 sales effectively adds $20,000 to the cost of
each of those first 10 conversions. 

A better alternative would be to set the Tier 1 cap at 100
vehicles.  This would reduce the added cost of testing to just
$2,000 per vehicle, which is manageable if not ideal.  Capping Tier
1 at 100 sales instead of 10 will also give small companies time to
gain important customer feedback, to grow the market, and to refine
their designs before one version gets "locked in" as the only
CARB-certified design a company can sell.  

Raising the Tier 1 cap from 10 vehicles to 100 will not harm air
quality because the regulations in Tier 1 require a company to show
through detailed engineering analysis that its modifications to the
vehicles will only reduce air pollution, and never increase it.   

Plug-In Hybrids not only clean the air, they also help slow global
warming and break our addiction to oil, while fostering innovation
and creating good, green jobs here in California.  CARB should be
supporing California's Plug In Hybrid conversion companies, not
squashing them.

Please raise the California Plug-In Hybrid conversion Tier 1
ceiling to 100 vehicles up from the currently proposed 10.

Thank You.

Sincerely,

William Young