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I strongly urge the board to consider the following changes to the
ZEV mandate.

1) Increase not decrease the minimum number of Pure ZEV required
in Phase III (2012-2015);

2) Eliminate the substitution of Pure ZEVs with Enhanced
AT-PZEVs;

3) Set the minimum ZEV requirements on a yearly basis rather than
for three years, thus preventing manufacturers from getting an
additional three year grace period and eliminating “blackout”
years;

4) Change the carry forward provision of gold ZEV credits earned
by any manufacturer that exclusively manufactures pure ZEVs to
expire 3 years from the date of transfer to another manufacturer.

With these actions the Air Resources Board will once again be able
to recapture its credibility and assume the mantle of leadership in
advancing the goal of true zero emissions transportation in the
state of California and beyond.

Kevin Harney