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Dear ARB,

Some of the ISOR proposals tend to motivate Plug In Vehicles
(PHEVs) at the expense of BEVs (battery-electric vehicles),
implying a choice that reflects the Board's view that BEVs are
significantly less near-term than PHEVs.

I believe that it is a major mistake to pit these two
complementary approaches against each other, requiring that
incentives for one come from the allocations of the other. And the
perspective flies in the face of the reality that several major
carmakers have announced their intentions to mass-produce BEVs
within the next five years (along with PHEVs).

Here's what Plug In America, CalCars and other organizations are
calling for: 

-Require the full 25,000 ZEVs that automakers had promised for
2012-2014; 
-Create a separate requirement for plug-in hybrids that lets them
replace the dirtiest vehicles in CARB's regulations, rather than
the cleanest ZEVs; 
-Incentivize plug-in hybrids that have the most on-board
electricity storage.

Please continue to lead our state by strengthening your staff
proposal and getting more electric cars on the road. 
Thank you.