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Greetings!

I'd like to offer the following views as an owner of a plug-in
hybrid vehicle.  A couple of concerns I’ve noticed in my
experience:

1) Not sure if this is part of the regulation, but please consider
any "pay-wall" barriers to public recharging stations.  For
example, many of the charging stations in downtown LA assess fees
on an energy equivalent basis that are more expensive than
gasoline.  To my knowledge, no one is reviewing these fees.  If
there are credits for these stations in this (or some other)
regulation, the credits should be valued according to the
favorability for the potential user (i.e., free charging stations
should have higher value than fee-based stations, and stations
charging more than gasoline should get zero credits).

2) If the regulation offers credits for EVs based on the potential
range capable under electric power, please consider whether or not
the ranges stated by manufacturers are for a fresh battery or for a
battery after many recharging cycles when its range is greatly
diminished.  For example, the EV I own had a much higher range off
the lot than it does now.  Consider also that even with the
existing purchasing incentives, the cost of ownership is still much
higher than for a comparable gasoline powered vehicle.  Battery
replacement costs (likely in my case) should be considered - these
will certainly wipe out any "advantage" from the state/federal
incentives.  Consider regulation if battery life is diminished by a
certain percentage within a certain time window (i.e., if range is
reduced by 40% within two years or 40,000 miles, battery
replacement costs should be borne by the manufacturers).

Thanks!