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We appreciate the efforts of CARB staff to prepare the scooping
plan update including looking ahead to long term targets.

We encourage you to build on California’s leadership reducing
transportation emissions by including action items for passenger
vehicle in-use efficiency in the scoping plan update. We believe
that estimates in the original scoping plan (p.C-64) of $750
million annual consumer savings and 3 million metric tons per year
of GHG reduction are very achievable.

In particular we recommend that the update include a pathway to
improve deployment of fuel efficient passenger vehicle replacement
tire and engine oil technology, which were included as part of
measure T-4 in the original scoping plan. The scoping plan update
should recognize the benefits of exploring both incentives and
standards. The discussion draft update defers to possible action by
the Department of Transportation (p.25) for tires. This program is
several years overdue and would be limited to ratings and customer
information, which are helpful but not likely to achieve the full
potential benefit of policies to promote low rolling resistance
tires. We also encourage including action items for similar efforts
for improved engine oil technology in-use. 

Thank you for the opportunity to provide suggestions for the AB32
Scoping Plan update.