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California has the opportunity if not the responsibility to lead in
reducing car emissions.  The world is not on track to prevent
dangerous levels of global warming (see Climate Central and
Nature). California must pursue more aggressive climate policies,
both to reduce its own emissions and to catalyze mass adoption of
new technologies necessary to avoid catastrophic climate change.

The latest generation of plug-in hybrids and battery electric
hybrids are affordable enough that California could massively
increase the rate of adoption. The current rules set a 4.5% ZEV
credit requirement for 2018 and 22% requirement for 2025. Toyota
could meet a 45% TZEV requirement in 2017 if it sold its $22,600
(after federal rebate) plug-in hybrid to everyone buying a Toyota
sedan. In comparison, current Toyota sedans cost $21,000 on
average, require over $12,000 for gasoline over their useful
lifetime, and cause $3,000+ in public health externalities,
according to the American Lung Association.

I encourage CARB to take the following actions
- A more rapid increase in ZEV requirements in light of the
favorable economics presented above
- A lifetime pollution fee on new internal combustion vehicles so
that public health damages (externalities) are priced into car
sales. See the American Lung Association's report.
- Introduction of a ZEV mandate by vehicle class to encourage
development of zero emissions pickups and SUVs.

Thank you for the opportunity to weigh in on this important topic.