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The electrification target commencement date of 2023 and target of
2% eVMT are unreasonably late and low, as is the increase to 90%
eVMT in 2030, considering both the rapid evolution of the
California market, and what is possible for the major TNCs. They
have the stock valuation to be able to subsidize and finance or
underwrite leases or purchases of high-all-electric-mileage PHEVs
today, and 300+ mile range BEVs by 2024, and to fund and build or
contract for charging infrastructure that includes stationary
batteries and solar canopies to relieve loads on the grid and
minimize capacity charges. Not only is it possible for the TNCs, it
is highly beneficial for the largely minority and
disadvantaged-community-member drivers. 
Context: I support the next proposed section ("The Standard would
require ...") as methods of gaining compliance by the TNCs, but
both my calculations and those of Tony Seba show that we can and
probably will get to near-zero ICE cars being sold after 2024 or
2025, through the introduction of disruptive technologies which are
now working under financial handicaps due to private investment
market conditions. The standards should be structured as temporary
floors, which will be raised as products come to market which can
disrupt the market, or portions of it. 
In other words, best feasible technology should be the floor, and
track breakthroughs closely, accompanied by non-dilutive funding
and low-cost financing of small technology companies. As a floor,
it should require commercial vehicle manufacturers to adopt these
technologies as rapidly as is technically possible, and would
reward those who lead the way with subsidies greater than those for
companies demonstrating inertia.
In addition, in order to 1) greatly accelerate adoption of BEV
drive trains compared to the normal rate of turnover, and 2)
maximize improvements in quality of life and prosperity for
disadvantaged and minority communities, funding should be made
available for systematic development, production and distribution
of conversion kits for all vehicles in wide use, of any age, and
incentives and BEV charging infrastructure development support
should be provided. By 2022 conversion kits should be available for
medium to heavy duty trucks and buses, with at least twice the
range per pound of today's lithium battery packs. Those creating
these systems can also be encouraged and rewarded for developing
kits for the vehicles most used, and / or creating the  most GHGs,
in the existing TNC fleets. As with new vehicles, stationary
batteries and solar canopies, managed by advanced energy management
systems, can minimize the life cycle cost of energy, and enable
fleets and independent operators to rely on solar energy and
least-cost grid electricity to continue to drive their repowered
and refurbished trucks until they are ready to retire. It will even
enable repowered cars and trucks with drivers to compete
economically with new autonomous fleet vehicles, greatly improving
prosperity and overall well-being in disadvantaged,
pollution-impacted, and minority communities. The proposed standard
should be overtly and tightly linked to the other programs that
work for the State goals alluded to in my statement.

"The Standard would require a transportation network company to
meet a GHG target of 252 g CO2/PMT in 2023, decreasing to 0 g
CO2/PMT in 2030.  Transportation network companies would have
various options to reduce company-wide GHG emissions to the annual
targets, including improving fleet-wide fuel efficiency, reducing
VMT by increasing shared rides, reducing VMT by reducing deadhead
miles (i.e., those miles driven without a passenger), and earning
CO2 credits by investing in active transportation infrastructure or
by providing integrated fare services to connect riders to mass
transit."