Comment Log Display

I am writing to comment on the proposed test procedures for plug-in
hybrid electric vehicles. I understand that for a company which
would market conversions from ordinary hybrids to plug-in hybrids,
there are proposed to be tiers defining escalating testing
requirements, based on the number of converstions sold. This seems
like a good approach. However, the current proposal, that Tier 1
would be only applicable until 10 conversions were sold, does not
appear workable.

The few, small and yet highly innovative conversion companies
would be hampered by both the high cost of the Tier 2 requirements,
which would need to be amortized over only 10 Tier 1 sales, and
also by the need to cease innovating and lock in on a design at
this early stage. Neither of these are desirable, especially in the
current credit market in which these small companies would find it
nearly impossible to obtain capital in the early stage of their
operation. As a co-founder of a silicon valley product design firm,
I am well aware of the difficulties faced by small businesses with
great ideas.

Please amend the proposal to raise the Tier 1 definition from 10
conversions to 100 or more.

Thank you for your support of the exciting new developments now
being led by individuals and small businesses who are injecting a
great deal of creativity into the U.S. automobile market. The
potential benefit of the rapid development of PHEVs on global
warming pollution, both directly in reduced tailpipe emissions and
indirectly through grid stabilization, is too large to miss. The
effect on the economy of California and the United States is also
potentially very beneficial.