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The current ZEV Mandate regulation does not recognize the
importance of the 2015 to 2017 timeframe in being the crtical
period to go from technology development to pre-commercialization.
 The current regulation retreats from prior commitments that should
be increased to be considered as part of a commercialization step. 
It is proposed that the ZEV Mandate regulation with a higher number
of vehicles needs to be conceived in conjunction with a federal
demonstration program in order not to put the entire cash flow
burden on industry. Also, the cost to achieve AB 32 goals for 2050
needs all low or zero carbon options.  HFCVs when compared to these
alternatives can have relaxed targets than were considered by the
expert panel.  The Type IV HFCV needs to be defined with a range
of 300+ mile range and given a credit of 10.