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Hold on a minute here! Now that I have looked at CARB's tables more
closely, do I understand its ZEV "tiers" correctly? In which the
higher tiers have "refueling" mandates?! If so, CARB continues to
impose an inherent bias against electric vehicles from the
get-go.

For example, a Tesla Roadster uses ~265 watts/mile on the road,
which requires ~308 watts/mile at the plug. This means that, for
the Type III Tier, you would have to load over 29 kWh (100 miles)
into the Roadster in under 10 minutes. Ridiculous! How many
high-capacity charging stations has the state of California
provided that are capable of such a recharge? Not one, that I am
aware of. Unless and until it does, the state has no business
mandating such a time limit.

Moreover, no EV on earth is going to qualify as a Type IV. Even
the Roadster, for instance, would have to recharge in 10
minutes... over 58 kWh of electricity (190 miles)!!! Impossible!
CARB has got to be kidding to limit the definition of a Type IV
ZEV like this! 

The only conclusion anyone can draw from these "refueling
capabilities" is that they represent a blatant bias toward
hydrogen --and those who want to _sell_ hydrogen to consumers
rather than letting them get their "fuel" at a cheaper price from
the electric grid or even --gasp!-- for free from solar panels on
their roofs.

What in the world is CARB thinking? I thought you were supposed to
be advocating ZERO-emissions. Period. NOT showing prejudicial
favoritism of one source of energy over another.

CARB needs to eliminate the refueling requirements and focus
exclusively on range to distinguish one Type of ZEV from another.
ANY vehicle that can travel over 100 miles without refueling
should qualify as a Type III, and ANY vehicle that can travel over
200 miles without refueling should qualify as a Type IV --no matter
how long that refueling takes, 10 minutes or 4 hours!

Think about it: a Tesla Roadster, now has a newly verified range
of 244 miles per charge. A driver could thus leave Los Angeles at
8:00 in the morning, stop for a leisurely lunch in San Luis Obispo
at noon while charging the batteries at an RV Park, continue
driving at 4:00 and arrive in San Francisco at around 8:00 in the
evening. Surely CARB can see that this is more than sufficient in
both range and recharge rate for a vehicle that produces zero
--ZERO!-- emissions.

Isn't that CARB's prime directive? To monitor and protect _air_
resources? When did it get into the business of mandating _time_
resources via refueling capabilities?

Please, PLEASE finally do the right thing. With more and more auto
manufacturers developing electric vehicles, if CARB continues down
this path it will only end up with more egg on its face.