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Dear Cap-and-Trade committee,

Thank you very much for inviting US Hybrid to attend the Los
Angeles workshop for the Second Investment Plan for Fiscal Years
2016-17 through 2018-19. We appreciate the state focusing
appropriations towards vehicle projects through CARB and CEC. The
combined efforts by both state entities have rightly been directed
towards curbing environmental pollution in disadvantaged
communities through zero emission (ZE) technologies. However, US
Hybrid feels there are several issues that need to be addressed by
Cap-and-Trade allocations.

Challenges posed by how the Cap-and-Trade funding is allocated:

1. Much of the ZE focus today is on light-duty vehicle (LDV)
projects still and not enough on medium- and heavy-duty vehicles
(MDV/HDV) in spite of the fact that that more than 23% of the
global warming pollution is attributed to MD/HD vehicles.  
2. Any ZE vehicle projects that are successfully funded by the
limited MDV/HDV pots are immediately handicapped by lack of funding
for MDV/HDV infrastructure.
3. Presently, OEMs are not fully committed to resources and
planning to support pre-commercial deployment of ZE technology.
State should be aware of this fact in ZE planning.
4. ZE goals for MDVs/HDVs are not clear enough. There is a lack of
state pressure through powerful mandates such as executive orders
for MDVs/HDVs.

Proposed solutions to meet above challenges:

1. State should push for greater emphasis on the potential for ZE
MDVs/HDVs to solve emission problems throughout all communities,
especially those with high local pollution concentration. Such
areas have been identified by CalEnviroScreen. 
2. State should consider widening the breadth of mandates for ZE
MDV/HDV targets.
3. State should consider allocating higher amounts to ZE vehicle
projects routes so that they can include funding for ZE MDV/HDV
infrastructure. This lack of funding limits the ability of ZE
MDV/HDVs of becoming widely adopted and re-introduces the
“chicken-and-egg” problem previously and still being faced by the
ZE LDV industry.
4. State should consider the 3rd party vehicle integrator model
instead of the OEM model for technology development. 3rd party
integrators can bridge this gap in both experience and their own
relationships with OEMs. This model would provide confidence for
OEMs and limit their fear of liability.
5. State should consider adding more language stating that ZE
projects will be support of local supply chain for emerging
technology companies and that such projects will ensure sustainable
products. The projects will service and support and growth of local
economy. This language becomes more important when considering
smaller 3rd party vehicle integrators and their supply chain
partners.
6. State should provide more language on service and support of
technology. Such activities are critical to new technologies. State
should have funding allocations devoted to such needs as either
explicitly called out in projects or in a distinct Operation and
Maintenance (O&M) pot, the latter of which is similar to what state
funding has provided for hydrogen station development.

Sincerely,
 
Abas Goodarzi

Abas Goodarzi, Ph.D., P.E.
President, CEO 
US Hybrid Corporation
445 Maple Ave., Torrance, CA 90503-3807
Tel: 310-212-1200, Fax: 310-212-1102