Comment Log Display

Dear California Air Resources Board Members and Staff, 

We appreciate the opportunity to provide comments on the
Volkswagen’s (VW) Appendix C zero emission vehicle (ZEV) Investment
in California. 

Green Commuter, a minority-woman-owned Benefit Corporation
headquartered in California, has developed an innovative system
that utilizes a fleet of 100% zero-emission vehicles (ZEV) to
provide a combined service of vanpool, car sharing and/or fleet
replacement to maximize efficiency, decrease the cost of commuting,
and increase ZEV access for all consumers in California. The Green
Commuter model operates vanpool vehicles as public car share and/or
fleet replacement vehicles during non-commute hours. This
integrated approach reduces costs and increases benefits—improving
zero-emission mobility, reducing emissions, and alleviating traffic
and parking issues.

Mobility services that maximize occupancy and use of the vehicles
are ideally suited for electric vehicle technologies. Utilizing the
electric vehicles for multiple forms of mobility services –
including vanpooling, car sharing and fleet replacement maximizes
efficiency and increases the benefits of zero-emission technology. 
Zero-emission vanpooling, with the combined car sharing/fleet
replacement and necessary supporting EVSE infrastructure, increases
awareness and access for more Californians to ride in an electric
vehicle and help reach the State’s ZEV deployment and air quality
goals, including the Governor’s ZEV Action Plan, SB 350, SB 1275,
and SB 535.

Green Commuter supports the Air Resources Board (ARB) four guiding
principles for the Consent Decree Appendix C. Our specific comments
include: 
• We support the installation of ZEV infrastructure, specifically
DC fast-chargers at workplaces and Level 2 chargers at Park and
Ride Lots or other vanpool pick-up locations. We respectfully
request expanding eligibility to include Level 3 mobile charging
stations to allow more EVs to access fast charging and improve
zero-emission vehicle scalability.  Mobile chargers provide the
ability to charge during off-peak periods and utilize the batteries
to charge vehicles during peak periods, reducing the strain to the
electrical grid and lowering costs. 
• We strongly support the inclusion of programs or actions to
increase public exposure and/or access to ZEVs without purchase or
lease of a vehicle. Specifically, we support zero-emission car
share and rideshare services, and respectfully request the
inclusion of zero-emission vanpooling in the guiding principles for
Appendix C to include funding for zero-emission vanpooling in all
four investment plans over the next ten years which will maximize
opportunities for California residents of all economic means to
ride and drive a zero-emission vehicle.  
• We applaud the inclusion of a Green City to provide key
demonstrations of zero-emission car sharing services and
respectfully request the inclusion of zero-emission vanpooling in
all four investment plans over the next ten years to further ZEV
access. 

Thank you for the opportunity to provide comments on the VW Consent
Decree Appendix C. We look forward to continuing to work together
to help carry out the goals and initiatives of increasing public
and equitable access to zero-emission vehicles for consumers in
California.

Sincerely, 
Leslie Graham - Director, Grants and Partnerships
Gustavo Occhiuzzo - Chief Executive Officer