The proposed low carbon fuel regulations are, in my opinion, not ambitous enough. Backloading and shooting for a target of E10 by 2020 are just not going to achieve the kind of sharp carbon emission reductions needed to stop global warming. They also don't account for the major impact the current, unprecedented economic recession will have on new car sales. The nation is now in the midst of an economic recession that is likely to severely reduce the number of new vehicles purchased over the next 5 years. Any plan to achieve carbon reduction from transportation fuels based on new electric, hybrid, plug-in hybrid, or increased efficiency conventional vehicles will not be supported by the economic conditions, absent major government subvention. Consequently, the state is likely to see the average age of automobiles on the road increase from 7 to 12 or more years as people postpone new car purchases because they can't get credit or simply don't have the money. This will result in a a reduction in or stagnation of increased fuel efficiency gains due to new vehicles put in service. There are over 32 million light duty vehicles on the road in California today and the vast majority of these use fossil fuel-based gasoline for fuel. The only way to significantly impact the climate crisis is for a substantial fraction of those vehicles to be converted to low carbon fuels quickly. ICE engines can run on E85 if the engine computer is reprogrammed or replaced, and any rubber gaskets or fuel lines are replaced by stainless steel. There are conversion kits on the market available for anywhere between $300 and $700. This is much more affordable than a $40,000 plug-in hybrid. However, due to CARB and EPA regulations from the mid-1990's, these kits cannot be legally sold in California unless the manufacturer submits a converted car of the exact make, model, and year to a $25,000 test. Many cars use the exact same engine configuration and drivetrain for multiple models and multiple years. In addition, many of the manufacturers of such kits are small companies that don't have the financial resources to submit thousands of cars to tests. My suggestion is that the low carbon fuels ruling be modified in the following way: - Move the goal for 2020 from E10 to E85. - Lift the regulation on conversions. Allow licensing of conversions for series of automobiles having the same drivetrain and engine configuration over multiple years and models, instead of specific make/model/year. - Provide financial assistance to the conversion manufacturers to reduce the cost of testing. - Require all licensed fuel retailers to stock E85 by 2020. Provide gradually decreasing incentives for retailers who offer E85 prior to 2015 and gradually increasing penalties after. - Modify the yearly vehicle registration fee so that it is based on carbon emissions rather than the age of the vehicle. Vehicles that use no fossil fuels (battery electric and fuel cell) should be free. Vehicles that get less than 18 mpg should face a hefty registration fee (something over $1000 a year). - Immediately institute a tax on fossil transportation fuels that gradually ramps up so that 100% fossil content fuels are the equivalent of $6.00 a gallon by 2015. Index the tax to the current world oil price so that it increases when the price of oil decreases and vice versa, in order to keep the price of fossil transportation fuels stable and increasing. This measure is necesary so that consumers experience the right price signals when they do decide to buy a new vehicle or consider a conversion. - Look into incentives to draw production cellulosic ethanol manufacturers to California, so that low carbon transportation fuels don't need to be shipped over large distances (which makes them less carbon-efficient).