On Sept. 28, recently appointed member of the Air Resources Board Ron Loveridge, Mayor of Riverside, sent a huge "fan letter" about PHEVs to the Board http://www.calcars.org/­calcars-news/­534.html. In response, an ad-hoc coalition of six organizations sent the Board an endorsement and an amplification of that message. Here are the groups, followed by their memo, which offer a clear and very well spelled out plan for actions at the statewide level. The Board is expected to act soon on some of these issues. Natural Resources Defense Council American Lung Association of California Coalition for Clean Air Planning and Conservation League Bluewater Network California Electric Transportation Coalition

October 13, 2006
The Honorable Ronald Loveridge
cc: CARB Board Members; Catherine Witherspoon, Executive Officer

The undersigned organizations were delighted to learn that you initiated a discussion about Plug-In Hybrid Vehicles (PHEVs) at the ARB Board Meeting on September 28, 2006.

We agree that PHEVs are an exciting emerging technology that offers the potential for reduced emissions of greenhouse gases and criteria pollutants, and improved energy diversity. As you point out, there are pockets of activity on PHEVs that have drawn considerable interest and media attention, but to date there has been little concerted or coordinated effort at a California state level.

We commend you for putting forward your "Plug-In California" Initiative with the goal of establishing a significant, focused effort at the state-level in California to develop and commercialize this technology. We support your request that ARB staff work collaboratively with the appropriate stakeholders, including the Governor's Office, state legislature, auto manufacturers, battery technology entities, state agencies such as the CPUC, CEC, and DGS, Plug-In Partners, the electric utilities, environmental groups, and CAPCOA members.

We agree with most of the activities you outlined which would comprise your Plug-In California Initiative, and we recommend some additions. We recommend that the California state-level effort include the following components:

1. Dedicate at least $5 million of the $25 million ARB received through AB 1811 toward the Research, Development, and Demonstration of plug-in hybrids. To the extent possible, without holding back immediate-term demonstration projects, leverage these funds with the other activities being conducted by the U.S. Department of Energy, the automobile manufacturers, battery technology firms, Plug-in Partners, other State agencies, and the South Coast AQMD. Funding should also be provided for the development of appropriate testing and certification protocols for PHEVs. ARB should conduct or oversee testing of emissions, fuel consumption, and performance testing and evaluation of PHEVs (including the examination of the different operational modes under discussion in recent months).

2. Establish a state commitment to purchase PHEVs when they are commercially available for all of the State agencies fleets. The ARB should work with the Department of General Services (DGS) to identify the percentage or number of PHEVs which could reasonably be added to the State vehicle fleet in the future when such vehicles become available. The ARB should begin work now with DGS to streamline its procurement procedures for plug-in hybrid vehicles for state and local agencies. The ARB should also work with DGS to develop mechanisms and incentives to encourage local governments to identify the number or percentage of PHEVs which could reasonably be added to local fleets, and to procure such vehicles. In the near-term, state fleets should participate in demonstration projects with conversion plug-in vehicles or with manufacturer demonstration vehicles. The systematic collection of information and data that is possible in a fleet setting is extremely important to ensuring the rapid development of this technology.

3. Establish economically attractive off-peak electrical rates for PHEVs, and other mechanisms, to encourage off-peak charging. The ARB should work with the California Public Utilities Commission, investor-owned utilities, and municipal utilities to develop these rates and to establish testing/demonstration programs as needed to evaluate the impacts of plug-in hybrids on utility systems, encourage load management and energy efficiency, conduct information and education activities, and to maximize economic and environmental benefits to ratepayers.

These activities should also include additional demonstration and evaluation of "Vehicle to Grid" (V2G) opportunities, potential benefits, and costs. V2G has the potential of supplying the energy stored/generated by PHEVs to the electrical grid for voltage support or reducing on-grid electrical demand during on-peak periods. Not only does V2G hold the potential to benefit our electricity systems, but could provide a revenue source for PHEV owners that would make these vehicles more economically attractive.

4. Provide consumer and fleet incentives to buy down the vehicle's initial higher cost.

5. Establish a favorable environment for PHEV-associated businesses here in California; this should include battery technology companies as well as small volume vehicle manufacturers.

6. Prepare a California PHEV Development and Commercialization Plan, identifying barriers to development and commercialization, possible solutions, and goals/milestones within each of the phases outlined below. Phase I - Research, Development, and Demonstration. (50-2,500 vehicles) Phase II - Bridge to Commercialization. (2,000-20,000 vehicles) Phase III - Sustained Commercial Introduction. (50,000-100,000 vehicles)

7. Establish and execute a public information/education plan which shall provide information to the general public and fleet owners in California about PHEV characteristics, benefits to consumers and society, costs, safety, and operating/charging procedures.

8. Establish a California Plug-In Hybrid Working Group to assist in the development and implementation of the activities described above. The Working Group would be comprised of appropriate State agencies, local air quality management districts, interested auto manufacturers, research organizations, national laboratories, appropriate federal agencies, battery technology entities, Plug-In Partners, electric utilities, environmental groups and other stakeholders as appropriate.

We believe that these recommendations build upon and further strengthen the "Plug-In California" Initiative you presented to the ARB Board and staff on September 28, 2006. We hope you and the other Board Members, and the ARB staff, will consider these recommendations in future deliberations on this proposal. We stand ready to work with you and staff in the development and implementation of this important PHEV initiative.

We commend you and the other Board members for your leadership in this area.

Sincerely,

Luke Tonachel, Natural Resources Defense Council Bonnie Holmes-Gen, American Lung Association of California Tim Carmichael, Coalition for Clean Air Gary Patton, Planning and Conservation League Danielle Fugere, Bluewater Network David Modisette, California Electric Transportation Coalition