Submission Number: 7371
Submission ID: 51286
Submission UUID: 4dd2945f-e72f-4498-8e50-535df3df0e91

Created: Thu, 08/14/2025 - 11:22
Completed: Thu, 08/14/2025 - 11:23
Changed: Thu, 08/14/2025 - 12:32

Remote IP address: 73.173.225.40
Submitted by: Anonymous
Language: English

Is draft: No

Flagged: Yes
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Submitted Comment
Levi Tillemann
Ample
Request for Regulatory Reforms to Support Battery Swapping in ACC III

Dear Air Resource Board Staff,

On behalf of Ample, Inc., I am sharing our formal comment to the California Air Resources Board regarding the Advanced Clean Cars III (ACC III) rulemaking process.

Ample is a California-based clean transportation company employing more than 200 people in the Bay Area and a recipient of CEC funding. Our comment outlines how specific provisions of the existing ACC II regulations — the 200-mile minimum range requirement and mandatory DC fast charging — unintentionally exclude battery swapping from California’s zero-emission vehicle program.

Battery swapping is a proven, globally adopted technology that can repower EVs faster than any plug-in charging standard, at lower cost, and with greater consumer accessibility. By adopting technology-neutral performance standards, California can expand consumer choice, accelerate emissions reductions, and support homegrown innovation.

We respectfully urge your offices to consider the recommendations outlined in the attached memo and to ensure ACC III fully accommodates battery swapping as a compliance pathway.

Thank you for your leadership on California’s clean transportation future.

Sincerely,

Levi Tillemann, Ph.D.
Vice President for Policy and International Outreach
Ample, Inc.

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