Submission Number: 8849
Submission ID: 61866
Submission UUID: 481ed5cd-afa4-4ca8-a0d7-42b876f4b55e

Created: Mon, 07/13/2026 - 14:38
Completed: Mon, 07/13/2026 - 14:41
Changed: Tue, 07/14/2026 - 07:45

Remote IP address: 18.68.29.84
Submitted by: Anonymous
Language: English

Is draft: No

Flagged: Yes
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Submitted Comment
Gil Tal
Electric Vehicle Research Center, University of California, Davis
Proposal to require on-board fuel and energy data collection and annual manufacturer reporting (EU OBFCM-equivalent), all plug-in vehicles first; responds to GHG Seeking Input (slide 52), ZEV data standardization (slide 35)

Please find attached comments from the Electric Vehicle Research Center at UC Davis. We propose that the Drive Forward regulation require annual manufacturer reporting of the standardized lifetime fuel and energy counters California vehicles already store under 13 CCR 1968.2 and 1962.5, modeled on the EU's On-Board Fuel Consumption Monitoring program, beginning with all new plug-in vehicles and extending to the remaining light-duty fleet. The attached letter specifies the vehicle capability and reporting requirements, documents that manufacturers covering 99.1 percent of U.S. PHEV sales since 2021 already operate this pipeline in Europe, explains the structural limitations of Smog-Check-based data collection, and presents the proposal as a lower-cost alternative for the SRIA

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