On June 4, 2018, the Association of Global Automakers submitted the attached comments on the California Labor and Workforce Development Agency’s (LWDA) and the California Air Resources Board’s (CARB) Concept Paper for “Potential Procedures for Certifying Manufacturers’ Fair Treatment of Workers for Clean Vehicle Rebate Project (CVRP) Eligibility.”  Global Automakers' comments highlight the important role the CVRP plays in supporting California's market for electric-drive vehicles, and caution the State against implementing policies that would harm the future growth of the electric vehicle market--as the implementation of this Concept Paper would.  The comments also outine Global Automakers' concerns about the workability and the legality of certain aspects of the Concept Paper, such as: (a) the fact that it requires automakers to submit to the LWDA a significant amount of information and documents without articulating how that material would be relevant to its “fair and responsible” certification, (b) the Concept Paper could be read as denying a "fair and responsible" certification because of an alleged violation of the National Labor Relations Act or for conduct arising outside of California, in contravention of well-settled constitutional principles and U.S. Supreme Court precedents, and (c) that whatever certification procedure is adopted should be based entirely on a manufacturer’s self-attestation that it has complied with all relevant and applicable U.S. federal and California wage, labor and worker safety laws with respect to vehicles manufactured in California, and a confirmation by the LWDA that that attestation is correct and remains so.