On the one hand, Tesla says, “we strive to be a fair and just company,” that it complies with all California and federal labor regulations, and holds worker safety to be “a core value” of the company. On the other hand, Tesla contends that it’s unfairly targeted by the state law and implies that the rule could drive it out of the state and keep other companies away.

Tesla first raised these issues last September, after the law was passed by the Legislature and signed by Gov. Jerry Brown as part of a budget measure dictating how income from the state’s cap-and-trade program would be spent. (The rebates are funded from that income.)

But matters are coming to a head now. On May 23, the California Air Resources Board and state Labor and Workforce Development Agency issued a joint “concept paper” detailing how they intend to put the rule into action. The public and interested parties were given until June 4, a little more than a week, to comment.

Tesla says in its 16-page brief against the concept paper that the proposed rule threatens to “compromise” the rebate program, “confuse consumers” and interfere with Brown’s stated goal of placing 5 million EVs on California roads by 2030.

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