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Tesla's $169 million in ZEV credits may push California to boast goals.

California may make it harder for Tesla, another automakers to earn zero-emissions credits.

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Automakers are tasked with meeting California mandate with more plug-in vehicles.

California's clean-vehicle rules, which are followed by nine other US states, will get stricter in 2018.

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One Washington, DC-based startup is looking to create a market for trading automaker "credits" that will allow gas-guzzler makers to "meet" stricter US fuel-economy requirements during the next few years, Automotive News reports.

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