Comment Log Display

HD/IM Adoption

On behalf of my family and grandchildren I want to thank Chair
Randolph and the CARB board for the legacy work to clean up our
air. As a child of the 60's I lived through very poor air quality.
Incrementally I have invested thousands of dollars over the years
to partner with CARB in reducing vehicle air pollution.

Zero emission vehicles provide us the best choice to deliver the
highest air quality to our children. But I fear in the single
choice to go electric and the constant assault on near zero
emission alternatives overlook the value of biomass liquid fuel as
biodiesel, renewable diesel and renewable compressed natural gas
which provide significant emission reductions when run in new
technology engines. HD/IM will be putting unnecessary burdens on
our children and economically challenged. It is these individuals
who will be most affected by the unavoidable increases in cost of
goods and transportation. 

HD/IM as it will be presented today will cripple the movement of
goods in CA. and is another layer of regulation in a cornucopia of
existing regulations that is unnecessary. The use of existing
regulations to monitor and enforce truck operational standards is
sufficient. 

To replace the estimated 1.6 million HD trucks in CA by 2030 would
require 685 trucks a day be produced to meet the 2030 deadline and
256 trucks a day to meet the 2045 requirement. These facts along
with our power grid estimated need to be a minimum of 4 times
larger than we have today pose a huge challenge ahead for all who
value clean air. 

I would ask that CARB staff continue to hold additional HD/IM
Workshops along with developing a larger pilot study over the next
two years to assure that families and freight costs will not become
victims of HD/IM. This additional time will allow CARB time to
validate studies regarding emissions reduction.  Ultimately
allowing advanced technology to assist in developing a smoother
transition to electric/hydrogen vehicle use.  

As a lifelong partner in the development of cleaner air across CA.
We have come a long way since the 60's. The necessity to adapt
HD/IM at this time needs more time to mature... to assure the best
pathways are chosen and new technologies have time to be
implemented. 

Thank you