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First Name	Bob
Last Name	Yuhnke
Email Address	bob.yuhnke@outlook.com
Affiliation	Elders Climate Action
Subject	Advanced Clean Cars II
Comment	Elders Climate Action submitts written comments requesting that the Board revise the ACC II rule to achieve the emission reductions needed for attainment of the ozone NAAQS in California's ozone nonattainment areas designated as "extreme" under the CAA. The proposed rule is not adequate for attainment. We ask that the rule be revised by 1) advancing full implementation of the 100% sales requirement from 2035 to 2030, and 2) adopting a rule to require the gradual phase-out of internal combustion engine vehicles in extreme nonattainment areas by 2035. Modeling results of NOx emission reductions to support this request and a legal analysis showing that the phaseout of ICEVs is required under the CAA are included in the written comments submitted today.
Attachment	https://ww2.arb.ca.gov/sites/default/files/BARCU/barcu-attach/509-accii2022-UWNVYVRlWTxRegg4.pdf
Original File Name	2206-09 Elders Climate Action COMMENTS ON ACC II.pdf
Date and Time Comment Was Submitted	2022-06-09 09:15:53

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