Comment Log Display

Team,

We are a Volvo, Isuzu & Hino & Workhorse Dealer in the state of New
York. We have sold 1 of the total 34 total class 8 BEV's in the
state of New York, and the first Northeast Dealer to be BEV
certified. We 100% support the ACT rule, but not to the extent of
loss of jobs & businesses in New York. Here, at Burr Truck, we are
the only Public Charging System in the state with a 125 KW DC Level
3 Fast Charger that allows trailer parking to charge two trucks. We
are asking for a 2 year pause in the state of New York because our
state has made no investments to support trucking for BEV's. That
being said, how can what is good for California be good for New
York today knowing these facts. Can New York get a two-year pause
approved by California and start at ratio's for the 2025 in 2027 as
opposed to the 2027 ratio's. meaning 7% in 2027 vs 15% as mentioned
in the below for class 7-8 tractors & rigid trucks. The OEM's place
dealer under allotments because they never have nor ever will have
enough ZEV credits to ever catch up. Although this rule is based
upon OEM's not dealers, the OEM"s have no choice to place dealers
in ACT states under allotments to get enough credits. This is and
will make dealers go out of business because dealers sell trucks
not OEM's. Example We had 200 trucks sold in 2025 but will only get
13 trucks now. We know that wasn't the intent of Carb ACT to makes
dealers go out of business. Since there are significant
infrastructure deficits to support ACT in New York State, should
there not be a bilaterial support given to meet the goals? This
would be a more commonsense approach to support job growth in the
state and clean the air with more ZEV's by working together united
for a greener and more sustainable approach.



Model Year 	Class 2b-3 	Class 4-8 	Class 7-8 Tractors 
2025 	7% 	11% 	7% 
2026 	10% 	13% 	10% 
2027 	15% 	20% 	15% 
2028 	20% 	30% 	20% 
2029 	25% 	40% 	25% 
2030 	30% 	50% 	30% 
2031 	35% 	55% 	35% 
2032 	40% 	60% 	40% 
2033 	45% 	65% 	40% 
2034 	50% 	70% 	40% 
2035 and subsequent 	55% 	75% 	40% 

Respectfully,