Comment Log Display

November 4, 2021

Peter Christensen
Manager, Innovative Heavy-Duty Strategies Section
California Air Resources Board
1001 I Street, Sacramento, CA 95814
Peter.christensen@arb.ca.gov  916-322-1520

RE: Comments on Proposed Changes to the Hybrid and Zero-Emission
Truck and Bus Voucher Incentive Project Program as Presented in the
Fiscal Year 2021-2022 Funding Plan

Dear Peter:

ROUSH CleanTech (Roush) appreciates the opportunity to provide
comments on the California Air Resources Board's (CARB) draft
Fiscal Year (FY) 2021-2022 Funding Plan and specifically on CARB's
Clean Truck and Bus Voucher Program (HVIP). CARB plays an important
role in driving and supporting fleets to adopt alternative fuel
technologies both in general and ahead of regulatory deadlines.
Roush acknowledges the benefits the transportation industry reaps
from such support and will continue to support CARB while providing
important real-world feedback- something we have a lot of
experience with, having nearly 40,000 vehicles operating in our
communities and more than a billion miles driven. 

Roush is an advanced clean transportations solutions company
focused on developing innovative and reliable clean fuel system
technology. As an original equipment manufacturer (OEM) and
approved HVIP equipment provider, Roush offers its perspective on
proposed changes to HVIP. ROUSH has been a proud participant of the
HVIP program and has continued to support CARB in its endeavors to
encourage the expansion of zero-emission heavy-duty (ZE HD)
vehicles in California. HVIP allows for market growth that would
otherwise not be possible and the opportunity to comment proves
that CARB is committed to designing programs to benefit the most
parties the greatest amount.

ROUSH is concerned that limiting eligibility to only those fleets
with less than 100 trucks in 2023 and 50 trucks in 2024 will
disrupt the growing success of HVIP and the ZE HD market,
counteracting the program's intent to "drive commercial technology
transformation." Our customers are telling us that capital costs
are the biggest impediment to the large-scale adoption of ZE HDVs.
Large fleets are currently leading the way towards a clean electric
transportation future, in part because they possess the capital to
do so. They are also able to take on a level of risk that smaller
fleets cannot. Thus, the exclusion of large fleets from future HVIP
eligibility may not translate to an increase in small fleet's
ability or interest in adopting electric technologies. However,
what is certain is that this new proposed requirement will impede
large fleets with available capital who have yet to widely adopt
EVs and wish to scale their ZE operations. Continued successful
deployments by large fleets is critical in driving down prices,
increasing exposure, and establishing scalability for smaller
fleets. 

Over the last several years, HVIP has successfully created momentum
for fleets to transition away from petroleum-based fuels towards
electric alternatives. Early and large-scale adopters of electric
technologies still have a role to play in making the HD electric
space more accessible to small fleets at a lower cost and a lower
risk. The market benefits from model deployments of all size fleets
which provide a variety of best practices and lessons learned for
others to study. 

Informed by experience manufacturing clean vehicles, communication
with customers, and previous engagement with HVIP, Roush
appreciates the opportunity to share input with CARB on proposed
changes to the HVIP program. Roush is hopeful that CARB will
consider the possible negative consequences of limiting eligible
fleet size for HVIP, effectively removing large fleets from the
opportunity to participate. Thank you for the opportunity to submit
comments on CARB's draft FY 2021-2022 Funding Plan. Roush looks
forward to continued engagement with and improvements to the HVIP
program as the HD transportation industry further adopts
electrification. 

Sincerely, 


Chelsea Jenkins
Vice President, Government & Industry Relations
Roush CleanTech