Comment Log Display

I am responding to the request for comments on the proposed
Amendments to the Advanced Clean Trucks regulation and the
ZERO-Emission Powertrain Certification Test Procedure.
The proposed amendments to apply these regulations to vehicles with
a GVW of 8500 or higher with no exceptions for vehicles that are
typically driven for less than 8,000 miles PER year seems onerous
and discriminatory to California residents that own and operate
Recreational Vehicles. 
The typical RV owner drives less than 8,000 per year (many only
2,000-5,000 miles per year) as the primary PURPOSE of such vehicles
is to drive a few hours away to a state park, national park or
other non-urban setting and STAYING for several days at a time.
Unlike large 18 wheelers (Semi tractor) that typically drive
80,000-110,000 miles PER YEAR, RVs are not purchased or used with
the intent to log lots of miles. The PRIMARY purpose of a SEMI
Tractor is to drive AS MUCH AS POSSIBLE to move cargo.
I beg you to rethink the impact of a blanket BAN on all on-road
vehicles over 8500 GVWR. Consider the PURPOSE of a vehicle in
determining the IMPACT on our air. Absent an exemption for RVs,
please consider an exemption for RVs that are equipped with solar
panels AND a CARB compliant generator as these features are
intended to reduce any impact on the environment when stationary.
We, as consumers, need more clarity from CARB as to how this
impacts the RVs that we purchase. I personally placed an order for
an RV back in APRIL 2023 and have yet to receive it due to the
backlog of this manufacturer.
Thank you for your consideration.