This is the first of 2 comment letters I will be submitting to
CARB for the Advanced Clean Car II Regulation.
I request CARB staff respond to the following itemized comments,
as required by CEQA and state and federal regulations pertaining to
response to public comments.
1A) EPA requires the state must demonstrate a "need" for the EPA
emission waiver this proposed regulation is operating under.
2A) The state's EPA waiver requires the state to demonstrate the
emission reductions in the proposed regulation are "needed" to meet
federal air quality standards.
3A) The state's EPA waiver requires the state demonstate that it
has exhausted all emission reduction alternatives available to the
state before the state implements the motor vehicle emission and
fuel economy standards found in the proposed regulation.
4A) The state does not "need" the motor vehicle emission
and fuel economy standards found in the proposed regulation
to achieve its federal air quality standard goals.
5A) The state can achieve its federal air quality standards
goals by reducing Vehicle Miles Traveled (VMT) by 50% from a 2014
baseline, while implementing the motor vehicle emission and fuel
economy standards proposed during the Trump Administration.
6A) By federal law, the state must be technology neutral when
preparing and implementing the proposed rule. The state is not
allowed to prepare or implement the proposed rule if it gives an
advantage to or inhibits the use of any technology that can be used
to meet the federal air quality standards goal of the proposed
rule.
Thank you,
T.Becker Power Systems
Tom Becker, owner
Buellton, CA