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Comment 66 for Proposed Advanced Clean Cars II Regulations (accii2022) - 45 Day.

First NameThomas
Last NameBecker
Email Addresstbeckerpower@gmail.com
AffiliationT. Becker Power Systems
SubjectProposed Advanced Clean Cars II Regulations
Comment

This is the second of 2 comment letter submitted by me for the Advanced Clean Cars II regulations.

 

I request that CARB staff reply to the itemized comments submitted, as required by CEQA, NEPA and any state or federal rules, regulations or statutes pertaining to responses to public comments.

AA1) The motor vehicle emission standards proposed in the ACC II regulation are stricter than federal EPA standards.

AA2) The state is using its EPA waiver to authorize the implementation of motor vehicle emission standards that are stricter than U.S EPA standards.

AA3) Before the state can implement motor vehicle emission standards that are stricter than U.S EPA standards, the state must show that it has exhausted all other emission reduction options available to the state that can be used to meet the state's goals to reduce atmospheric concentrations of NOX, CO, ROG, ozone and CO2.

AA4) the state has not exhausted all its options to reduce atmospheric concentrations of the afore-mentioned gases.

AA5) the state can achieve its goals without the motor vehicle emission standards proposed in the regulation by using the following methods:

    - Reduce statewide VMT by 25% from a 2014 baseline by 2030 and 50% from a 2014 baseline by 2040.

    - Implement a renewable fuel standard for liquid motor vehicle fuels of 25% content closed loop renewable fuels by 2030 and 50% content closed loop renewable fuels by 2040.

     - Reduce Port of Los Angeles/ Long Beach shipping actitvity (tonnage) by 75% from a 2019 baseline by 2030.

 AA6) The proposed motor vehicle emission standards in this regulation will impact the types of motor vehicles sold in other states by the fact that motor vehicle manufactures will, due to economics, be forced to design and build all their vehicles to meet the state's emission standard.

AA7) The state is required to exhaust all the emission reduction options available to the state before implementing motor vehicle emission standards that are stricter than U.S EPA standards. The reason for this is to prevent other states from being unnecessarily impacted by motor vehicle designs that are influenced by the State of California's motor vehicle emission standards.

AA8) California residents have for years attempted to require the State of California to implement the strategies listed in comment AA5. The state has resisted those efforts.

 

Thank you

T,Becker Power Systems

Tom Becker

Buellton, Ca


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Date and Time Comment Was Submitted 2022-05-29 09:56:36

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