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