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Comment 142 for Proposed Advanced Clean Cars II Regulations (accii2022) - 45 Day.

First NameTricia
Last NameStever Blattler
Email Addresspstever@tulcofb.org
AffiliationTulare County Farm Bureau
SubjectOppose Electrification of all Vehicles
Comment

Tulare County Farm Bureau represents approximately 1100 farms and ranches, and member families in Tulare County.  We are very concerned about the CARB's proposal to advance electrification of all vehicles in the coming years, we believe it will come at great expense to the rural communities and farm economy of California and hinder the safe distribution of food and farm products across the nation and globe.  These rules deepen inequality, particularly in rural and farm regions of California where electric infrastructure is already substandard, and grid capacity is not set up to support every farm, ranch, home, and business utilizing electric vehicles. 

As California tries to recover from the impacts of COVID-19, we are now met with another challenge – unprecedented energy costs. Californians are paying for all forms of energy because of the climate design of our state. It is no doubt that climate change needs to be addressed, but the Advanced Clean Cars II (ACC II) rulemaking will only make our energy problems worse. Families and businesses are affected by inflation, and ACC II will increase rising costs for necessities that produce and ship our food.

We all want to do our part to lower emissions, but this is the wrong way to go about it. Bans and mandates aren’t feasible for most of California, especially farmers who will have to make a drastic shift in all their equipment needed to grow and transport food safely and in a timely manner.

Farmers have already made their pledge to address the climate crisis by adjusting such as growing more with less water and reducing greenhouse gases. They’ve also made changes to using better soil that increases carbon capture, thus reducing emissions. ACC II will make the agriculture community collateral damage instead of joining forces.   

Rural towns do not have the infrastructure to support drastic electrical changes, and in the end the small farms will eventually be cut out. The state wants to reduce “vehicle miles travelled” by 22% by 2045 and would hit people living and working in rural areas harder – especially agricultural workers, who would need to some place to charge EVs.

Californians are already feeling the burden of inflation with higher grocery bills. Not only will this mandate raise inflation, but it could add to food insecurity all over the state. The California grid can barely support our current energy usage. Forcing farmers to rely on that grid for transportation will increase energy usage and power outages. Power outages would mean transportation will be interrupted, and most food is perishable. These factors ultimately raise the cost of food to pay for higher energy consumption and food scarcity.

Public Safety Power shutoffs during times of emergencies, forest fires, and other catastrophic disasters could mean that Californians would not have access to charge their electric vehicles to escape and evacuate from areas of disaster. Low income communities, many situated here in the San Joaquin Valley could be impacted disproportionately by these changes. 

Commerce between states, and trucks taking California ag (perishable) commodities to out of state distribution centers would be adversely impacted by the lack of charging stations across other states, the onerous rules governing Electronic Driver Logs, and hours drivers can log each day, and could make perishable shipments face countless delays that could cause crops to be damaged or harmed in shipment. 

We urge you to consider whether: consumers will be able to buy the cars they need, and can afford, on the schedule outlined to get to where they need to go; whether car manufacturers can build the cars and offer them for an affordable price given supply chain constraints; how increasing utility rates across the state (and at different) rates will affect affordability; how the build-out of EV charging will be done equitably, especially in rural areas; and how California’s electric grid can reliably meet the energy demands expected.

Climate polices need to be technology neutral and cost-effective for everyone to be able to participate in the fight against climate change. The protection of California’s agriculture community is a necessity, as they are a key element for the wellbeing and survival of Californians.

A coalition of groups & individuals known as Energy IDEAS states: the regulation could potentially reduce personal income by $15 billion dollars, car ownership would increase by $6,000 per car, economic output could be reduced by as much as $22.7 billion, and low income communities will carry a disproportionate burden of these costs.    Food security and affordability will be negatively impacted, and small businesses will pay a huge price along with 85,000 jobs that could be impacted or eliminated by a shift to electrification of all motor vehicles. 

We urge you to think about the impact to farms in California, rural Californians, low income and elderly who cannot and will not be able to afford electric cars in the next two decades.   This is not a workable solution for many reasons outlined above. 

Thank you,

Tricia Stever Blattler

Executive Director

Tulare County Farm Bureau 


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Date and Time Comment Was Submitted 2022-05-31 17:04:44

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