October 10, 2022
CARB Board Members California Air Resources Board 1001 I
Street
Sacramento, CA 95814
Submitted Electronically
Subject: Proposed Advanced Clean Fleets (ACF) Regulation
Dear Chair Randolph, Vice Chair Berg, and CARB Board
Members:
The undersigned organizations appreciate the opportunity to
comment on the California Air Resources Board’s (CARB)
proposed Advanced Clean Fleets (ACF) regulation. Our coalition
consists of organizations that represent California’s
manufacturing, commercial, industrial, agricultural,
transportation, construction, energy, and public agency sectors. As
a coalition, we acknowledge California’s continuing efforts
to develop leading-edge policies to address climate change and
health-based air quality mandates. We also recognize that these
efforts
GHG emission reductions pursuant to AB 32. Regrettably, we
collectively find ourselves – despite
require the
adoption of regulations for “achieving the maximum
technologically feasible and cost-effective”
our best efforts – in a difficult position
regarding the workability of the proposed ACF regulation
scheduled to appear before you on October 27, 2022.
California businesses, industries, our employees and the
local communities that we serve are in
need of your intervention. The proposal that will come
before you in October is in need of
significant change. Throughout the entirety of the
rulemaking process, California’s private and
public sector stakeholders have continually raised
critical implementation issues that have been
cast aside.
These concerns include vehicle availability (at scale) and
supply chain issues that intensify
affordability concerns, the necessity to incorporate
workable emergency response exemptions,
obvious infrastructure readiness questions, regulatory
timing and process concerns (including
transparency for determining ‘commercially
available’ vehicles), and the need for flexible low-
carbon fuel alternatives, amongst others. Since these
issues have been not been resolved, we
are extremely concerned that the proposed ACF rule will be
unworkable in the real world and
could result in compromising the delivery of essential
goods and services to Californians.
The COVID-19 pandemic, the supply chain crisis and
inflation challenges are making it difficult
for Californians. There is a great deal of financial
uncertainty that exists for California, and it is
harmful to further sow uncertainty and potential hardship.
CARB needs its stakeholders to be
successful and would make great strides by directing staff
to work with us, in earnest, to develop
workable, affordable, and timely solutions to this major
regulatory effort before it is finalized next
year.
Respectfully,
CALIFORNIA MANUFACTURERS & TECHNOLOGY ASSOCIATION
101MFG, LLC.
ALMOND ALLIANCE OF CALIFORNIA
ASSOCIATED GENERAL CONTRACTORS – SAN DIEGO
CHAPTER
ASSOCIATION OF CALIFORNIA EGG FARMERS
AUTOCARE ASSOCIATION
CALIFORNIA ADVANCED BIOFUELS ALLIANCE
CALIFORNIA AUTOMOTIVE WHOLESALERS’ ASSOCIATION
(CAWA)
CALIFORNIA BUSINESS PROPERTIES ASSOCIATION
CALIFORNIA BUSINESS ROUNDTABLE
CALIFORNIA COMPOST COALITION
CALIFORNIA FUELS & CONVENIENCE ALLIANCE
CALIFORNIA GRAIN & FEED ASSOCIATION
CALIFORNIA GROCERS ASSOCIATION
CALIFORNIA METALS COALITION
CALIFORNIA NATURAL GAS VEHICLE COALITION
CALIFORNIA SEED ASSOCIATION
CALIFORNIA RAILROADS
CALIFORNIA RETAILERS ASSOCIATION
CALIFORNIA WAREHOUSE ASSOCIATION
CLEAN ENERGY
COUNCIL OF BUSINESS & INDUSTRIES OF WEST CONTRA COSTA
COUNTY
HEXAGON AGILITY
INDUSTRIAL ENVIRONMENTAL ASSOCIATION
MANUFACTURERS COUNCIL OF THE CENTRAL VALLEY
NATURAL GAS VEHICLES FOR AMERICA
SAN JOAQUIN MANUFACTURING ALLIANCE
TRILLIUM
WESTERN GROWERS ASSOCIATION
WESTERN INDEPENDENT REFINERS ASSOCIATION
WESTERN PROPANE GAS ASSOCIATION