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Comment 105 for Advanced Clean Fleets Regulation (acf2022) - 45 Day.

First NameAgnes
Last NameSuleiman
Email Addressagni.suleiman@gmail.com
Affiliation
SubjectExtending deadline for the ACF
Comment

I am writing today to ask to extend the deadline for the finalized Advanced Clean Fleets (ACF) Regulation to allow more time for industry and staff to develop workable, affordable, and timely solutions.  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, services, and food to Californians, the nation, and the world.

 

As a proud and working member of the California Almond community, we provide 85% of the world's supply of almonds, and 70% of the nation's almonds. Of our 7,600 almond farms, 70% are family owned and operated with 90% being less than 100 acres grown across 16 counties in California's Great Central San Joaquin Valley, adding $9.2B annually to California's economy, and is one of the third largest agricultural exports for the US. 

 

 At this time, there are no Zero Emission trucks that can make a round-trip between California’s Central Valley and the Ports of Los Angeles, Long Beach or Oakland. Despite this fact - the solutions for compliance not being available -  CARB plans on preventing any additional trucks from entering port service after 1/1/24 unless they are Zero Emission.  Drayage trucks do more than just shuttle containers between terminals or local yards; they shuttle containers and almonds to and from our farms & facilities to rail spurs and coastal ports.  For shippers and trucking companies who upgrade their trucks on a regular basis, they will be out of luck in just 14 months, because the truck they need to comply with this proposed regulation is not commercially available at scale yet. 

 

Supply chain disruption since the Covid-19 global pandemic has already created a socio-economic crisis in our community, resulting in tens of millions of pounds of almonds being sold, but not shipped or paid for, resulting in a nearly $2B loss to our community and 110,000 employees. We fear adding this regulation at this time without option or opportunity for compliance, will further devastate our industry, our California rural communities, and our American export economy. 

 

Please, extend the deadline for the finalized  Advanced Clean Fleets (ACF) Regulation to allow more time for industry and staff to develop workable, affordable, and timely solutions.


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Original File Name
Date and Time Comment Was Submitted 2022-10-12 13:54:11

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