Thank you for the opportunity to submit comments on this
proposed ACF rule. I seriously hope all of these comments do
not fall on deaf ears and that CARB seriously considers ALL of the
opinions expressed in this forum.
In my opinion, there are many problems with this proposed
regulation. First of all, I am all for cleaner tail pipe
emmisions and pollution reduction. However, to mandate that
from 1/1/2024 all new drayage trucks registering for the first time
in the CARB online system / drayage registry must be ZEVs is
unrealistic and unfair. There is currently not enough public
charging infrastructure and/or hydrogen fueling stations set up in
the state neccessary to service the amount of ZEV class 8 tractors
that would be added. I have serious doubts that there will be
enough charging infrastructure and hydrogen fueling stations needed
by 1/1/24. In fact, I'm sure there won't be. This rule
is asinine, CARB is putting the carriage before the horse.
Plus the cost of ZEV trucks and the neccessary charging
infrastructure is way too much for most drayage companies to
afford. Traditionally drayage companies purchase 3rd or 4th
generation used trucks for the lowest price available because this
is a very low margin business. Drayage companies aren't huge
Forbes list entities. I hope CARB has considered this.
We are mostly small family run businesses that are lucky enough to
break even each year. Where are we supposed to come up with
the millions of dollars it will take to electrify our whole
fleets. Most of the incentive grants only get us half way
there. So for a $400,000 truck the grant's only cover up to
$200,000. If we have to replace 5 trucks that's 1 million
dollars that we don't have. There's a saying that the port is
where old trucks come to die. Most drayage companies never
buy new trucks because we can't afford them. CARB is trying
to force us to spend money we don't have and if we don't spend the
money we can't exist as a business anymore. Doesn't something
seem immoral with that picture??? That in addition to that,
most drayage companies and drivers are imigrants and/or
minorities. I don't think I need to expound on the racial
inequities that already exist in our society and California.
But this rule will perpetuate those biases. I don't
know how any of you sleep at night knowing that this proposed
regulation will take away THOUSANDS of people's livelihoods.
It's bad enough that we already have to replace our 2009 engines
with 2010 or newer before the end of this year. I'm sure
you're already putting a lot of people out of business with that
mandate. This is on top of what we're dealing with regarding
AB5. I know that's not on CARB but put yourselves in the
shoes of a drayage company or driver. No wonder owner
operators that have 2009 or older trucks are leaving the
industry. CARB will be partially responsible when drayage
capacity drops and the things we all need like food, medicine, and
clothes are more expensive and harder to get.
It seriously baffles me that CARB is even proposing this
draconian rule. There are right and wrong ways to go about
everything. This is clearly the wrong way. We can all
share a common goal of one day all vehicles be zero emmission but
how many people are you willing to hurt in pursuit of that
goal? Shouldn't the answer be none??? But, clearly
CARB thinks drayage companies are expendable or you would't
even be proposing this rule. I urge you to reconsider pushing
back the start date until there is ample public charging
infrastructure and hydrogen fueling stations and the cost of ZEVs
comes down to reasonable amounts.
I appreciate the opportunity to voice my opinion on the
matter. Please do the right thing. There are thousands
of people who work in drayage that this will affect. Please
consider us. We are not expendable nor should we be viewed as
such.
Scott Shimamoto, VP
Mutual Express Company
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