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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