Comment Log Display

On behalf of the San Diego Regional Chamber of
Commerce and speaking for a variety of industries and small,
medium, and large employers in our region, we like to
comment on the Advanced Fleet Regulations being proposed by
CARB.  


 


The passage of the North American Free Trade
Agreement (NAFTA) led to the integration of the U.S. and Mexican
economies through increased cross-border manufacturing and trade.
Today, over 5 million U.S. jobs and over 565,500 jobs in California
are supported by trade with Mexico, forming part of a complex
network of cross-border and integrated supply chains. Goods cross
the border back and forth multiple times before final assembly,
developing one of the world’s most impactful
platforms.  


 


Expanded cross-border trade has been integral to
California’s success as the fifth largest economy in the
world. California boast one of the world’s busiest
international land border crossings and the busiest between the
United States and Mexico which processes 90% of California’s
exports to Mexico. Together, San Diego and Baja have created a $2.5 billion
co-producing manufacturing supply chain and became the largest
medical device cluster in the world. Although movement across
our border is not limited only to goods, much of our conversation
centers around the physical infrastructure needed to support all
this economic activity.   


 


As the leading voice for business, the Chamber is
committed to making the San Diego region the best place to live and work through the
development of global policies that boost the economy, facilitate
cross-border commerce, and strengthen international business relationships. We believe that
there is a disconnect with the proposed regulation
to include small
operators in the availability and pricing of ZEV truck. In
addition, the regulation does not ensure the required infrastructure will be
in place to handle fueling/charging ZEV trucks in important freight
corridors.  


 



Based on the foregoing, we ask that CARB
provide us with the following: 




The modification of the high
priority definition to not include small operators that have
service clients handling over $50 million, since most major manufactures in
Baja California would fall under this
category. 


An extension on the date of the requirement to
register a new drayage truck at a
maritime port until it is actually viable to
purchase a ZEV truck.  


Ensure a public charging/fueling station
be funded and built in the vicinity of California’s most
important commercial land port of entry.  


Provide an in-depth economic
expert analysis of this proposed regulation before implementing, to
avoid any potential catastrophic disruptions to our supply chains
and California’s economy. 

 




We applaud and share your
commitment to promote and protect public health, welfare, and
ecological resources through effective reduction of air
pollutants while considering equitable solutions by region. Modifying the high priority
definition of ZEV truck users, an extension on the date of the
requirement to register a new drayage truck
at a maritime port and ensuring incentive funding
programs to comply with this regulation are concrete actions that
CARB can take to avoid the interruption
of supply chains and
inflation in our
region. 
 


Thank you for your leadership on this
important manner. Please don’t hesitate to contact the
Chamber if we can further be of assistance.