Ed Staub &
Sons
10/15/2022
Clerk of the Board
California Air Resources
Board
1001 I Street, Sacramento,
California 95814
RE: Title 13. Public
Hearing to Consider Proposed Advanced Clean Fleets
Regulation
Ed Staub & Sons
respectfully opposes the
adoption of the Advanced Clean Fleets rule as it attempts to
transition the transportation and goods movement economy much too
quickly without sufficient regard for the necessary infrastructure
overhaul in the state, a realistic consideration of the
state’s power grid capabilities, and the lack of an adequate
and accurate cost analysis.
The regulation’s proposed
timeline will place significant strain on the transportation
industry and gravely hamper goods movement in the state.
Additionally, the cost of replacing fleets with entirely zero
emissions vehicles will unduly harm small businesses in the state,
many of which are family- and minority-owned. With the limited
supply and options for heavy duty ZEVs, large companies with
greater capital will be prioritized by manufacturers as compared to
their small business counterparts. The highly restrictive timeline
that has been proposed will only serve to further exacerbate this
problem in the market.
Additionally, significantly
increasing the operating costs of the transportation and goods
movement sector within the state will ultimately harm our most
vulnerable communities and residents the most. Low-income
households in the state are already bearing the brunt of increased
electricity costs, which
will only be further intensified by the adoption of this regulation
as our unreliable grid continues to be strained beyond capacity. As
a small business who takes great pride in serving our community,
the impacts of the proposed regulation on the costs of goods and
necessities, such as food, water, and fuel, are of grave concern.
Ed Staub & Sons
also has significant concerns
because the regulation does not sufficiently consider the current
and future needs of the transportation industry within the state.
The range of the vehicles that are currently offered on the market
will not ensure a seamless transition, as many heavy duty vehicles
are often used nearly continuously to ensure the timely delivery of
goods to other businesses and consumers. Moreover, the
infrastructure necessary to support a full transition to zero
emission fleets is not prevalent enough to serve the vast number of
vehicles CARB intends to replace. This regulation will be a major
disruptor to the state’s supply chains, which will increase
the cost of goods at every level.
We urge the Board to consider
the deeply unsettling ramifications of bottlenecks in our fuel,
food, water, and medical supplies, in addition to every industry
that moves goods on heavy duty vehicles within the
state.
For these reasons, we must
respectfully oppose the adoption of the Advanced Clean Fleets rule.
Sincerely,
Dan
DeWitt
Ed Staub &
Sons
Director of
Operations