Thank you for considering our feedbak on the proposed Advance
Clean Fleet Regulation. We hope our comment's contents will
resonate and be carefully considered. We content that
the proposed rule's inclusion of the $50m gross revenue threshold
is biased against non-transportation sector
businesses. It will require local businesses who
have fleets smaller fifty tractor to comply with the ruling if
their businesses bundle revenue from multiple service
sectors. For instance, our local, family-owned beverage
distribution business is being paid by our customers to manage
their beverage inventory levels; to move/organize products into the
storage and retail areas of their facilities; to merchandise their
retail shelves/displays; to clean their draught lines; to
create/install signage at their facilities; and to use our
tractor/trailers to deliver the beverages to their retail
establishments. We are not solely a transportation
company.
Please ask you self this simple question. In our case, how
is the $92.2m of gross revenue that we generate across multiple
service sectors tied to how much pollution our delivery tractors
emit? The answer is simple: "There is no
correlation." The size of our fleet, thirty-four tractors, is
certainly a direct measure. We contend that the
simplistic approach of the gross revenue aspect of the proposed
ruling is biased against local, service-sector businesses who only
use medium/heavy duty diesel tractors for a minor portion of their
revenue generation. Total company, we have 150
employees, and we have thirty-four tractors, each driven for
one-shift, five days per week. Our thirty-four drivers are
only 22.7% of our workforce while 77.3% of our employees perform
non-transportation-related services to our customers.
The Advanced Clean Fleet Regulation is meant to put
zero-emission tractors on the road running in high-use
scenarios. Our tractors sit more then they drive, and
we’re getting paid by our customers to do a lot more than to
deliver beverages. With less than fifty tractors, driving
low, local miles, we should be allowed to remain exempt regardless
of our aggregated service-sector gross revenue. The
simplistic use of a $50m gross revenue threshold is unfair to
businesses that operate in multiple services sectors.
Please consider removing the gross revenue aspect of the
ruling or adjusting it to not penalize multi-service sector,
non-transportation businesses! Thank you, again, for
your time and consideration.
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