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Comment 218 for Advanced Clean Fleets Regulation (acf2022) - 45 Day.

First NameDana
Last NameHamilton
Email Addressdana.hamilton@advancebeverage.com
AffiliationAdvance Beverage Company
SubjectAdvanced Clean Fleet Regulation bias Against Non-Transportation Sectors
Comment

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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Date and Time Comment Was Submitted 2022-10-17 09:10:32

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