Comment Log Display

Here is the comment you selected to display.

Comment 220 for Advanced Clean Fleets Regulation (acf2022) - 45 Day.

First NameTrevor
Last NameGasper
Email Addresstgasper@thorindustries.com
AffiliationTHOR Industries, Inc.
SubjectTHOR Industries' Written Comments on Proposed Advanced Clean Fleet Regulation
Comment

 

Liane M. Randolph, Chair

California Air Resources Board

1001 I Street

Sacramento, CA 95814

 

Re:       THOR Industries’ Written Comments on Proposed Advanced Clean Fleet Regulation

 Dear Chair Randolph: 

 I am initiating this correspondence to you in my capacity as Senior Vice President and General Counsel for THOR Industries, Inc. (“THOR”).  THOR is the world’s largest manufacturer of recreational vehicles including motorhomes, travel trailers and fifth-wheel trailers. 

 This letter is intended to serve as THOR’s written comments on the California Air Resources Board’s (“CARB”) proposed Advanced Clean Fleets (“ACF”) regulations.  For the reasons set forth below, THOR is requesting that CARB amend the ACF to exempt motorhomes from its requirements.  

 

1.         ACF’s Zero Emission Requirements Impose an Undue Burden on the Motorhome Industry.   

 Section 2016(d) of the proposed ACF requires vehicles over 8500 lbs. GVWR (which includes motorhomes) and offered for sale in California to be ZEVs beginning with the 2040 model year.  If enacted, this requirement will have a substantial negative impact on the motorhome industry in the State of California.  

 Unlike automobiles, there are no zero emission motorhomes currently being sold to consumers.  While zero emission motorhome concept vehicles exist, it is unlikely that these concept vehicles will be manufactured for sale to consumers in the foreseeable future.  This is due, in part, to the unique batteries and motors that are required to power motorhomes. 

 Switching to batteries and motors that produce zero emissions will significantly increase the cost of motorhomes.  It is currently estimated that zero emission motorhomes will cost approximately $50,000 - $100,000 more per unit than existing gas or diesel powered motorhomes.  A cost increase of this magnitude will render ZEV motorhomes unaffordable for many potential owners who will be forced pursue other recreational activities to the detriment of California’s motorhome dealers, service providers (e.g. campgrounds, parks, etc.) and other businesses that rely on the motorhome industry.  These negative economic impacts on the motorhome industry can be avoided by simply amending the ACF to exempt motorhomes from its requirements. 

 

2.         The ACF Fleet Milestone Requirement Excludes Motorhomes. 

 

The ACF establishes new regulations for owners of motorhome rental fleets in California that include fifty (50) or more motorhomes at any point of time in the course of a year.  Beginning in 2024 and 2025 owners of such motorhome rental fleets will be required to comply with either the “ZEV addition” requirements in S.2015.1 or the “ZEV fleet milestone” requirements in S.2015.2. 

 To comply with the “ZEV addition” requirements, owners of motorhome rental fleets are required when adding to their existing fleet to purchase ZEV motorhomes unless a ZEV unavailability exemption can be utilized.   To comply with the “ZEV fleet milestone” requirements, owners of motorhome rental fleets are required to meet or exceed the ZEV milestone percentage requirements set forth in Table A: ZEV Fleet Milestones by Milestone Group and Year, as listed in Appendix A-2. 

 Table A provides “ZEV fleet milestone” for three (3) groups (Milestone Group 1, Milestone Group 2 and Milestone Group 3).  Each of the three (3) groups are defined in the ACF; however, such definitions fail to reference motorhomes.  As such, it appears that owners of motorhome rental fleets are not eligible to comply with the “ZEV fleet milestone” requirements and, instead, are required to comply solely with the “ZEV addition” requirements.  If this is interpretation is correct, owners of motorhome rental fleets will be required to begin purchasing ZEV motorhomes (or utilizing ZEV unavailability exemptions) in 2024 rather than 2040.  Such a result is nonsensical given the fact that no zero emission motorhomes are currently being sold to consumers.  Again, these negative impacts can be avoided by amending the ACF to exempt motorhomes from its requirements.           

THOR appreciates the opportunity to comment on the proposed ACF. 

If you have any questions or would like to discuss THOR’s written comments, please feel free to contact me.  My contact information is set forth below. 

Sincerely,

 

           

                                                            Thor Industries, Inc.

                                                            By: Trevor Gasper, Sr. Vice President , General Counsel & Corporate Secretary

Telephone: (574) 970-7925

 

E-Mail:  tgasper@thorindustries.com  

 


Attachment
Original File Name
Date and Time Comment Was Submitted 2022-10-17 09:49:03

If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.


Board Comments Home