The San Diego County Farm Bureau strongly
supports the Business-Industry Coalition Comments, dated October 13, 2022:
California businesses, industries, our employees and the local
communities that we serve are in
need of your intervention. The proposal that will
come before you in
October is in need of
significant change. Throughout the
entirety of the rulemaking process, California’s private and
public sector stakeholders
have continually raised critical implementation issues that have been
cast aside.
These concerns include vehicle availability (at scale) and supply chain issues that
intensify
affordability concerns, the necessity to incorporate workable emergency response exemptions,
obvious infrastructure readiness questions, regulatory timing and process concerns (including
transparency for determining
‘commercially available’ vehicles), and the need for flexible low-
carbon fuel alternatives, amongst others. Since these issues have been not been resolved, we
are extremely concerned that
the proposed
ACF rule will be unworkable in the real world and
could result in compromising the delivery of essential goods and
services to
Californians.
The COVID-19
pandemic, the supply
chain crisis and inflation challenges are making it difficult
for Californians. There is a great deal of financial uncertainty that exists for California, and it is
harmful to further sow uncertainty and potential hardship.
CARB needs its stakeholders to be
successful and would make great strides by directing staff to work with us,
in earnest, to
develop
workable, affordable, and timely solutions to this major regulatory effort before it is finalized next
year.
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