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Comment 13 for Advanced Clean Fleets Regulation (acf2022) - 45 Day.

First NameSam
Last NameWilson
Email Addressswilson@ucsusa.org
AffiliationUnion of Concerned Scientists
SubjectTranscript of Verbal Comments on ACF - 10/27
Comment

Chair Randolph and members of the board, my name is Sam Wilson and I’m a Senior Vehicles Analyst with the Union of Concerned Scientists, a national nonprofit that puts rigorous science to work in our democracy. On behalf of our half-a million supporters, thank you for the opportunity to comment on this highly consequential regulation.

Thanks to CARB staff for their hard work and robust public process. The ACF is a crucial step in the right direction to reduce GHG emissions, help to relieve disproportionate health burdens on freight-adjacent communities and accelerate the market and tech for clean heavy-duty vehicles.

While we support this proposal, it does not adequately address the outsized impacts of tractor trucks. Big rig trucks are just around 10 percent of the state’s medium and heavy-duty fleet but are responsible for about half of GHGs, NOx, and fine particulate emissions from HD vehicles. However, the compliance threshold under the rule is agnostic to the fact that different types of trucks and fleets contribute vastly different amounts of pollution. For example, a fleet of 50 tractor trucks emits around 14 times as much NOx, 4 times the fine particulates, and 4.5 times the GHG emissions as a fleet of 50 class 2b delivery vans.

Our analysis shows that a compliance threshold of 10 for tractors would best account for the significant pollution from these trucks – it would bring nearly 90 percent of tractor truck emissions under the rule, while only regulating around 10 percent of tractor fleets in the state AND leaving the most vulnerable small businesses outside the regulation. A lower threshold would also help to address the exclusion of certain tractor trucks under the drayage portion of the rule, which would allow combustion-powered auto transports and fuel delivery drayage trucks to operate nearly 20 years past the Governor’s goal of 100 percent drayage operations by 2035.

Finally, other 177 states have signaled their intent to adopt a dynamic threshold by establishing fleet reporting thresholds of 5.

 

A dynamic compliance threshold that recognizes the outsized impacts of the dirtiest trucks would supercharge the benefits ACF is poised to deliver. Thank you.


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Date and Time Comment Was Submitted 2022-10-27 10:57:35

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