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Comment 15 for Advanced Clean Fleets Regulation (acf2022) - 45 Day.

First NameSuzanne
Last NameSeivright-Sutherland
Email Addresssseivright@calcima.org
AffiliationCalCIMA
SubjectCalCIMA comments - ARB ACF high priority and federal fleets and LER
Comment

I’m Suzanne Seivright-Sutherland from the California Construction and Industrial Materials Association, better known as CalCIMA, the statewide trade association for producers of aggregate, concrete, cement, asphalt, and industrial minerals used to build our state’s infrastructure.  

In coordination with Jeffer Mangels Butler & Mitchell, CalCIMA submitted a comment letter proposing specific revisions to the regulatory language consistent with its goals to address the deficiencies and to help ensure the construction materials producers can implement this Regulation. Some key points from our letter include the following:   

1) To ensure consistent and practical application, we ask for accurate and precise definitions for the terms “available to purchase”, “commercially available,” and “configuration.”

 

2) Because the ZEV Unavailability Exemption simply assumes the future availability of pickup trucks in all configurations, we ask that pickup trucks be addressed the same as the Regulation addresses trucks over 14,000 pounds GVWR. 

 

3) For fleets whom a transition to hydrogen fuel cell is the logical operational endpoint, and for whom a requirement to purchase battery electric vehicles to achieve short-term compliance will force a double investment, we ask for an alternative compliance pathway.  

 

4) Because CARB inconsistently categorizes ready-mix concrete trucks in various locations and versions of the rulemaking documents, we request these trucks be clearly categorized as “specialty vehicles” since they are over 33,000 pounds GVWR and have a heavy front axle.  

 

5) The Daily Usage Exemption requires a fleet to have 10 percent ZEVs which may be unattainable as manufacturers are still bringing new products to market and no rationale in the ISOR limits this exemption, we ask this percentage to be removed.

 

6) Regarding the Infrastructure Delay Extension, because the ISOR presents no evidence that one year is sufficient to assure delivery of infrastructure or electricity, we ask for this timeframe to be removed.  

 

7) We also ask that all exemptions include an appeal process as an oversight or correction mechanism to deliver consistent application of the Regulation.

8) And finally, CARB assessments do not expect viable zero-emission technology in specialty and weight-sensitive applications accounting for 2 percent of the trucks on the road, until after 2030. CARB considers a subset of these vehicles, construction specialty vehicles, among the least likely a ZEV may become available. In lieu of the Regulation only permitting continued use of diesel for this subset, we ask CARB to promote the use of RNG as a bridge technology that supports GHG reductions and make a good faith effort to quantifiably understand how this bridge technology supports GHG reductions.

Thank you for considering our comments. 


Attachment
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Date and Time Comment Was Submitted 2022-10-27 11:13:39

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