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First Name	Ryan
Last Name	Gallentine
Email Address	rgallentine@aee.net
Affiliation
Subject	AEE supports ACF Alternative 2
Comment	Good afternoon, Chair Randolph and Board Members My name is Ryan Gallentine and I’m here representing Advanced Energy Economy to express our strong support for the Advanced Clean Fleets rule AEE is a national association of businesses representing the broad spectrum of advanced energy and electrified transportation solutions. It is from the perspective of these diverse members that we encourage CARB to adopt Alternative 2 requiring all-electric medium- and heavy-duty vehicle sales by 2036. An assertive, accelerated timeline for electrifying medium- and heavy-duty vehicle fleets will stimulate new economic growth, maximize emissions reductions, and propel CA’s competitive ZEV manufacturing industry. We also appreciate the complexity of implementing this rule, and recognize the balancing act required to rapidly and cost-effectively electrify the MHD sector. Vehicle availability, supply chain constraints, and other factors outside fleet operators’ control will need to be tackled holistically and in tandem with distribution system upgrades, financial assistance, and other planning considerations. Correspondingly, we recommend that CARB establish reasonable interim milestones and opportunities for formal assessment along the way so barriers to industry compliance can be timely addressed. These recommendations and others outlined in our written comments will provide reasonable flexibility as the market continues to evolve while preserving a clear market signal and keeping California on track to meet the aggressive goals enshrined in the Governor’s Executive Order. In closing, AEE looks forward to working with CARB and other stakeholders to cement an ambitious, achievable ACF rule.
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Date and Time Comment Was Submitted	2022-10-27 15:45:14

Good afternoon, Chair Randolph and Board Members
My name is Ryan Gallentine and I’m here representing Advanced Energy Economy to express our strong support for the Advanced Clean Fleets rule
AEE is a national association of businesses representing the broad spectrum of advanced energy and electrified transportation solutions.
It is from the perspective of these diverse members that we encourage CARB to adopt Alternative 2 requiring all-electric medium- and heavy-duty vehicle sales by 2036.

An assertive, accelerated timeline for electrifying medium- and heavy-duty vehicle fleets will stimulate new economic growth, maximize emissions reductions, and propel CA’s competitive ZEV manufacturing industry.
We also appreciate the complexity of implementing this rule, and recognize the balancing act required to rapidly and cost-effectively electrify the MHD sector.
Vehicle availability, supply chain constraints, and other factors outside fleet operators’ control will need to be tackled holistically and in tandem with distribution system upgrades, financial assistance, and other planning considerations.
Correspondingly, we recommend that CARB establish reasonable interim milestones and opportunities for formal assessment along the way so barriers to industry compliance can be timely addressed.

These recommendations and others outlined in our written comments will provide reasonable flexibility as the market continues to evolve while preserving a clear market signal and keeping California on track to meet the aggressive goals enshrined in the Governor’s Executive Order.

In closing, AEE looks forward to working with CARB and other stakeholders to cement an ambitious, achievable ACF rule.

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Comment 31 for Advanced Clean Fleets Regulation (acf2022) - 45 Day.