I applaud
CARB’s efforts to reign in the emissions of
California’s trucks. I believe we need to do this as quickly
as possible and therefore support the Environmental Defense Fund
and other organizations in proposing three changes to the CARB
staff proposal that would accelerate the transition to ZEVs and
increase public health benefits of the regulation.
First, the
100% ZEV sales requirement should be moved up to 2036 instead of
2040. A new
report shows this change would generate $2.7 billion in
additional health care savings by 2050, cut an additional 24
million metric tons of climate pollution, and put 133,000 ZEV
trucks on the road in 2050 (comprising 78% of all trucks). In 2035,
the average ZEV truck will cost almost $50,000 less to operate over
its lifetime than a combustion engine truck.
Second,
the 50 or greater fleet size floor for the in private fleet
requirements to apply should be decreased to 10 vehicles for Class
7 and 8 trucks (these are the large tractors that pull separate
trailers). These tractors account for only 12% of MHD trucks but
emit half of the NOx from all MHD trucks. This change would
decrease NOx and PM2.5 emissions by an additional 16% compared to
the CARB staff proposal.
Third, in
the fleet ZEV composition schedule for private fleets (See Table
above) the Class 8 sleeper cabs should be moved up three years to
be consistent with the day cabs (row 2 of the table).
CARB has
analyzed the combined effect of our three recommended changes and
presents the results as Alternative 2 in its staff
report, which is available for public comment. The
analysis indicates Alternative 2 results in 59% greater health
benefits, 55 to 60% additional NOx, PM2.5 and GHG emission
reductions, and even a small increase in the net savings to fleet
operators. Adopting Alternative 2 of the ACF rule rather than the
staff proposal presents a critical opportunity to more rapidly
clean up the air in California and takes a stronger step towards
meeting the Governor’s climate goals, while decreasing the
cost of operation for fleet owners. Our leaders must finalize a
stronger rule.
Thank you
for seriously considering making these changes to support us and
our children in having a healthier and more livable
home.
Lawrence
Garwin
Palo Alto,
California