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Comment 40 for Advanced Clean Fleets Regulation (acf2022) - 45 Day.

First NameLawrence
Last NameGarwin
Email Addresslawrencegarwin@yahoo.com
Affiliation
SubjectProposed Advanced Clean Fleets Regulation (acf2022)
Comment

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 

 


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Date and Time Comment Was Submitted 2022-10-07 12:44:57

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