Clerk of the Board
California Air Resources
Board
1001 I Street, Sacramento,
California 95814
RE: Title 13. Public
Hearing to Consider Proposed Advanced Clean Fleets
Regulation
Dear Clerk of the
Board,
United Pacific
respectfully opposes the adoption of the Advanced Clean
Fleets rule as it attempts to transition the transportation and
goods movement economy much too quickly without sufficient regard
for the necessary infrastructure overhaul in the state, a realistic
consideration of the state’s power grid capabilities, and the
lack of an adequate and accurate cost analysis.
The regulation’s proposed
timeline will place significant strain on the transportation
industry and gravely hamper goods movement in the state.
Additionally, the cost of replacing fleets with entirely zero
emissions vehicles will unduly harm small businesses in the state,
many of which are family- and minority-owned. With the limited
supply and options for heavy duty ZEVs, large companies with
greater capital will be prioritized by manufacturers as compared to
their small business counterparts. The highly restrictive timeline
that has been proposed will only serve to further exacerbate this
problem in the market.
Additionally, significantly
increasing the operating costs of the transportation and goods
movement sector within the state will ultimately harm our most
vulnerable communities and residents the most. Low-income
households in the state are already bearing the brunt of increased
electricity costs, which
will only be further intensified by the adoption of this regulation
as our unreliable grid continues to be strained beyond capacity. As
a small business who takes great pride in serving our community,
the impacts of the proposed regulation on the costs of goods and
necessities, such as food, water, and fuel, are of grave
concern.
United Pacific
also has significant concerns because the regulation does
not sufficiently consider the current and future needs of the
transportation industry within the state. The range of the vehicles
that are currently offered on the market will not ensure a seamless
transition, as many heavy-duty vehicles are often used nearly
continuously to ensure the timely delivery of goods to other
businesses and consumers. Moreover, the infrastructure necessary to
support a full transition to zero emission fleets is not prevalent
enough to serve the vast number of vehicles CARB intends to
replace. This regulation will be a major disruptor to the
state’s supply chains, which will increase the cost of goods
at every level.
We urge the Board to consider
the deeply unsettling ramifications of bottlenecks in our fuel,
food, water, and medical supplies, in addition to every industry
that moves goods on heavy duty vehicles within the
state.
For these reasons, we must
respectfully oppose the adoption of the Advanced Clean Fleets
rule.
Sincerely,
United Pacific
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