Dear CARB Staff,
I'm concerned with the timing and applicability of the new ACF
regulation which will require businesses meeting certain criteria
to add only Zero-Emission Vehicles to fleets beginning Jan 1, 2024
(only 14 months away!). There are major barriers to implementation
including significantly higher costs to purchase ZEVs, lack of
availability, insufficient technology, uncertain grid
accomodations, creating unfair competition and more.
Why is CARB pushing this legislation with a 2024 date when
California lawmakers have already chosen 2035 as the year to ban
the sale of new gasoline powered cars. What data is CARB reviewing
that suggests this will be successful more than a decade
earlier?
What work is happening now to strengthen the electrical grid to
sustain the additional demand? Businesses may not have the ability
to charge fleet vehicles at non-peak times as was asked of
Californians this past September amid a record heat wave.
Why is CARB forcing businesses of a certain size to comply with
this regulation? This gives an unfair advanatage to businesses
under the threshold which will not need to spend millions of
dollars in vehicles and fueling/charging infrasturcture.
Please consider postponing this regulation until a time when its
implementation is practical and wont burden the businesses that
support California's economy. Thank you for reveiwing my
comments.