I am writing
today to ask to extend the deadline for the finalized Advanced
Clean Fleets (ACF) Regulation to allow more time for industry and
staff to develop workable, affordable, and timely
solutions. We are extremely concerned that the proposed ACF
rule will be unworkable in the real world and could result in
compromising the delivery of essential goods, services, and food to
Californians, the nation, and the
world.
As a proud
and working member of the California Almond community, we
provide 85% of the world's supply of almonds, and 70% of the
nation's almonds. Of our 7,600 almond farms, 70% are family owned
and operated with 90% being less than 100 acres grown across 16
counties in California's Great Central San Joaquin Valley,
adding $9.2B annually to California's economy, and is one of the
third largest agricultural exports for the
US.
At this
time, there are no Zero Emission trucks that can make a round-trip
between California’s Central Valley and the Ports of Los
Angeles, Long Beach or Oakland. Despite this fact - the solutions
for compliance not being available - CARB plans on preventing
any additional trucks from entering port service after 1/1/24
unless they are Zero Emission. Drayage trucks do more than
just shuttle containers between terminals or local yards; they
shuttle containers and almonds to and from our farms &
facilities to rail spurs and coastal ports. For shippers
and trucking companies who upgrade their trucks on a regular basis,
they will be out of luck in just 14 months, because the truck
they need to comply with this proposed regulation is not
commercially available at scale yet.
Supply chain disruption since the Covid-19 global
pandemic has already created a socio-economic crisis in our
community, resulting in tens of millions of pounds of almonds being
sold, but not shipped or paid for, resulting in a nearly $2B loss
to our community and 110,000 employees. We fear adding this
regulation at this time without option or opportunity for
compliance, will further devastate our industry, our California
rural communities, and our American export
economy.
Please, extend the deadline for the finalized
Advanced Clean Fleets (ACF) Regulation to allow more time for
industry and staff to develop workable, affordable, and timely
solutions.
|