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Comment 69 for Advanced Clean Fleets Regulation (acf2022) - 45 Day.

First NameAngelyn
Last NameTornell
Email Addressatornell@bestdrayage.com
AffiliationBest Drayage, LLC
SubjectExtend the deadline for ACF Regulation!
Comment

Please extend the current unrealistic deadline for Advanced Clean Fleets (ACF) Regulation to allow more time for the industry to react and the necessary infrastructure to be in place.  The proposed ACF rule is too early for the real world situation and could further handicap an already challenged industry that the US and world relies on for the timely delivery of most things we purchase, including goods, services, and food.

There are presently no Zero Emission trucks that can make the round-trip between California’s Central Valley and the Ports of Los Angeles, Long Beach or Oakland. It will not be physically possible for most companies to be compliant by the current deadline.  Despite this fact, CARB plans on preventing any additional trucks from entering port service after 1/1/24 unless they are Zero Emission.  To note:  Drayage trucks do more than just shuttle containers between terminals or local yards; they shuttle containers/product to and from farms & facilities to the railroad 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 billions in losses in addition to thousands of lost jobs.  Adding this regulation at this time without opportunity for compliance, will devastate the Ag and Drayage industries and as a result, 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.


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Date and Time Comment Was Submitted 2022-10-11 12:16:54

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