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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