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.