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.
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