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The stricter version of the electric truck standard could put a lot
of small transportation companies out of business without state
grants to help purchase electric trucks. I would hope the Board
consults with the truck manufactures and the companies that need to
set up the electric infrastructure to handle the transition to
electric trucks and see what kind of timeline they need to be ready
to handle this major change in industry standards.

Electric trucks will not work for interstate movements but I
believe hydrogen/electric trucks will. There are not enough
electric truck manufactures to meet the new percentages you propose
by 2030. 

A lot of transportation companies went out of business when the
last emission standards were put in place due to the major repairs
that had to be performed on trucks because the manufactures
engineering departments did not have enough time to adapt (e.g.,
turbocharges having to be replaced due to excessive heat from the
emissions components at 350,000 miles for $7,500 that usually last
900,000 miles, EGR valves, particular filters and on and on all
VERY expensive emission components). 

I would hope the board works with manufactures and discusses the
challenges they face before the board puts impractical policies in
place. Unrealistic rule making never benefits any industry
especially when it has become evident how important trucks our when
a pandemic occurs.

I urge you to rethink your timelines and consider the realistic
goals you wish to achieve taking in to account all the parties
involved. I want clean air just as much as you do and I truly
believe we can get to zero emission trucks in a workable timely
manner. 
Trucking keeps America going and without it the shelves in the
stores could empty faster and longer when the next pandemic hits.

Thank you for your consideration.
Allen L. Genetti, CPA, CFO
California Tank Lines Inc.
Chemical Transfer Co.