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Comment 305 for Proposed Advanced Clean Trucks (ACT) Regulation (act2019) - 15-1.

First NameNathan
Last NameChan
Email Addresschan.nathan.th@gmail.com
AffiliationUrban Environmentalists
SubjectAdopt this Rule, Ideally Make It Even Stronger
Comment
When car traffic fell by nearly 40% due to Covid-19-induced
Shelter-In-Place policies, it was thought dramatic improvements in
air quality would follow. However, NPR recently reported that ozone
levels have fallen by much less than car traffic has. In Los
Angeles, heavy duty transportation is now the largest source of
this toxic air pollution, and truck activity was down by much less
than passenger vehicle activity
(https://www.npr.org/sections/health-shots/2020/05/19/854760999/traffic-is-way-down-due-to-lockdowns-but-air-pollution-not-so-much).
To make any more improvements in air quality for our most
vulnerable people and communities, we need a strong clean trucks
rule like what is being proposed.

CARB should make this rule even stronger. If Norway could adopt a
50% goal for new truck sales by 2030 back in 2017, then California
can surely do better than 30%. (see attachment)

If CARB is concerned that battery technology will not be economical
enough to support widespread adoption, battery costs continue to
fall faster than initially estimated. In 2017, ICCT forecasted
battery costs of $228/kWh by 2020 and $120/kWh by 2030. Now, BNEF
projects battery prices will drop below $100/kWh by 2024 and hit
$61/kWh by 2030
(https://bnef.turtl.co/story/evo-2020/page/6/1?teaser=yes). In
fact, in 2019, they calculated  prices were already $156/kWh.
(https://about.bnef.com/electric-vehicle-outlook/)

There is both a moral and economic imperative to adopt a stronger
rule. We hope CARB does that.

Attachment www.arb.ca.gov/lists/com-attach/4120-act2019-VCNWNVEmBz4LIFRl.pdf
Original File Namewevj-11-00005-v2.pdf
Date and Time Comment Was Submitted 2020-05-28 22:17:26

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