Comment Log Display

Dear Chair Randolph,

While the proposed regulation has been amended to address some
industry concerns, there are still significant issues with the
rulemaking that must be acknowledged including cost, feasibility of
implementation, and inaccuracies of data in CARB's analysis. Main
points of contention are as follows: 

Actual impacted forklifts far exceed CARB estimate: CARB has
modelled the total affected forklifts of approximately 95,000,
though this inventory count is less than a third of the values
produced from the 2017 CARB/SSRC Study. CARB assumes that the
internal combustion engine (ICE) forklift population remains
stagnant though time has shown an increase in forklifts in the
state due to an increase in goods movement. After evaluating
forklift fleet owners and operators, CARB's proposal will actually
impact over 390,000 ICE forklifts - over three out of every four
forklifts in the state. 

Technical challenges of run time & operational loads could impact
overall cost: While CARB noted that "opportunity charging" may
resolve use needs, manufacturers and industry experts remain
skeptical that there is a one-to-one replacement for ICE forklifts
versus battery electric. Considering an 8-hour use period, 8-hour
charge period, and 8-hour battery cool down period for the bulk of
existing battery electric forklifts, it would actually be a
three-to-one replacement for businesses utilizing 24-hour shifts.
Such ratios would significantly increase the total financial impact
of this regulation. In addition, lift capacities of battery
electric units can make real-world runtimes for heavier loads much
lower than rated capacities. 

Burdensome costs to forklift owners and operators: CARB's
Standardized Regulatory Impact Assessment (SRIA) estimates that the
proposed regulation will result in cumulative savings of over $13.9
billion. Unfortunately, analysis undertaken by Andrew Chang &
Company, a consultant hired to determine the potential savings or
costs from the rulemaking, has shown quite the opposite. In total,
the proposed regulations will cost forklift owners and operators as
much as $28 billion in extra expenses. Even under midpoint
estimates, owners and operators must bear nearly $20 billion in
costs. 

Propane-powered forklifts are the more affordable fuel option: ICE
forklift fuel costs decrease substantially when propane fuel costs
are utilized. When propane is used as the fuel of choice for ICE
forklifts, ICE forklift fuel costs go down by approximately 55%.
Cumulative fuel savings when using propane add up to $1.87 billion,
while cumulative fuel savings when using gasoline amount to $5.25
billion. Utilizing propane as the main source of fuel for ICE
forklifts provides a more accurate depiction of ICE forklift fuel
costs as the majority of forklifts are propane-powered. Considering
that the fuel savings generated by CARB make up approximately 47%
($8.2 billion) of CARB's cumulative regulation benefits,
transparency on their fuel cost methodology is essential. 

Renewable propane drastically reduces GHG emissions without
significant financial investment: The propane industry has made
extraordinary strides to expand production of low carbon renewable
fuels for the transportation sector within California. These
strides have been made in part thanks to the work of CARB in its
implementation of the Low Carbon Fuel Standard. Renewable propane
carbon intensities range from half- to one-quarter of the carbon
intensity of California's current electric grid. With current
blending and transitions to all-renewable fuels, propane has
outpaced carbon emissions for California's electric sector in
transportation - particularly off-road forklifts. 

I appreciate the opportunity to submit this document regarding the
rulemaking in hopes of adopting an equitable solution for forklift
owners and operators.

Regards, 
Adina Chapman 
8300 San Marcos Rd
Atascadero, CA 93422