Comment Log Display

Thank you for the creation of this program and the continued
improvements CARB is making to the LCFS Program.  With ~6,000
trucks coming off the drayage registry in the next 3 years, that
must be replaced by ZEVs, a strong LCFS is crucial for attracting
the investment necessary to build the needed charging
infrastructure.  

Getting the details right on this LCFS program will accelerate the
adoption of EV heavy-diesel trucks that are poised to grow
exponentially just as we are witnessing in the EV passenger and
small truck market. 

To this end, we recommend several important improvements to the
program:


1.	Allow heavy duty trucks to qualify for the Fast-Charging
Incentive Program. The importance of this program for heavy duty
vehicles can't be overstated as it has proven necessary to bringing
in the capital to finance the heavy-duty charging stations as the
FCI program provides downside protection on the investment.   
Furthermore, Governor Brown's Executive Order B-48-18 (see below)
calls for putting "zero emission" vehicles on the road which
includes all vehicles, including heavy-duty trucks.  

Unlike commercial vehicle charging stations that can be installed
at a store, heavy duty vehicles will need dedicated sites for
charging.  We ask that the cost of the land be included in the
capital expenditures paid back through the FCI program.   Lastly,
recommend that the associated solar and storage integral to the
charging stations be considered as well.

2.	Support extending LCFS beyond 2030. Investors time horizon for
analyzing such investments extends beyond the current end of the
LCFS program.  Clearly laying out the declining LCFS requirements
beyond 2030 will allow investors to amortize the costs of electric
trucks and infrastructure over a longer time horizon, thereby
lowering the costs in the short term. Lowering the costs will also
help to accelerate the adoption of EVs. 

3.	Support strengthening pre-2030 targets for LCFS.  This will send
market signal to attract the needed private investment in
transportation decarbonization.  We believe the program should
prioritize and/or provide more value to project/vehicles located in
the state.

4.	Support specifying EER classification between medium and
heavy-duty (diesel replacement) applications.  This will spur
investments in vehicles that create the greatest decarbonization in
alignment with the goals of the LCFS program.