Comment Log Display

As a significant lift truck fleet owner, we are submitting comments
on the proposed updates to forklifts in the LCFS regulation based
on our expertise in the industry.  As fleet owners, we invest major
capital resources and have significant compliance obligations in
the proposed ZEF rules.  We are often the trusted source of
information for businesses considering electrification and have
dedicated staff for the ongoing successful operations and
maintenance of our forklift fleet.
  Our comments on the proposed updates are as follows:
•	Metering requirements should provide flexibility to meter
batteries or chargers or use truck telematics so that the most
cost-effective technology can be deployed at any given location. 
This would frequently mean measuring the battery, but in some cases
could include using data from 'smart' chargers or other measuring
solutions.  Each site and lift truck deployment are different, so
providing for a range of data collection options is important. 
•	As fleet owners, we have the most robust data on our fleet and
are best equipped to collect data on all fleet operations including
energy used.  For example, we have access to hardware that can
monitor batteries that are deployed to a site and are best
positioned to set up the hardware and ensure data collection for
our fleet, regardless of location. These metering solutions come at
a cost to us to deploy, especially at scale, which is why it's
important to align the incentive with the entity incurring costs to
obtain accurate data.
•	The most significant compliance issue and greatest potential for
near-term electrification in forklifts is for businesses to move to
class I and class II forklifts. CARB should evaluate using lift
class, not load capacity as a parameter for adjusting credit
generation. 
•	Reducing credits for forklifts <12,000 lbs. capacity at the same
time that businesses are facing expenses to comply with the new
Zero Emission Forklift rules for forklifts <12,000 lbs. capacity
sends the wrong message and comes across as indifferent to the
significant costs to businesses for compliance.  

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Date and Time Comment Was Submitted: 2023-03-13 14:47:32