First Name | Steve |
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Last Name | Douglas |
Email Address | sdouglas@autoalliance.org |
Affiliation | |
Subject | Enhanced Fleet Modernization - AB 118 Comments |
Comment | The Alliance Of Automobile Manufacturers (Alliance) submits the enclosed testimony in response to the revised regulatory proposal implementing the Enhanced Fleet Modernization (EMF) component of AB 118. The Alliance actively participated in the extensive negotiations involving AB 118 and publicly supported its enactment. Historically, the Alliance has strongly supported Fleet Modernization programs, which promote safety and fuel economy while, simultaneously, reducing air pollution and greenhouse gas emissions. The Alliance supports the revised regulatory proposal with one significant reservation. Specifically, the Alliance objects to Section 2623(f) and requests deletion of subdivision (f) in its entirety. The automobile industry is beleaguered. Sales of new vehicles nationally have plummeted from historic highs (approximately 16 million, annually) to 10 – 11 million vehicle sales, annually. Manufacturing capacity has been reduced. Dealerships have closed. 2010 may be more promising, but daunting challenges remain. For example, financing is increasingly hard to obtain and expensive to procure. Consumers who wish, or need, to purchase a new vehicle in 2010 will confront limited financing opportunities. Certainly, no artificial impediment to the purchase of a new vehicle (and retirement of an old vehicle) should be erected. The Alliance considers subdivision (f) to be an imprudent impediment to an optimally-functioning EFM program. The intent of the EFM program is to create incentives to purchase new vehicles (and retire old vehicles). There is no provision in AB 118 that suggests incentives by other jurisdictions detract from the AB 118 program. Nothing in AB 118 compels rationing of incentives. To the contrary, the express purpose of AB 118 is to accelerate Fleet Modernization and avoid the inane and counter-productive limitations of other “scrappage” programs. Why discourage a robust EMF program by instituting artificial constraints? Do not constrain the Enhanced Fleet Modernization program (emphasis added) by imposing the limitation contained in (f). The Alliance notes that nothing in the proposed regulations is permanent. If deletion of (f) produces objectionable results, we will support an adjustment. However, in the absence of evidence demonstrating an objectionable result, we request deletion of (f). Thank you for your willingness to consider our position. |
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Date and Time Comment Was Submitted | 2009-12-22 11:50:37 |
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