| Comment | We support the adoption of the Advanced Clean Fleet rule to reduce
pollution that disproportionately harms low-income, immigrant, and
communities of color. A major obstacle to meeting climate goals is
the misclassification of truck drivers. The trucking industry is
notorious for misclassifying drivers as independent contractors
even while the businesses retain functional control over their
operations. CARB has recognized this and we appreciate the
inclusion of the rule's definition of "controlling companies" that
ensures firms, not drivers, are accountable for the fiscal
responsibility of transitioning to clean vehicles. This is a
partial but necessary step towards worker justice. But applying the
rule to fleets with 50 or more creates a loophole that companies
can exploit to evade the ACF rule and that encourages
misclassification. We urge CARB to reduce the fleet size threshold
to 10 trucks and we hope to work with CARB to ensure owners of
fleets of all sizes are deterred from exploiting their drivers.
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