I am writing today to ask to
extend the deadline for the finalized Advanced Clean Fleets (ACF)
Regulation to allow more time for industry and staff to
develop workable, affordable, and timely solutions. We
are extremely concerned that the proposed ACF rule will be
unworkable in the real world and could result in compromising the
delivery of essential goods, services, and food to Californians,
the nation, and the world.
As a proud and working member of the
California Almond community, we provide 85% of the world's supply
of almonds, and 70% of the nation's almonds. Of our 7,600 almond
farms, 70% are family owned and operated with 90% being less than
100 acres grown across 16 counties in California's Great
Central San Joaquin Valley, adding $9.2B annually to California's
economy, and is one of the third largest agricultural exports for
the US.
At this time, there are no Zero Emission
trucks that can make a round-trip between California’s
Central Valley and the Ports of Los Angeles, Long Beach or Oakland.
Despite this fact - the solutions for compliance not being
available - CARB plans on preventing any additional trucks
from entering port service after 1/1/24 unless they are Zero
Emission. Drayage trucks do more than just shuttle containers
between terminals or local yards; they shuttle containers and
almonds to and from our farms & facilities to rail spurs
and coastal ports. For shippers and trucking companies who
upgrade their trucks on a regular basis, they will be out of luck
in just 14 months, because the truck they need to
comply with this proposed regulation is not commercially
available at scale yet.
Supply chain disruption since the Covid-19
global pandemic has already created a socio-economic crisis in our
community, resulting in tens of millions of pounds of almonds being
sold, but not shipped or paid for, resulting in a nearly $2B loss
to our community and 110,000 employees. We fear adding this
regulation at this time without option or opportunity for
compliance, will further devastate our industry, our California
rural communities, and our American export
economy.
Please, extend the deadline for the
finalized Advanced Clean Fleets (ACF) Regulation to allow
more time for industry and staff to develop workable, affordable,
and timely solutions.
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