Liane M. Randolph,
Chair
California Air Resources
Board
1001 I Street
Sacramento, CA
95814
Re:
THOR Industries’ Written Comments on Proposed Advanced
Clean Fleet Regulation
Dear Chair Randolph:
I am initiating this correspondence to you in my
capacity as Senior Vice President and General Counsel for THOR
Industries, Inc. (“THOR”). THOR is the world’s largest manufacturer of
recreational vehicles including motorhomes, travel trailers and
fifth-wheel trailers.
This letter is intended to serve as THOR’s
written comments on the California Air Resources Board’s
(“CARB”) proposed Advanced Clean Fleets (“ACF”)
regulations. For the reasons set forth below, THOR is requesting that
CARB amend the ACF to exempt motorhomes from its
requirements.
1. ACF’s Zero Emission
Requirements Impose an Undue Burden on the Motorhome
Industry.
Section 2016(d) of the proposed ACF requires
vehicles over 8500 lbs. GVWR (which includes motorhomes) and
offered for sale in California to be ZEVs beginning with the 2040
model year. If enacted, this requirement will have a substantial
negative impact on the motorhome industry in the State of
California.
Unlike automobiles, there are no zero emission
motorhomes currently being sold to consumers. While zero emission
motorhome concept vehicles exist, it is unlikely that these concept
vehicles will be manufactured for sale to consumers in the
foreseeable future. This is due, in part, to the unique batteries and motors
that are required to power motorhomes.
Switching to batteries and motors that produce
zero emissions will significantly increase the cost of
motorhomes. It is currently estimated that zero emission motorhomes
will cost approximately $50,000 - $100,000 more per unit than
existing gas or diesel powered motorhomes. A cost increase of this
magnitude will render ZEV motorhomes unaffordable for many
potential owners who will be forced pursue other recreational
activities to the detriment of California’s motorhome
dealers, service providers (e.g. campgrounds, parks, etc.) and
other businesses that rely on the motorhome industry. These negative economic
impacts on the motorhome industry can be avoided by simply amending
the ACF to exempt motorhomes from its requirements.
2. The ACF Fleet Milestone
Requirement Excludes Motorhomes.
The ACF establishes new regulations for owners of
motorhome rental fleets in California that include fifty (50) or
more motorhomes at any point of time in the course of a year. Beginning in 2024 and 2025
owners of such motorhome rental fleets will be required to comply
with either the “ZEV addition” requirements in S.2015.1
or the “ZEV fleet milestone” requirements in
S.2015.2.
To comply with the “ZEV addition”
requirements, owners of motorhome rental fleets are required when
adding to their existing fleet to purchase ZEV motorhomes unless a
ZEV unavailability exemption can be utilized. To comply with the
“ZEV fleet milestone” requirements, owners of motorhome
rental fleets are required to meet or exceed the ZEV milestone
percentage requirements set forth in Table A: ZEV Fleet Milestones
by Milestone Group and Year, as listed in Appendix A-2.
Table A provides “ZEV fleet milestone”
for three (3) groups (Milestone Group 1, Milestone Group 2 and
Milestone Group 3).
Each of the three (3) groups are defined in the ACF;
however, such definitions fail to reference motorhomes. As such, it appears that
owners of motorhome rental fleets are not eligible to comply with
the “ZEV fleet milestone” requirements and, instead,
are required to comply solely with the “ZEV addition”
requirements. If this
is interpretation is correct, owners of motorhome rental fleets
will be required to begin purchasing ZEV motorhomes (or utilizing
ZEV unavailability exemptions) in 2024 rather than 2040. Such a result is
nonsensical given the fact that no zero emission motorhomes are
currently being sold to consumers. Again, these negative impacts can be avoided by
amending the ACF to exempt motorhomes from its requirements.
THOR appreciates the opportunity to comment on
the proposed ACF.
If you
have any questions or would like to discuss THOR’s written
comments, please feel free to contact me. My contact information
is set forth below.
Sincerely,
Thor Industries, Inc.
By: Trevor Gasper, Sr. Vice
President , General Counsel & Corporate Secretary
Telephone:
(574) 970-7925
E-Mail: tgasper@thorindustries.com