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Please stop making it harder and harder to operate a business in
California. Every year there is a new fee or in the case here,
additional costs and less credits for doing the right things (e.g.
operating electric equipment at my facility).


I am opposed to reduction in number of credits generated by
e-forklifts for the reasons below:

·                  Unlike other EVs, most forklifts do not have
energy measurement devices, making this an additional expense in
hardware as well as resources to implement

·                  The reduction of credit generation will make it
difficult to finance implementation the required metering.

·                  I Recommend leaving the current credit
generation or evaluating ways to temper the reduction

·                  These changes make it more difficult for smaller
operations to participate as the cost of metering cannot be split
across as many forklifts as larger operations

•                          Implementation of metering:

·                  More time needed for implementation: The time
needed to evaluate appropriate solutions relative to specific fleet
(e.g. charger frequencies) and operating conditions (i.e. cold
storage) and cost-effectiveness relative to estimated revenue. 
·                  If more time is not allowed, there may be months
or up to a year that we are not able to participate in this
program, which is a dramatic change rather than the more typical
phased-in approach used by CARB to avoid volatile impacts on
businesses.

·                  Recommend extending estimation method for
several quarters to give industry opportunity to adapt.

Regards,
Yasser Jaber
Vice-President
Seagate Produce, Inc.