Comment Log Display

To whom it may concern,

Thank you for including our company in the 45 day public comment
process for the Zero-Emission Forklift Regulation.  We appreciate
the approach taken by staff in balancing the time needed to
transition from LSI equipment to ZE options.  

After review of the Proposed Regulation our comments primarily
center upon the exemption of diesel powered units as noted in the
ISOR and specifically on Page 4 of the June 27, 2024 Notice of
Public Hearing documents.   The last sentence of the 3rd full
paragraph on this page states:

"Certain types of forklifts, such as rough-terrain forklifts and
diesel forklifts, would not be addressed by the Proposed
Regulations".   

While we may have missed the inclusion of a reference to this
exclusion in our review of the Proposed Regulations, we didn't see
a specific notation of diesel forklifts being excluded from the
Proposed Regulation.  This may be inferred as the Proposed
Regulation specifically addresses spark ignited forklifts and
diesel forklifts are compression ignited.    

This distinction is made clear in the second full paragraph on Page
4 of the aforementioned Notice of Public Hearing.  However, we
believe it would be helpful for the Final Regulation to have a
clear reference regarding the exclusion of diesel forklifts.  
Additionally, the Proposed Regulation references reporting
requirements for diesel powered forklifts as well as the need to
justify the addition of diesel fueled forklifts in Section 3008(j).
  

In summary, due to the items noted above we believe that some
additional thought be placed into whether diesel fueled forklifts
are fully exempt from the Proposed Rule or conditionally exempt if
no other ZEV options are available.  If the latter is true and/or
reporting is required for newly added diesel powered forklifts, as
inferred in Section 3008(j), there should be a clear statement in
the supporting documents (ISOR, other discussion documents and
Notice of Public Hearing) of their inclusion under specific
circumstances.   

Lastly, Workshops put forth by CARB staff have been very helpful on
this and many other proposed rule changes.  Given the extent of
comments received and some of our comments noted herein, we believe
additional Workshop(s) on this Proposed Regulation (before and/or
after it's adoption) would be helpful to address any points
requiring further clarification.  

We appreciate the consideration of our comments and look forward to
participating in the rulemaking process as it progresses.

Regards,

Michael Caprio
Director of Government Affairs