Comment Log Display

Dear Chair Randolph,

In the coming months, new, lowest-emission towing and recovery
trucks will no longer be built or sold in California unless CARB
amends the Advanced Clean Trucks regulation, as Miller Industries
requested.

California's towing and recovery drivers are not just service
providers, they are the backbone of our highway public safety
system. They ensure motorists' safety around the clock, assist
first responders, and clear over 1,200 road accidents and 2,400
mechanical breakdowns daily. Governor Newsom underscored their
importance during the COVID-19 pandemic when they were recognized
as part of California's "Essential Critical Infrastructure
Workforce."

When the California Air Resource Board (CARB) enacted the Advanced
Clean Truck (ACT) regulation, the board recognized that truck
manufacturers had not developed electric engine alternatives that
meet an emergency service vehicle's range, performance, and safety
standards. So, CARB exempted emergency vehicles such as police and
fire vehicles, including government-owned towing and recovery
vehicles - but not towing and recovery trucks operated by private
businesses.

The unintended consequences of the current regulation are becoming
increasingly apparent. In the coming months, the production and
sales of towing and recovery vehicles will grind to a halt, with
existing inventories rapidly depleting. This is leading to a
paradoxical situation where towing services are barred from
acquiring new, lower-emission chassis assembled in California,
while used, higher-emission trucks can be imported from
out-of-state. The result is a loss of jobs and increased emissions,
which could be avoided with a simple exemption, even if temporary.

At a time when California is facing the country's highest
unemployment rate, we need a solution that exempts ALL towing and
recovery trucks from the ACT deficits for manufacturers until ZEV
chassis are available.

The clock is ticking for small businesses, their employees and
truck drivers who are the lifeline of emergency and roadside
services for millions of California motorists.

Thank you.

Sincerely,

Mark peeples
2361 Fruitvale Ave Apt Apt3
Oakland, CA 94601
mwill666@yahoo.com