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Dear CARB,
We are very concerned about your proposed changes to the LCFS
Program.
We oppose the proposed reduction in credits generated by
e-forklifts. Unlike other EV's, our forklifts do not have energy
measurement devices. We would be faced with the additional expense
of purchase and installation of such devices.
LCFS Credit reduction will make it more difficult for our small
family-owned business to purchase and install meters to continue to
participate in this program. We are not as capable of installing
measurement devices as other large companies nor do we have the
number of forklifts over which to spread the costs of such devices.
 Our rural location leads to additional risk in the implementation
of metering due to issues with internet connectivity. 
If one or both of these proposed changes must be implemented,
please allow us a minimum of 2 years before adoption. This time
will allow us to evaluate and install the necessary equipment.
Please maintain the current level of credits and do not impose
metering requirements so that operations like ours can continue to
phase out the use of internal combustion forklifts and adopt the
use of electric units. 
Thank you,
Mike Noland