Comment Log Display

Kim Mesfin, President of Affinity Truck Center.  I represent the
Volvo, Mack and Autocar franchises in the Fresno, Bakersfield,
Salinas and Paso Robles area.  I have 140 employees 10 of which are
truck salesmen that have worked with us for 3 to 43 years.  Those
salesmen maintain a consultative vs transactional relationships
with our very diverse customer base.   
 
CARB has regulated aspirational goals to meet our much needed air
quality improvements. I feel we have gone too far, far too fast. 
We have regulated laws in a boardroom without consistent input from
stakeholders operating in the industry and on the street.  I know
you speak to the Manufacturers regularly, but they are also not on
the ground working with customers and the equipment. I am very
hopeful that you are soliciting for these exact people to weigh in
on the administration of ACF.

I have spent the last 9 months trying to understand the interplay
of these three new regulations that all go into effect in 70 days.
It remains difficult. No one is yet an expert.  It is all new
territory and we learn something new that was not considered every
day. I actually feel that even CARB is not yet an expert, but these
regulations are being implemented on an unsuspecting and unaware
public. I have fought to get this information out to our staff and
customers, but it is too much in too short a time window.

We are all behind improving our Valley air, but when our
aspirational goals are technologically and financially unachievable
by the forecasted timeline, it is irresponsible to press forward.
CARB did not intend to regulate diesel trucks out of circulation
prior to the availability of replacement zero emission technology
for all classes of trucks, but that is where we are today.  The
July amendment we are gathered for today, involving complex
mitigation credit formulas, was a great effort to make additional
trucks available within our CA market place. Still too far, too
fast.   In May, I knew I would have zero diesel trucks available to
sell. The net result was that I now have 37 trucks toward the 500 I
would normally sell and 4 natural gas trucks. The rest have not
been designed to certify and will not be available across all
classes of truck function. I would normally have 450 trucks to
start the year. The complex mitigation formulas associated with
credit recapture and higher prices all calculated in arrears is too
complex for the business market place.

All brands of manufacturers are stymied by the credit calculations
associated with the CA registrations.  Fear of penalties keeps them
excessively conservative in their CA production.  The research and
development dollars that go into designing, testing and certifying
a .1 CARB 2024 engine, instead of putting those dollars into
research and development of ZEV is dollars wasted.  Customers will
not pay $20k more for a first run trial engine that emits a
microscopically smaller amount of NOx and consumes more expensive
diesel than the truck they can buy today. Diesel prices continue to
grow.

It is disingenuous and deceptive to the public to hold tight to
this emissions reduction timeline, when in reality, customers will
be forced to chase loopholes and work around this stringent
regulation. OEMs of all brands will maintain current production of
EPA emissions vehicles allowable in all 49 states by diverting
production allotted to CA dealers and trucking businesses to states
outside CA. Customers will be forced to move their purchases
outside the state, but the law permits them to drive those vehicles
up to 90% of the time in CA.  Others will continue to run older
trucks or will by used units that pollute more than today's newer
units.

The CARB NOx regulation is a shell game that deceives the EJ groups
and all CA residents into believing CARB is aggressively helping to
clean California air.

I respectfully ask that CARB realigned CA NOx emissions with that
of our other 49 states under EPA NOx regulations.  Those three
additional years will let CA retain small business truck purchases
within CA generating necessary tax revenue and retaining jobs down
stream of truck sales.  The 2027 EPA regulation of .035 is even
stricter than CARB's stair step approach to further regulating out
the last 2% of NOx. The OEMs need that time and all those research
and development dollars to create ZERO emissions vehicles across
all truck classes and functions.

CA feeds the nation and needs to keep product moving from the field
and warehouses to the world.  We should not give that
responsibility to trucking companies outside CA.

We all like our garbage to be collected, the firemen to arrive when
called and our store shelves to be full.  If one of our garbage
companies, fire departments or ambulances wrecks a truck or has a
catastrophic engine failure, there are severely limited replacement
diesel trucks available for purchase in the state of CA. We will go
without.

These same diesels could be mandated to utilize only renewable
fuels and still operate during their useful life while keeping our
communities clean, safe and our supply chain undisrupted.  We need
to prevent job loss in this transitional time.

We are all in on ZEV and cleaning our air.  The technology with
limited range, high cost and first run product failure is only
available in the day cab, return to base application. 80% of the
trucks I sell are sleeper trucks that haul the ag products we grow
across the nation. 

Without a technologically proven, affordable ZEV or near ZEV
solution for all classes of diesel trucks, you cannot aggressively
ban today's diesel engine without a viable alternative.

Please delay the CARB NOx Omnibus CA regulation to align with EPA
NOx 2027, so manufacturers can invest those R&D dollars into viable
ZEV technologies and charging infrastructure.  We must avoid the
coming supply chain disruptions and job loss that will result from
the legislation up for approval today.

I am here today to speak on behalf of my employees, my customers
and my community members in addition to all the other board seats I
represent. We need responsible change to zero and near zero
emissions trucks. CARBs regulation as written today are a man made
disaster with devastating impacts.  

Please go back to the table and look at trucks by class and by
purpose.  Let's drive zero emissions trucks hard into the classes
where they fit.  
Look harder at alternative renewable fuel options for existing
combustion engines on the road.
53% of the trucks on the road in CA today are older that 2010 clean
diesel technology.  Put the money and incentives into getting those
old vehicle off the road and into today's clean diesel vehicle.  We
would instantly have 83% cleaner air.

Mr Cliff, you are responsible for the state for cleaner air.  The
regulations as written today will not improve the air, and will
force older trucks to run and pollute longer or people to buy
outside an run it. 
 
Do not devastate my business, my salesmen's and customer's
livelihoods, our state's supply chain.  These tight
dealer/salesman/customer relationship are exactly what you must
keep in tack, so that we can help them transition to the future ZEV
technology.   We can do this together. Please bring us in. Not in
scripted formats in hearing, but as actual consultative teams to
drive this agenda.