Comment Log Display

April 7th, 2023

Clerk of the Board
California Air Resources Board
1001 I Street, Sacramento, California 95814

RE: Modifications for the Advanced Clean Fleets Regulation

As the third generation of a family-owned business in our 90th year
in operation in California we are writing you to as the employer of
64 people who work full-time in the fuel sales and transportation
segment on the Central Coast of California. Our customers depend on
us to deliver produce, grow their crops, build roads, buildings and
the infrastructure used throughout California and to provide
emergency services for police, fire, and ambulance services.

JB Dewar Inc. respectfully opposes the adoption of modifications to
the Advanced Clean Fleets rule as it continues its attempts to
transition the transportation and goods movement economy much too
quickly without sufficient regard for the necessary infrastructure
overhaul in the state, a realistic consideration of the state's
power grid capabilities, and the lack of an adequate and accurate
cost analysis.

Modifications to the regulation's proposed timeline still do not
address the significant strain on the transportation industry and
will continue to gravely hamper goods movement in the state.
Additionally, the cost of replacing fleets with entirely zero
emissions vehicles will unduly harm small businesses in the state,
many of which are family- and minority-owned. With the limited
supply and options for heavy duty ZEVs, large companies with
greater capital will be prioritized by manufacturers as compared to
their small business counterparts. The highly restrictive timeline
that continues to be proposed in the modifications will only serve
to further exacerbate this problem in the market. 

JB Dewar Inc. continues to have significant concerns because the
regulation's modifications do not sufficiently consider the current
and future needs of the transportation industry within the state.
The range of vehicles that are currently offered on the market will
not ensure a seamless transition, as many heavy-duty vehicles are
often used continuously to ensure the timely delivery of goods to
other businesses and consumers. Moreover, the infrastructure
necessary to support a full transition to zero emission fleets is
not prevalent enough to serve the vast number of vehicles CARB
intends to replace. This regulation, even as modified, will be a
major disruptor to the state's supply chains, which will increase
the cost of goods at every level, and negatively impact our most
vulnerable communities and residents the most. 

For these reasons, we must continue to respectfully oppose the
adoption of the Advanced Clean Fleets rule as modified.

Ken Dewar 
President
JB Dewar Inc.