NAA Comments in Opposition to the California Clean Air Act Waiver
The National Aquaculture Association (NAA) has submitted a comment letter to the Environmental Protection Agency in opposition to a State of California request to waive Clean Air Act provisions governing vehicle emissions.
The regulations, which have been adopted by the state agency, require incorporation of zero-emitting vehicles beginning in 2024 for state and local government fleets, drayage truck fleets, federal agency fleets, and large commercial fleets that own, lease, or operate on-road medium-duty and heavy-duty vehicles, and light-duty package delivery vehicles.
The regulations also require that all new California-certified medium- and heavy-duty vehicle sales be zero-emitting vehicles starting in 2036. Elements of the regulation apply to off-road engines and equipment, specifically off-road yard tractors.
In part, the NAA’s letter noted the California regulations cannot be met by the farming community for a lack of 1) available technology of the capability and capacity in the form of zero emission trucks suitable for fish and shellfish farmers, and 2) a sufficient rural electric power infrastructure. State of California provided truck sales data indicates as much; however, the analyses they did provide does not address three critical questions:
- Do zero emission trucks provide serviceable alternatives (capacity and capability) under all temperatures versus existing diesel and gasoline powered trucks used by the farming community?
- How many additional zero emission trucks would have to be purchased to replace current vehicles?
- What are the real costs, not as influenced by optimistic market-based credit and tax credit assumptions, to purchasing, using and maintaining zero emission trucks?
Farms and businesses that operate in California or recognize truck technology is not available to fulfill farmer or live haul transportation needs should comment to the agency. This is a link to the EPA Federal Register notice seeking written comments: https://www.govinfo.gov/content/pkg/FR-2024-07-12/pdf/2024-15343.pdf. Written comments are due September 16th.
Written comments can be submitted here: Regulations.gov.