California Air Resources Board

Dear Compliance Assistance and Outreach Branch,

I appreciate the opportunity to provide input on the Used Truck Voucher Pilot Concept as part of the Innovative Small E-Fleet (ISEF) Pilot Project. With years of experience in selling used trucks, cars, equipment, RVs, powersport vehicles and boats, I have firsthand knowledge of the challenges and opportunities within the secondary vehicle market. Below, I provide insights and recommendations based on my industry expertise and market data.

Key Stakeholders for Program Design

Small fleet owners, ZEV manufacturers, financial institutions specializing in commercial vehicle loans, charging infrastructure providers, and industry associations should be actively involved in shaping the program.

Dealers with experience in heavy-duty trucks and commercial vehicle resale should contribute insights on pricing trends, certification processes, and market demands.

Collaboration with organizations like the California Trucking Association and California Electric Transportation Coalition would ensure realistic and sustainable implementation.

Voucher Distribution Through Certified Dealers

Using HVIP-approved dealers ensures transparency and streamlines the voucher process. However, expanding eligibility to certified used vehicle dealers would increase the availability of quality ZEVs in the secondary market.

Incentives should be provided to dealers that meet training and certification requirements to inspect and repair ZEVs, ensuring they can properly assess vehicle health and longevity.

Fleet Size and Revenue Caps for Eligibility

Most small fleet operators have fewer than 20 vehicles and generate under $5 million in annual revenue. Setting these limits ensures that funding reaches those who need assistance the most.

Allowing flexibility in the cap based on operational needs and geographic constraints would help small businesses transition smoothly.

Tiered Incentive Structure Based on Vehicle Condition

ZEVs with lower mileage and higher battery capacity should qualify for higher incentives due to their extended usability and efficiency. Suggested structure:

30% incentive for vehicles with fewer than 100,000 miles and over 80% battery capacity.

20% incentive for vehicles with 100,000–200,000 miles and 60–80% battery capacity.

10% incentive for vehicles with over 200,000 miles or under 60% battery capacity.

Dealers purchasing ZEV fleets from out-of-state auctions should receive additional incentives to cover shipping, inspection, and unforeseen repair costs. This would ensure a wider availability of quality used ZEVs within California.

Prioritizing vehicles with lower emissions and higher efficiency will contribute to achieving California’s clean air and sustainability goals.

Vehicle Certification and Quality Assurance

Vehicles should meet Original Equipment Manufacturer (OEM) certification standards to verify safety and performance.

Battery State of Health (SOH) certification should be mandatory to ensure fleet owners understand the vehicle’s remaining capacity and expected performance.

Independent third-party inspections could enhance credibility, prevent subpar vehicles from entering the market, and provide transparency in resale valuations.

Mileage and Age Restrictions

Vehicles should be capped at 250,000 miles and be no older than 7 years to ensure long-term reliability.

Vehicles within these parameters hold better residual value, require fewer repairs, and are more attractive to fleet buyers.

Reporting and Accountability Measures

Fleets receiving vouchers should maintain performance records for at least five years to track vehicle efficiency, cost savings, and emissions reductions.

Annual reporting should include mileage logs, operational costs, and maintenance records to assess the program’s impact.

A structured review process will help refine the program over time based on real-world data and fleet owner feedback.

Extended Warranty Support

One of the biggest concerns for used ZEV buyers is battery replacement cost, which remains a significant financial burden. A minimum one-year warranty covering powertrain and battery systems should be required.

Additional warranty support for high-mileage vehicles would improve buyer confidence and encourage broader adoption among fleet owners.

Challenges Facing Used ZEV Buyers

Battery degradation is the biggest concern, as it directly impacts vehicle range and efficiency. A standardized method for battery health assessment should be implemented.

Limited charging infrastructure, particularly in rural areas, may discourage adoption. Targeted incentives for charging station deployment could alleviate this issue.

Upfront costs remain high despite incentives. Creating low-interest financing options and insurance products tailored to used ZEVs would support small fleet owners in making the transition.

Additional Considerations for the Program

Dealers specializing in ZEV resale and repair should receive additional incentives to expand their expertise and cover operational costs related to acquiring, inspecting, and maintaining used ZEVs.

Encouraging collaboration between financial institutions and fleet operators will create leasing options that lower upfront costs for small businesses.

Educating fleet owners on ZEV maintenance and charging logistics through training programs will ensure long-term program success.

Establishing a marketplace for certified used ZEVs, where fleet owners can confidently purchase quality-assured vehicles, would further strengthen the program.

Thank you for considering my input. I look forward to collaborating on this initiative and contributing to the successful implementation of the Used Truck Voucher Pilot Program.

I've attached a word document with the above information as well.