NFIB Requests Cost-Benefit Analysis from Colorado Air Quality Control Commission

December 19, 2022

NFIB Requests Cost-Benefit Analysis from Colorado Air Quality Control Commission

Colorado is one of 13 states that takes California’s lead on emissions regulations, and on April 19, 2023, the Colorado Air Quality Control Commission (AQCC) will address California’s Advanced Clean Trucks regulations with an eye toward modifying Regulation Number 20. According to the AQCC, “if you believe there will be a significant negative impact on small business, job creation or economic competitiveness, you may request that the Department of Regulatory Agencies require the rulemaking agency to prepare a cost-benefit analysis of a proposed rule or amendment. This request must be made to the Department of Regulatory Agencies by Sunday, January 15th, 2023. You may also submit comments directly to the rulemaking agency for the agency’s consideration during the upcoming rulemaking hearing.” On December 19, NFIB Colorado State Director Tony Gagliardi submitted the following request for a cost-benefit analysis, and he encourages members to do the same. —————————————- The National Federation of Independent Business (NFIB) is a 79-year-old association comprised of small and independent businesses involved in almost every industry imaginable. The average NFIB member has between 5 – 9 employees. The Colorado chapter of the NFIB believes modifications to Rule 20 concerning the requirement for semi-tractor truck manufacturers and dealers to begin aggressive marketing of electric delivery vehicles to end users will cause an exponential increase is cost to not only those purchasing electric delivery vehicles but also the customers of those purchasers. Another area of concern is the proposed program is not limited to large, heavy-duty trucks. The application of the rule to vehicles with GVW limits of 8,500 lbs. can include many light duty pick-up trucks and vans equipped with heavy duty suspensions. These lighter vehicles are often used by small businesses in industries such as printing, auto parts, and home maintenance services such as HVAC and office equipment sales and service. Currently inflation is at an all-time high. In a November 2022 study conducted by the NFIB Research Foundation of small business owners, the net percent of owners raising average selling prices increased 1 point from October to a net 51 percent seasonally adjusted. Unadjusted, 8 percent (unchanged) reported lower average selling prices and 56 percent (unchanged) reported higher average prices. Price hikes were most frequent in wholesale (73 percent higher, 0 percent lower), retail (69 percent higher, 7 percent lower), construction (66 percent higher, 5 percent lower), and manufacturing (63 percent higher, 5 percent lower). Seasonally adjusted, a net 34 percent plan price hikes (unchanged). Salaries for employees of small businesses are increasing exponentially due to the shortage of qualified workers. NFIB requests that a Cost Benefit Analysis be conducted to ascertain the proposed changes can be implemented with no or limited financial damage to Colorado’s small business economy. A.F. Tony Gagliardi 1700 Lincoln, 17th Floor Denver, CO. 80203 303-831-6099 For nearly 80 years, NFIB has been advocating on behalf of America’s small and independent business owners, both in Washington, D.C., and in all 50 state capitals. NFIB is a nonprofit, nonpartisan, and member-driven association. Since its founding in 1943, NFIB has been exclusively dedicated to small and independent businesses and remains so today. For more information, please visit nfib.com.