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Section 2023.3(c)(1) states "For transit agencies on the diesel
path, in accordance with the requirements in section 2023.1, a
minimum 15 percent of purchase and lease agreements, when
aggregated annually, for model year 2011, or from the start model
year of Zero Emission Bus purchases, through model year 2026 urban
buses shall be zero-emission buses."  The meaning of the phrase "or
from the start model year of Zero Emission Bus purchases" is not
clear.  It is our understanding that the phrase is intended to
refer to transit operators that are not currently subject to the
ZEB regulation and become subject to the regulation in the future,
but this is not evident from the wording.  The sentence could be
interpreted to mean that the ZEB purchase requirement for diesel
path operators takes effect in 2011 or in whichever year an
operator first purchases a ZEB.  Two Bay Area transit operators
have already purchased ZEBs, but they are not yet subject to the
purchase requirement.  The wording of the sentence should be
revised to make clear when diesel path operators will be subject
to the purchase requirement.  The same phrase appears in
2023.3(c)(2).  Thank you for your consideration.