Dear Sir or Madam
The proposed requirements within the advanced clean fleet for
drayage trucks beginning 1/1/2024 is impossible to meet. I
understand the concerns regarding the environment. However your
office and the drayage community needs to come together and build
the infrastructure we all need so that this mandate can be
successful.
Unfortunately, the infrastructure for this mandate is not there
yet. For starters our state power grid can not support this mandate
or our current annual heat waves. There are not enough recharging
stations or fueling infrastructure in place to support a mandate
requiring all vehicles entered into the statewide Drayage Truck
Registry to be zero emissions. Additionally, there are not enough
mechanics or automotive repair shops that have been certified to
work on these costly trucks statewide or nationally.
Please take into consideration that if this rule is adopted, it
will no doubt result in thousands of small fleet operators being
forced out of business.
Lastly, please consider pushing any initial entry standard for
drayage trucks operating in California out until the infrastructure
has been built to support the deployment of tens of thousands of
zero emissions drayage vehicles.
Thank you in advance for taking the time to read my
concerns.