Re: Proposed Advanced Clean Fleet Regulations
(ACFR 2022)
Dear Members of the California Air Resources Board
(CARB),
We are submitting the following comments on your Proposed
Advanced Clean Fleet Regulations, as a Motor Carrier, Broker and a
Warehouse service provider based in LA/LGB and Oakland,
Ca.
We understand the goal of California and the desire to
advance the clean air initiatives, especially in and around the
maritime facilities in our state. We are based at both above-mentioned maritime
area with facilities and employees that breathe the air every
day. Although,
we agree that the Ports need to evolve and meet the goal of
reducing emissions to bring about an environmentally cleaner
workplace; the burden seems to always fall onto the operators and
especially the truck operators currently servicing the maritime
industry at these facilities. The proposed regulation, despite grants and
assistance, puts an enormous burden on companies like PCC and the
drivers that have worked with us for multiple decades.
We ask you to reconsider the following:
Termination of 2008-2010 Legacy trucks at the
end of 2022.
Although many of the contracted carriers for PCC have
upgraded their equipment to qualify for the Legacy provisions of
the proposed ACFR; there are many who have been priced out of this
upgrade due to the Post Covid supply chain issue that has minimized
the available used trucks in the market. Many have argued that truckers have had ample
time to adjust to this regulation and being unable to qualify at
the last hour is irresponsible. Although, all the truckers have been aware of
the schedule for truck termination; we can all agree that the past
three years have not been “normal” or expected by
anyone. The pandemic
has brought forth numerous extenuating circumstances including
inflation, reduction of available trucks and inability, especially
older truckers, to work a regular schedule due to family and
medical concerns.
We respectfully request that an extension of a reasonable
period is granted until the supply chain issues and used compliant
truck markets are normalized for these drivers. Class A truck drivers are
in shortage everywhere in the United States and to force these
qualified Port drivers to seek employment outside our state is a
losing proposition for the maritime industry and the State of
California.
Zero Emission Truck Requirement for Drayage
Truck Registry post 12/2023
The proposal to lock out diesel emission trucks regardless
of the MYE or MY by the end of the next year is unreasonable and
unachievable due to lack of infrastructure, limited performance of
ZEVs and the current cost of upgrade.
After next calendar year, the proposed ACFR would limit any
new trucks to the registry to be Electric or Hydrogen thus
qualifying as a ZEV under the CARB definition. The unproven performance
and current specification of the ZEVs are unfit for services
offered at the Port.
The lack of charging infrastructure, availability of power
grid, lack of Hydrogen stations and the gross weight of the
vehicles compromise trucking companies’ ability to deliver
service to the California consumers.
The Ports in CA and the distribution centers located in our
state rarely operates on a 24-hour basis. This translates to all port related trucks
needing a charge at the same period (mainly overnight). The infrastructure needed
for number of ZEVs proposed would take years to build and be made
available for the amount trucks that would populate the Ports
located in CA. In the
past month, during the heat wave, we were advised to turn power
down due to the strain on our power grid. Are we ready to place thousands of charging
stations in a concentrated area?
Although,
Hydrogen has been offered as an option, there are very few hydrogen
stations available in our state to make this option viable. Charging/Fueling options
need to be solidified prior to announcing any compliance date with
zero emission vehicles. Although the proponents argue they can be
built, we have very little confidence that the hydrogen/charging
infrastructure can be built by the end of 2023.
The weight of the ZEVs is of great concern to all truck
operators. The
average ZEV is 8,000 to 11,000 above the normal diesel rigs in
operation today. The
80,000 GVW or 82,000GVW for ZEVs is grossly inadequate for the
payload coming into our ports. We would have to ask our customers to decrease
their cargo weight (pay load) by 6,000 to 9,000 lbs. to accommodate
the extra weight of these vehicles. We are unaware of any legislative or
administrative relief to address this issue. This is a gross inequity
to the exporters of CA as they would have to decrease their exports
due to the limitation of the trucks proposed by CARB. Asking customers to send
less is a sure way to chase commerce out of CA.
Port Truckers are an asset to our state. The smaller fleets that
have serviced the Maritime industry for decades will be phased out
of the industry due to the cost of upgrading to a ZEV fleet. Port Truckers are a
specialized occupation in our industry as they possess the skills
to process the administrative burden put forth by international
trade, security clearances that are necessary to enter secured
areas designated by Homeland Security and the ability to navigate
the challenges at the Marine and Rail terminals. The inability to purchase
trucks that are 2 to 4X the current cost of diesel trucks will
devastate the driver pool that is already challenged by lack of
applicants.
The ACFR proposal to lock out diesel units by end of next
year is unrealistic and will cause disruptions beyond
imagination. We
respectfully submit that this policy be reviewed and delayed until
infrastructure and weight issues are resolved.