Thank you for the
opportunity to comment on the proposed regulations. CARB’s plans for
gradual ZEV deployment are enthusiastically supported, however
overall statewide plans to deploy ZEV’s for the stated goal
of reducing tailpipe emissions must also allow cities the
flexibility to focus on market ready and available technologies and
financing strategies, including incorporating deployment of
existing low-carbon and renewable fuels such as Renewable Diesel
and Renewable Natural Gas. These renewable fuels can provide
similar “right now” emissions benefits while the ZEV
plans are executed and are critical to the success of achieving
these goals. Examples of this successfully being deployed are found
in the Innovative Transit Rule which currently requires large
transit fleets with diesel busses to operate them on Renewable
Diesel. Mandating statewide use of Renewable Diesel allow immediate
carbon footprint reductions and actually achieve ARB GHG reduction
goals earlier than relying solely upon ZEV strategies for
compliance.
Infrastructure
upgrades costs to enable large scale ZEV deployments are extremely
high for fleets which typically operate in a depot model,
consolidating vehicle domiciling in a small area. This will require
a significant investment increasing the electrical power feeding
these locations, which typically will require trenching and/or
additional power feeds. These modifications are most cost-effective
and successful when performed as a single project which requires
identifying and scoping total power requirements for 100% fleet
electrification (allowing for exemptions) and performing the
upgrade may be necessary prior to the arrival of the ZEV equipment.
Integrating these factors into the rulemaking will improve outcomes
and improve the implementation pathway for fleet owners.
Funding to support
the incremental vehicle acquisition costs and charging
infrastructure installation costs must be provided to COVID-19
cash-strapped fleet operations. Competitive grants and complex
application mechanisms disadvantage smaller fleet operations and
will likely create inequities penalizing fleets that actually need
the funding the most. The mandated ZEV acquisition costs are
significantly higher than current inventory petroleum fueled
equipment so any proposed acceleration of existing replacement
schedules requires funding not just for the incremental costs, but
for the total acquisition costs of any additional quantities of
vehicles now identified for replacement beyond the fleet’s
existing replacement schedule. Additionally, the incremental costs
identified by CARB staff in ACF materials significantly
underestimates costs that the City of Oakland is seeing in the
market. In fact, CARB’s own acquisition data for Medium/HD
vehicles found on the ARB HVIP funding website are significantly
higher than data for the same vehicles found in the ARB ACF
documentation.
The timeline for
implementation is not realistic and encourages a piecemeal approach
to installing required EV charging infrastructure due to the tight
timelines. This is neither realistic nor cost effective. It is
relatively straight forward to add charging capability up to
existing facility electrical available, but the next step beyond
this is typically a large-scale increase to power to the facility.
Additionally, multiple fleet customers all building out EV charging
infrastructure to maximum on the same circuit may be expected to
identify and trigger issues at any weak spots in the existing grid
that may not necessarily be an issue at existing demand. This may also be expected
to increase cost and extend compliance timelines. These costs and
timelines are largely facility specific, however installing a
typical additional power drop to a facility by PG&E prior to
ACF took about 18-24 months. Since every fleet in the state will
now be asking for similar improvements/upgrades, the actual
adjusted timeline needs to be identified and accommodated for in
the implantation plan. Furthermore, due to the large numbers of
fleet customers requiring significantly larger amounts of
electricity, it can be expected that some locations will actually
require a more involved solution such as a sub-station or other
larger scale grid project to support the multiplied customer
demand. Accommodations to the implementation plan need to be made
to allow for these activities which may require CEQA or other
time-consuming approvals. Most recently, a transformer shortage is
contributing to upgrade timeline delays and cancellations as
existing transformers are held in inventory for replacement of
existing transformers that fail in service or otherwise become
unserviceable.
Factoring Total
Cost of Ownership over the life of an EV into acquisition funding
discussions fails to acknowledge the distinct differences between
capital acquisition funding sources and use restrictions and
Operations and Maintenance (O&M) funding sources and use
restrictions. This methodology may be appropriate for light duty
sedans and high mileage/use transit applications, but the practical
implications for medium and heavy duty fleets do not hold true in
current market conditions. Even in the more mature light duty
vehicle market, the existing TCO models for EV’s don’t
show cost parity or potential costs savings until the last 10% of
vehicle life or later. It is unrealistic to anticipate fleets to
fund significantly increased capital acquisition costs, through
anticipated savings in O&M that are projected 10 or 15 years in
the future. It is also unclear if the higher rates for electricity
in California were included in the TCO analyses relied upon by ARB
to identify these potential ZEV TCO savings.
Facility
electrification goals and mandates must also be factored into these
regulations. While electrification to accommodate light and
medium/heavy duty fleets, many jurisdictions like Oakland are also
endeavoring to eliminate natural gas service to facilities in favor
of electricity. These additional demands may be expected to
increase costs of electrical upgrades and place further demands and
stress on the existing grid. These facility electrification
projects are also taking place at numerous locations in addition to
the fleet depot facilities which needs to be identified and planned
for in power increase/grid improvement plans.
The City of
Oakland supports aggressive action on expanding zero emission
vehicles and infrastructure, but needs regulations and incentives
that work with the competing and challenging efforts to electrify
buildings and transportation systems simultaneously. With supply chain
shortages and first cost capital concerns dominating procurement
decisions, we recommend modifications to the draft regulations to
ensure full compliance and progress towards the State’s clean
energy and air quality goals.