Roadstar Trucking, Inc.-Hayward, California
appreciates the opportunity to provide public comment on the
Proposed Advanced Clean Fleets Regulation (ACF). We support a
transition to new vehicles that will address climate change, but we
fear CARB’s plan does not fully address many issues in this
transition.
While our fleet size is currently under 50
vehicles, we see logistical problems in rolling out this
regulation. We want to understand in concrete terms how CARB will
guarantee that the clean electric supply as well as the
distribution grid will be reliably capable of supplying the
necessary capacity down to the actual transportation location that
will need fast charging technology.
We also believe that even with all proposed
subsidies for the site level charging infrastructure or Hydrogen or
other clean fuels and for the actual zero emission vehicles will
fall far short of requirements for individual fleets to put in to
service.
While OEMs are making headway in development
of zero emissions equipment, these vehicles will remain
“test” vehicles for some time before they are proven
and reliable. The necessary technician workforce able to support
maintenance of these vehicles is also a concern and will take time
to develop. In the meantime, we are going to see unacceptable
reliability.
We have not seen detailed information
regarding cost to the supply chain customers dependent on trucking.
It is too simplistic to say that electric vehicles will be cheaper
to operate than diesel powered vehicles.
Carb needs to make the case to the shipping
public how these issues will be addressed.
We urge you to amend the ACF regulation for
more flexibility so that the regulation catches up with technology
and not technology catching up with the regulation.
Thank you,
Robert Ramorino
President
Roadstar Trucking, Inc.