First Name | Glen |
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Last Name | Tepke |
Email Address | gtepke@mtc.ca.gov |
Affiliation | Metropolitan Transportation Commission |
Subject | Modified Text for the Proposed Amendments to the Zero Emission Bus Regulation |
Comment | 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. |
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Date and Time Comment Was Submitted | 2007-08-10 17:53:29 |
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