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This is a point of clarification relative to Section
3007(b)3B1(c&d) - Page 47 - Fleet Eligibility Criteria for an
Infrastructure Site Electrification Delay.

Republic Services has nearly 50 operating locations in CA with at
least one affected forklift.  Most of the facilities don't have a
large number of forklifts (generally 1 per site) with the exception
being our recycling plants which may have 3-4 forklifts at each
location (there are 3 such facilities statewide).  These locations
are served by a wide range of public and municipal utilities.   

Subdivision c of this section notes that in order for the extension
request to be considered the "Fleet Operator has deployed the
maximum number of ZEFs that can be supported by the electric
utility provider". Due to the limited number of ZEF at each
location, the number deployed will most likely be zero since the
issue will be access to power or Construction Delays as noted
below.  There will be limited ability to move units between
locations as is required in subdivision d of this section.  This
will be  challenging due to the limited number of units at each
site to start with (ie. 1 at most locations that is needed for
continuation of operations at that location).   

This is more of an FYI and that this type of situation  may arise
with several company's like ours that operate numerous locations
throughout the state that have only 1 forklift.  As such, our
ability to power and deploy any forklifts at the site if there is
an Infrastructure Site Electrification Delay or relocate units from
another location and remain in compliance as we Phase Out certain
model years will be extremely limited.  This may also be the case
for Infrastructure Construction Delay Extension requests (outlined
on Page 44) as the criteria for receiving the extension are similar
to the Electrification Delay criteria.

The reporting platform to be developed by CARB should allow us to
map this out for CARB staff as it will be a complete listing of all
of our units that operate in the state.  We note this here as there
is at times a tendency to view large corporations as having the
resources to cover their needs state wide and just simply transfer
spare equipment between locations.  However, the Phase-Out Criteria
along with the manufacturer, dealer and rental restrictions
contained within the regulation could make it difficult to gain
access to qualified forklifts as there will be a higher demand on
compliant units throughout the state for all sectors.  As noted,
there will not be a surplus of spare units that are compliant
within our company pool due to the limited number at each location
that are needed to continue operations at each site. 

Just noting this so that if and when a situation such as the one
described herein does arise, all of the factors noted are taken
into consideration when reviewing the extension request.    The
interaction with several utilities will also complicate matters in
this regard and since our Fleet will be viewed as an aggregate of
our statewide position (due to the provisions in the Common
Ownership or Control definition) the extension request will most
likely involve information from multiple locations and multiple
utilities.  

Appreciate CARB staff's consideration of this note as well as
clarifications made on comments we submitted on the 45 day rule
(ie. are diesel powered forklifts governed by the rule or not).  

Regards,

Michael Caprio
Director of Government Affairs - CA