Good afternoon, my name is Jennifer Goodsell and I am the
General Services Manager at the Imperial Irrigation District.
IID is an irrigation district and a public power provider
representing some of the most economically disadvantaged and
underserved communities in the State. Our predominantly rural
service territory encompasses all of Imperial County, parts of
Riverside and San Diego Counties, and spans over 6,000 square
miles.
IID recognizes that transportation is the
single largest source of the State’s greenhouse gas
emissions, and achieving a zero emission medium and heavy duty
fleet is critical to meeting California’s environmental
goals. While we support the state’s goals to promote clean
transportation options, and we endorse the direction that fleet
electrification is headed, I am urging this board to seriously
consider the unintended consequences this regulation would impose
on public utilities, and our ability to deliver essential public
services, especially during emergency events.
On September 28th, IID in conjunction with the
member agencies of the Southern California Public Power Authority
hosted a demonstration and round table discussion at our La Quinta
facility. That event was attended by CARB Board member Riordan,
CARB staffer Paul Arneja, Assemblyman Eduardo Garcia and his Chief
of Staff, as well as representatives from the Assembly Utilities
and Energy Committee, the Assembly Transportation Committee, the
California Municipal Utilities Association and the Northern
California Power Agency. We appreciate CARB’s presence, and
want to thank everyone who attended and made an effort to
understand the unique needs of public utilities.
Our goal for this event was education, and to give the
attendees an intimate look at the equipment we use, let them
witness a live demonstration of real life working conditions, and
experience what we mean when we talk about duty cycle and the
performance requirements of a PTO, or Power Take Off System. Most
of the attendees didn’t know what a PTO was, or what purpose
it served.
Mother Nature is a force that we cannot predict or control,
and this equipment is the heart and soul of our fleets, and it is
what our customers rely on in times of emergency. Whether it is a
lack of commercially available technology, exemptions an agency
can’t qualify for until a certain percentage of the fleet is
already electrified, or the reality that the infrastructure of the
California grid isn’t ready for this regulation, it is
respectfully requested that you fully consider the implications of
your decision on public utilities and the services we provide to
the residents of this state.
Thank you
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