The Advanced Clean Fleet rule is too ambitious
for the reality of the technology and infrastructure of 2024 for
Port Drayage. Below I
will highlight the most urgent issues with this bill facing the
companies I work with directly every day, which are drayage
trucking companies that run from the Port of Oakland to the Central
Valley:
1.
There is no public charging
infrastructure currently in place to charge these vehicles. Many drayage trucking
companies own 1-5 trucks, and often do not own the yards they park
the trucks in. They
have no option for private charging, either due to cost or simply
because they do not own land to do so. There is no way there will be adequate public
charging available for all of the drayage trucks in 14 months.
2.
Not allowing diesel replacement
trucks beyond 2024 puts too much uncertainty in this industry. Right now many drayage
drivers are being forced out of perfectly viable trucks because
they have 2010 or older engines. Used truck prices are at an all time high. However, with this rule,
if a company buys a 2019 truck (which should be able to be used
until 2032), and it gets totaled on January 2, 2024 even if no
fault of the driver, they cannot replace this truck except with an
electric truck that is triple the price and not viable for this
industry?
3.
Current electric trucks do not
provide the range needed to go from the central valley to Oakland
and back home. This
will mean drivers that currently do these runs in 10-14 hours will
not be able to do the same jobs they do now and still adhere to
legal hours of service requirements. It should not be a 2-day trip from Fresno to
Oakland and back, but it will be in an electric truck that does not
have the range to make it.
This will cause an influx of drivers to no longer want to be
in this industry which currently allows them to be home with family
each night.
4.
Cargo weight issues due to these
much heavier trucks will severely harm agricultural product
exporters in the central valley, and require more trucks on the
road to haul the same amount of product. Right now, electric trucks are 12,000lbs
heavier than the average truck we work with. That means almond shippers
will only be able to put 33,000lbs of product into a container
instead of 45,000lbs due to the maximum gross weight still
remaining 80,000lbs.
There will be a need for 25% more trucks on the road each
day, not to mention the explosion of costs due to this and adding
to the total number of containers needing to be exported on
container ships.
Are electric trucks the future of the drayage
industry? Maybe. But this rule is way too
early based on the reality of the technology and infrastructure
that currently exists.
What this will do is cause a true crisis at the ports for
trucking companies, for ag exporters in the central valley, and for
a huge number of hard working families that rely on these jobs for
their survival. 2035
might be a more realistic start date for these rules and
regulations, once the technology has caught up with the ambitions
of CARB. Drayage should not be among the first industries
targeted by these rules, or else you risk catastrophic supply chain
issues that directly impact California businesses, and ultimately
all California residents.
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