Comment Log Display

Hello Ms. Nichols et al: 

In its current form, the Innovative Clean Transit rule, divests in
critical public goods and services by mandating a technology that
is not viable for its intended use: 
-Electric buses cost nearly 3.5 times that of a CNG bus with ranges
that far exceed that of their electric counterpart. Some systems in
rural California received as little at $34,000 from FTA and limited
financial support from State and local governments: this mandate
has the potential to limit and/or stop services in less affluent
areas. 
-The rule provides limited-term incentive funding but no dedicated
funding to offset the cost of a much more expensive technology.
-Current mandates by the federal government specifically bar
purchases of Chinese-manufactured buses (i.e. - electric buses.)
-The acceptability of ZEB as an alternative to less clean vehicles
has been postured by lobbyists from electric bus manufacturers:
actual data provided from ZEB-implemented agencies in Oregon and
BAY-area, CA show that actual range is generally 1/3-2/3 of
estimates posited by ZEB-manufacturers and highly dependent on
terrains. These vehicles simply do not travel on one charge to
complete an average route. 
-This regulation would require rural agencies to cut life line
services (such as Plumas Transit's service to the nearest major
medical center) as the distance traveled could not be provided by
ANY known electric vehicle as of today
-This regulation highly favors affluent urban areas and their
public transit systems with no acknowledgement of funding
differences/FO and DAR miles traveled in rural areas. 
-The added weight of battery packs could limit the amount of
passengers allowed on a vehicle and MORE IMPORTANTLY: the amount of
ADA wheelchair-passengers on a vehicle. 
-This regulation does not address caveats presented that could
potentially cause agencies to fall out of compliance with both
federal and state law and the Americans with Disabilities Act. 
-The impact of this regulation on a public good that seeks to limit
road congestion and single-occupancy vehicle reliance could lead to
services cut - having the opposite, intended consequence. 

For all these reasons, I request the Board and esteemed staff take
into consideration both the nuances of the proposed regulation and
of a spurious technology - both the mandated technology and the
regulation in its current form are incredibly harmful to public
transit, HOV infrastructure, and the head way California has just
started to make on coordinating transit and mobility services in
the state. I respectfully ask you to consider a reinvestment in
mass transportation rather than a divestiture; our state needs less
reliance on SOV's and more mobility options. 

Regards,
Tenley C. Borchman