Good afternoon,
We are a small solid waste hauler and processor servicing the
Tahoe, Truckee, Sierra community. We respectfully submit our
comments and concerns for truck electrification in high elevation
areas and for solid waste collection vehicles.
·
Cold Weather
Battery Issues
o
Range can be
reduced by 10-40% in the winter due to Lithium-Ion performance
issues in cold weather, battery heating, and extended hydraulic
system warm-up periods.
o
Due to our
fleet being stored outside, winter charging will be a significant
challenge as trucks can sometimes be buried in over 6 feet of snow
overnight. Plowing operations and clearing will threaten to clip
wires and safety risk is a major concern.
o
Lithium battery
charging below 32 degrees Fahrenheit can cause “lithium
plating,” a chemical reaction that increases the internal
resistance of the battery and ultimately causes a permanent
reduction of the battery’s capacity. Most of our charging
would occur below 32 degrees (we experience consistent nighttime
temperatures below freezing in winter and shoulder seasons).
o
Charging speed
can be reduced significantly in cold weather. Charge current must
be reduced below 41 degrees Fahrenheit because of reduced diffusion
rates. We are concerned that trucks may not be able to achieve a
full charge overnight.
o
On-road safety
is a major concern during winter months. Many times, road closures
due to storms and avalanches have left our vehicles stranded for
hours and can occur at the end of the day. Last winter, road
closures led to passenger electric vehicles running out of charge,
stranding passengers, and requiring a major local towing effort. We
fear that drivers could be similarly stranded without heat in a
blizzard should they find themselves facing a road closure at the
end of the day.
Grid Capacity and Outages
o Our current grid
can barely support building infrastructure, we will need to install
higher capacity lines to support electrification.
o Power outages can occur
for long durations. Last year we had over 25 days without grid
power, with 6 of those days being continuous, not to mention
intermittent grid power. Generators currently only support critical
building functions (for example, only half of the MRF is powered
during an outage) and a significant number of generators and
battery banks would have to be installed to support fleet charging
during outages.
Technology and Cost
o The high torque required to service
the mountain community will reduce range (This is one reason our
fuel burn per mile is generally higher than industry). Some roads
that we operate over can be around 15% grade.
o Lithium-Ion
batteries experience more rapid degradation when charged to 100%
capacity. This is why passenger electric vehicle manufacturers warn
again charging over 80% and why most civilian charging stations
slow charging after 80%. We are concerned about range if trucks are
only charged to 80% and about battery degradation if charged to
100%.
o We are not aware of any current
electric trucks with soft-start functionality. The high torque of
electric vehicle motors can cause issues in slippery conditions and
transition from ice to dry pavement could result in drive-train
damage.
o We have reviewed
most of the currently available vehicles and none demonstrate the
necessary electrical capacity to support a full operating day.
o It will be a
challenge to service rural routes that can require over 100 miles
of travel to and from the route (50 miles to route start, 50 miles
to MRF).
o We are concerned
about having adequate electricity for the collection of materials
like pine-needles and Greenwaste, which require the truck packer to
be running near constantly throughout the day.
o The added weight
of the electrical system significantly reduces the hauling capacity
of vehicles, requiring more vehicles to support normal route
operations.
o Specialized
electric trucks will constrain parts availability and aftermarket
options. This could cause delays and extended vehicle down time
(already an issue with current electric truck systems).
o Specialized
electric trucks will require significant mechanic training, repair
infrastructure, and cost.
o We are not aware
of any current electric trucks that have swappable batteries. This
is an issue for operations as a truck will have to return to base
to charge when power is low. It is also an issue for battery
replacement, as the truck will have to be shipped to a broker
capable of replacing the battery at the end of its useful
life.
o We received a
quote from our broker for a “front loader” and
it’s estimated to be around $1 million, not including
charging infrastructure. An equivalent diesel-powered front loader
currently costs close to $580,000. This will significantly increase
costs to rate payers.
We hope that our comments can be
of use in reviewing the merits and challenges of truck
electrification.
Thank you,
Ryan
TTSD