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Comment 2 for AB179 Joint Meeting with CARB/CTC/HCD (ab179carbctchcd2022) - Non-Reg.

First NameRyan
Last NameCollins
Email Addressrcollins@waste101.com
AffiliationTahoe Truckee Disposal Co Inc
SubjectZEV Concerns for High Elevation Operations
Comment

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

 

 


Attachment
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Date and Time Comment Was Submitted 2022-10-20 16:00:05

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