My agency is one of the "Big 8" State Government Fleets in
California. My agency fully supports the transition to ZEV
fleets, but we must proceed in a way that will not overburdon
taxpayers with higher taxes.
First we ask CARB to consider the short and long term plans (or
lack of plans) for ample power generation. If there are plans
in place to create more green energy plants (solar, wind,
geothermal, hydroelectric, tidal or nuclear) we recommend taking a
pause to seek electrical engineering experts to determine if the
power needs this regulation will generate will be met as these
plants come online. If there are no plans for more power
generation, CARB should pause the regulation until a sustaianable
power generation plan is adopted.
Second, we ask CARB to consider the extreme cost for the
installation of EVSE infrastucture. My agency estimates these
costs at about $40 Million. We operate in the most remote
locations of the state where planned private, state and federal
EVSE projects are not currently prioritized. While we may be
successful in obtaining some funding through a Budget Change
Proposal to install ample EVSE at our sites, it is unlikely we will
be able to have all needed EVSE in place before the regulation as
written hits.
Third, we ask CARB to consider the price point of these medium
and heavy duty assets. While formed Governor Brown indicated
in his Executive Order B-16-2012 for light duty: "The costs of
zero-emission vehicles will be competitive with conventional
combustion vehicles; and". This has not been the case in 2012
and is definitely still not the case in 2022. EV trucks are
expected to be twice as much or more likely triple the price of ICE
trucks. My agency can barely afford to replace its ICE fleet
at current market rate, let alone 2 or 3 times more for EV versions
with less range and utility. We ask CARB to include
exemptions when the cost of a ZEV is 10% or more than the ICE
equivalent.
Fourth, we ask CARB to consider the slow emergence of the
market availablity of certain classes of vehicles subject to the
regulations. Currently there are no or few offering on the
market for 3/4 ton pickups on up to larger 33,000+ GVWR
trucks. Year-by-year exemptions need to be added to the
regulation if the truck you are buying either a) is not avaiable on
the market or b) is not avaiable in the needed configuration
(including range) to meet the business needs.
In closing, again we support the transition to ZEV, but the full
adoption needs to 1) not crash the CA energy grid; 2) allow for the
supporting EVSE to be installed within reason; 3) not be an
exorbinate cost to taxpayers by more than doubling fleet
replacement costs; 4) allow for certain year-by-year exemptions
when needed assets are not on the market or not avaiable in the
needed configurations.
Thank You