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.
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 sustainable
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 former
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 availability 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 available on
the market or b) is not available 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 available in the
needed configurations.
Thank You