First Name | David |
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Last Name | Pérez Tejada |
Email Address | dperezt@baja.gob.mx |
Affiliation | State government of Baja California |
Subject | Proposed considerations to CARB’s ZEV regulations |
Comment | On behalf of the State Government of Baja California, we would like to respectfully submit the following considerations to the Zero Emissions Program proposed by the California Air Resources Board: • Pause the implementation of proposed regulations until studies and reports that will identify critical infrastructure that would guarantee the success of the transition to ZEV and its impact to integrated, bilateral supply chains. These include: • SANDAG CTC • Senate Bill 671 Grants - We appreciate the opportunities that existing grants present, however, they are not enough to support companies in purchasing electric trucks or build necessary infrastructure. It is practically impossible for small or medium-sized companies to cover current market costs. - The trucking companies are currently required to cover all costs upfront and, once it is all done, request a reimbursement. Reimbursement programs may return up to 80% of infrastructure building costs at best. - Other grants are offered to communities in high contamination zones. Unfortunately, the San Diego map has not been updated and communities such as Otay Mesa, where the great majority of transportation companies are located, is not considered a high contamination zone. • Even though we have established negotiations with the NADBANK, the Mexican Government has not implemented similar regulations nor access to grants. Without financial support, the Baja California State Government is unable to provide the essential tools for trucking companies in order for them to comply with the zero-emission vehicle program. As a Binational Megaregion, "high priority" regulations impact most Mexican trucking companies which don't have access to grants provided by the State of California. In addition, importation costs and trade tariffs yet to be determined for ZE vehicles purchased abroad further increased the cost of trucks, not to mention the existing challenge of Mexican regulations mandate local-established companies must acquire these vehicles within the country for fiscal deduction. Drayage • Several trucking companies established in Mexico have already acquired trucks operated by natural gas to comply with the "Truck & Bus" rule, but with an estimated delivery date of November 2024, they will be unable to register these previously acquired trucks to access California maritime ports under proposed regulations. Exceptions currently state a "vehicle delay", but only got ZE vehicles not the natural gas ones. Weight - ZE Trucks would weigh around 5,000 to 7,000lbs more than diesel ones. The weight of batteries would roughly reduce cargo truck capacity by ⅓. This would translate into 33% additional trucks on highways needed to transport the same loads and 33% increase on transportation costs for industry and/or final consumers. - As the price of transportation raises, so will the merchandise. Making an inflation cycle that affects everyone. - Lastly, having more trucks on the road will somehow still create pollution and is not as efficient. Exemptions - Regarding industry and the cross-border economy, we request that trucks that travel from Mexico with a final destination to US states (in-transit) other than California, are exempt due to their limited time operations across this state. - Current regulations proposed by CARB allow for an exception of 5 days per year, however, this is not enough considering the number of trucks that travel across the busiest border. |
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Date and Time Comment Was Submitted | 2023-04-07 18:33:12 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.