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Comment 168 for Advanced Clean Fleets Regulation (acf2022) - 15-1.

First NameDavid
Last NamePérez Tejada
Email Addressdperezt@baja.gob.mx
AffiliationState government of Baja California
SubjectProposed 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.

Attachment
Original File Name
Date and Time Comment Was Submitted 2023-04-07 18:33:12

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