Comment Log Display

At this moment, there is no data that indicates we are ready to
transition our transportation into zero emissions. There are no
case studies that indicate the financial or feasible ease of small
carriers to transition their fleets into ZEVs. Currently, our
infrastructure is not ready to take on the weight of ZEVs at the
proposed scale. The market offerings from the OEMs do not currently
meet industry standards for duty cycles. I caution you against
going about this in haste, there will be significant damage to
small carriers that are for the most part owned by marginalized
people living and contributing to the economy of neighborhoods with
high unemployment rates and low standards of living. If we look at
this as a social justice issue, we should take an approach that
gains us the best benefit both for the environment and the material
conditions of the citizens in the area. 

The North American Council for Freight Efficiency has published
their findings after years of research and they advise that the
road to zero emissions will require the use of bridge technologies
like Renewable Natural Gas. At this moment, the use of RNG can
provide a carbon capture solution that can take us from the dirty
Diesel exhaust fumes and deliver us to zero tail pipe emissions in
due time while being 90% cleaner than Diesel and providing a Carbon
Intensity level going below zero.