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Comment 137 for Advanced Clean Fleets Regulation (acf2022) - 45 Day.

First NameAaron
Last NameShelton
Email Addressaj_shelton@trane.com
Affiliation
SubjectThe Advanced Clean Fleets Regulation
Comment

To Whom it may concern,

I am responsible for a fleet of 300 vehicles driven by HVAC technicians responsible for maintaining building systems.  As you may know buildings account for 50% of the worlds energy usage, and half of that is consumed in order to heat or cool the building.  We have evaluated the electric products on the market that will enable our technicians to continue to make buildings more efficient, and there simply aren't any made that will allow us to carry the tools we need to effectively maintain these buildings.  The majority of our vehicles are <10,000 GVW, so I would request that this legislation be modified to only include vehicles over 10k GVW  This will allow us to reduce energy consumption from buildings, and continue our mission to drive sustainability.

Further, 

We request CARB engage with the PUC and other relevant agencies to develop a report that exams the feasibility of whether or not the energy grid can be upgraded and how the grid will need to be upgraded to meet these new demands including the overall costs, ratepayer increases and a feasible timeline to accomplish this herculean feat, before deciding on enacting the proposed ACF. 

 We need to know the plans for addressing public DC charging stations along the highways and for remote locations. 

 A single big rig truck will need up to 15,000 pounds in batteries that will ultimately become hazardous waste. We request that CARB work with DTSC and EPA on developing a report that outlines how this massive new amount of hazardous waste will be managed, before deciding on enacting the proposed ACF.

We request that CARB engage a team of experts and stakeholders to determine the cost and availability of the vehicles needed to comply with the ACF regulations. Including the technological feasibility of manufacturing vehicles that will have the same capacity and power of those vehicles being replaced, and that can be replaced on a one-to-one basis. We look forward to that report that CARB must make available for public scrutiny before deciding on the proposed ACF regulations.

 We request that CARB prepare an environmental impact report required under CEQA for the estimated 500,000 new high voltage charging stations that must be in place to make this new proposed mandate feasible.

Thank you for your consideration,

Regards,

A.J. Shelton

Regional Service Operations Leader

Trane 

714-474-5593


Attachment
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Date and Time Comment Was Submitted 2022-10-13 07:09:10

If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.


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