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Comment 162 for Advanced Clean Fleets Regulation (acf2022) - 45 Day.

First NameGreg
Last NameOwen
Email Addressgrego@trimodal.com
Affiliation
SubjectProposed ACF Regulation
Comment

We are a local Trucking/warehousing company here in the Port of LA/LB area that have serviced the ports for 75 years. We have studied electrification totally for trucking & warehousing operations “fully” have implemented solar panels on three of our warehouses; purchased ZET yard tractors; forklifts; are in the process of studying charging infrastructure for each of our facilities.

The cost of ZET in drayage operations will be a total failure due to EXTREME COSTS for tractors, infrastructure, generational changes, inefficiencies requiring a minimum of twice the trucks currently handling drayage operations throughout the port communities. Initial costs per tractor will be over $1 million “times two” for each current drayage haul today.

Currently California Energy Commission has no plans how to provide a 24/7 uninterrupted source of energy for current operations, let alone the future demand being proposed.  The current demand being studied are based on less than half of future demands.

CARB mandates to date have been a total failure, lack good science rules for study and implementation.  The cost to industry to date have been Billions in clean units purchased, maintained and destroyed by past, current and future draconian rules/mandates. Future purchases will be multi-billions:

1.     Past clean truck implementation cost $1.5 billiion

2.     Future cost $15.4 Billion

3.     Infrastructure estimated $9 million per facility

Nothing makes sense or is feasible without “SUBSIDIES” a future without subsidies will be failure upon failure.

The use of ZET and the infrastructure, without the energy production infrastructure is not possible.  We have done more than most users with our past purchases and implementation; the future additions lack financial feasibility or possibility.

CARB has the cart before the horse, first you should have decided what you wanted to do; how you will provide the energy to offset the demand; put the infrastructure in place; then, proceed that ZET will reduce the cost of what its replacing.

Greg Owen, Head Coach

Ability-Trimodal

2011 East Carson Street

Carson, CA. 90810


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Date and Time Comment Was Submitted 2022-10-14 10:17:44

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