CARB “Clean Trucks”
Rule
Comments For Record
Here we go again…. Like the original
“Truck and Bus Rule” that broke many Companies, (almost
ours too) we have to change out our fleet with our money, on a
government required timeline, with “future” technology
without infrastructure available, in a plan built on pipe dreams
and guesstimates about what the government power brokers want us to
do.
Remember CARB’s MTBE debacle? CARB
denies their involvement as they just required a
“specification” that could only be met with MTBE at the
time. This created
statewide pollution issues, some of which are still being cleaned
up! CARB did not pay
for that! Or how about methanol fuels in bus fleets? It rotted the motors from
the inside out and was poisonous to humans costing CARB hundreds of
millions of dollars to essentially force bus fleets to use the fuel
and keep replacing engines?
Or what about hydrogen cars where the fuel was made from
natural gas? A few
bucks spent there over how many years? How many other examples are there?
Here is my primary groups of issues,
in no particular order:
First: We don’t have
the supply of electricity in the State needed for this government
required transition.
And yes, I have 1200 solar panels on my property….
but that is one property, headquarters, not the other 10 places I
have trucks parked around Central California. By the way, I also had to
put in a 250KW generator to keep my business running when the power
goes out as without the Renewable Diesel generator, I cannot run
off my solar power, that I have had for over 16 years (closer to
end of life than I realized).
Second: These electrified trucks
will not have a smaller environmental impact on the planet than the
Renewable Diesel powered trucks we run now. But there will be a GIANT
COST! This is a
political decision, not a scientific one, similar to solar panels
which are not recyclable, and windmills, that are bird killers and
not recyclable either, but why look at facts. What is the fine for each
bird killed, the cost of picking up the ones you notice? If I killed an eagle, I
would be put in jail. All CARB’s” fines start at
$10,000 per violation, how many birds have died for this eyesore of
so called “clean” power.
Third: All the battery minerals
and components have to be imported from China, need I say
more….National Security. It takes about 500,000 pounds of mining to
provide the minerals to make a 1,000 pound car sized battery. How
much mining is needed when you require SUPERSIZING of these
batteries for truck use?
Clearly CARB does not mind if the pollution from mining that
occurs in a third world country with child and slave labor.
Fourth: If we took all the trucks
in one mid-sized county and electrified them today, it would take
all the power available for every residence in the State
Fifth: It takes how many hours to
charge a class 8 truck hauling 80,000 pounds all day? Is it all night? MY fleet runs these trucks
around the clock as it is the only way to make money off of the
huge investment that CARB and other Regulators have pushed the
pricing of these trucks to!
So, will I need a Day Fleet and a Night Fleet, so that I can
be charging one while the other is running? Doubling the size of my
fleet? IS that a
savings? Is doubling the number of vehicles needed to do the same
work environmentally friendly?
Sixth: One will never be able to
load an electric powered truck transporting flammable or
combustible liquids as they can never be shut off or de-electrified
during loading.
Static Electricity, for the same reason, we cannot even have
a cell phone on at loading terminals! That is an AHA moment! I know what will happen,
cell phones will continue to not be allowed but you will make sure
that “special rules” will be quietly forced allowing
your giant static generators with constantly running electric
systems, including fans, be allowed access to load at any
time. Probably by
declaring the equipment “explosion proof” as all
electrical systems are required to be in terminals and
refineries.
Seventh: There is no available FAST
charging infrastructure available for heavy duty trucks nor enough
power from the starved Statewide grid, with no capacity in the
power lines in the streets as they were not built with this load in
mind, with no charging stations at our terminals. What is all this
infrastructure going to cost? Then what can I connect those systems
into? What will my
power bill be for fast charging? More than overnight parking, but we don’t
park day or night.
Eighth: The batteries are
non-recyclable and must be replaced regularly. As will my solar panels in
a few years. A big
dump run coming …. will CARB be helping me pay to replace
them? Is the future
cost of recycling built into your models? The stupidest thing on the
planet is that we still bury our “waste.” In a previous life I used
to sell car batteries that to this day are still over 90%
recyclable. I bet
that I could never acquire a permit to build a plant to recycle
these electric car batteries in California, even if the technology
existed!
Nineth: Our power grid is
shrinking, not growing! The same people that are desperate for
electrification of transportation want Diablo Canyon, with 2.256
Gigawatts of power, to be closed 25 years early, AND the same
people want all the dams in the State removed, they used to
generate some power also.
Have we also forgotten about high speed rail to
nowhere? It will
demand a lot of power to run 250 miles per hour from San Francisco
to Los Angeles! The
first section of track will run $100 billion before it is
complete.
Tenth: CARB is picking winners
and losers economically with no free market involvement. Tesla has gotten many
BILLIONS of dollars and still almost went broke, and the owner is
now the richest man in the world. Their cars have been the worst built, ranked by
independent studies, for years, but you love them, and continue to
“sponsor” them.
Without huge subsidies, electrification would die quickly as
the free market recognizes that “market technology” is
not really there yet.
So, CARB’s response is ….. let’s force
it. Like the
Governor’s ICE ban.
Eleventh: With all that will need to
be spent to make this Truck rule eventually happen, from power, to
grid, to vehicles, the State could give every homeless person in
the State support and a place to live for life which actually might
be more environmentally friendly due to the elimination of the
environmental impact that results from homelessness.
CARB is so myopic in its focus. People are actually dying
on the streets every day, contrary to your “statistical
estimates” of possible lives saved. Do we have our priorities straight here? CARB’s is clearly
focused on power and politics, “how do we best justify the
control we want over every single facet of the lives of people in
CARB’s serfdom” rather than basing decisions on the
science.
I have one important thought and comment that
needs to be made in light of recent news of major disasters that
befall us in California and across the country; that is, having all
of our emergency response “eggs in one
basket” namely electric light, medium, and heavy
duty electric vehicles needed for emergency response.
As a Company that has always been there
through earthquakes, major snow events, huge deadly fires, and
floods AND PANDEMICES, we have been participating in emergency
response preparedness for decades.
I know that electrification of emergency and
other response vehicles will make any disaster recovery and
response much worse in life and death situations. In most, if not all of the
disasters experienced in our State, one of the first effects
experienced is that the electrical grid goes down. Hence the requirement for
back-up power for hospitals, police facilities, California’s
Office of Emergency Services, and media outlets to name but a few,
that also includes OUR solar powered offices with a standby 250KW
generator that is regularly utilized often in area outages to keep
our systems and equipment coordination running.
Just consider last month when the Governor was
telling those with electric vehicles to not charge them due to
overwhelming grid stresses.
This was not even coupled with another disaster, like a fire
or earthquake…. or any other disaster where major response
is required.
With electric vehicles you cannot “get there from
here!” EVEN in
that grid demand problem we experienced, our companies were
involved working to keep power plants up with what they needed to
generate power at record levels. We CAN deliver fuels and products needed
without electricity as all our vehicles are independently powered
and carry fuel that is turned into power without electricity or
using standby power.
We cannot use electric vehicle to fill those roles.
THE ASK: Please exempt
ALL vehicles that work to keep our State operating
during crises. That
would include: Fire
Trucks, Ambulances, Police vehicles, utility vehicles, the many
State, County, and local agencies vehicles that respond when
disaster strikes.
Exempt all the vehicles that
deliver food prepared and grocery and fuel as these vehicles
provide fuel for evacuations, and response and food to keep people
alive right now. The
list would be large but the need during these events would be
immediate and demand all resources available to preserve human life
and health.
I appreciate your thoughts to make commute and
local errand cars less polluting but using a broad brush to shut
down emergency response vehicles, food and fuel deliveries and support vehicles for
example, lacks adequate consideration of the redundancy needs
required for large crises.
Remember, in all large emergencies, it is
ALLWAYS, “All Hands on Deck.”
David Atwater