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Comment 223 for Advanced Clean Fleets Regulation (acf2022) - 45 Day.

First NameDaniel
Last NameHamilton
Email Addressdhamilton2@oaklandca.gov
AffiliationCity of Oakland
SubjectCity of Oakland comments on proposed ACF2022 Regulation
Comment

Thank you for the opportunity to comment on the proposed regulations.  CARB’s plans for gradual ZEV deployment are enthusiastically supported, however overall statewide plans to deploy ZEV’s for the stated goal of reducing tailpipe emissions must also allow cities the flexibility to focus on market ready and available technologies and financing strategies, including incorporating deployment of existing low-carbon and renewable fuels such as Renewable Diesel and Renewable Natural Gas. These renewable fuels can provide similar “right now” emissions benefits while the ZEV plans are executed and are critical to the success of achieving these goals. Examples of this successfully being deployed are found in the Innovative Transit Rule which currently requires large transit fleets with diesel busses to operate them on Renewable Diesel. Mandating statewide use of Renewable Diesel allow immediate carbon footprint reductions and actually achieve ARB GHG reduction goals earlier than relying solely upon ZEV strategies for compliance.

 

Infrastructure upgrades costs to enable large scale ZEV deployments are extremely high for fleets which typically operate in a depot model, consolidating vehicle domiciling in a small area. This will require a significant investment increasing the electrical power feeding these locations, which typically will require trenching and/or additional power feeds. These modifications are most cost-effective and successful when performed as a single project which requires identifying and scoping total power requirements for 100% fleet electrification (allowing for exemptions) and performing the upgrade may be necessary prior to the arrival of the ZEV equipment. Integrating these factors into the rulemaking will improve outcomes and improve the implementation pathway for fleet owners.

 

Funding to support the incremental vehicle acquisition costs and charging infrastructure installation costs must be provided to COVID-19 cash-strapped fleet operations. Competitive grants and complex application mechanisms disadvantage smaller fleet operations and will likely create inequities penalizing fleets that actually need the funding the most.  The mandated ZEV acquisition costs are significantly higher than current inventory petroleum fueled equipment so any proposed acceleration of existing replacement schedules requires funding not just for the incremental costs, but for the total acquisition costs of any additional quantities of vehicles now identified for replacement beyond the fleet’s existing replacement schedule. Additionally, the incremental costs identified by CARB staff in ACF materials significantly underestimates costs that the City of Oakland is seeing in the market. In fact, CARB’s own acquisition data for Medium/HD vehicles found on the ARB HVIP funding website are significantly higher than data for the same vehicles found in the ARB ACF documentation. 

 

The timeline for implementation is not realistic and encourages a piecemeal approach to installing required EV charging infrastructure due to the tight timelines. This is neither realistic nor cost effective. It is relatively straight forward to add charging capability up to existing facility electrical available, but the next step beyond this is typically a large-scale increase to power to the facility. Additionally, multiple fleet customers all building out EV charging infrastructure to maximum on the same circuit may be expected to identify and trigger issues at any weak spots in the existing grid that may not necessarily be an issue at existing demand.  This may also be expected to increase cost and extend compliance timelines. These costs and timelines are largely facility specific, however installing a typical additional power drop to a facility by PG&E prior to ACF took about 18-24 months. Since every fleet in the state will now be asking for similar improvements/upgrades, the actual adjusted timeline needs to be identified and accommodated for in the implantation plan. Furthermore, due to the large numbers of fleet customers requiring significantly larger amounts of electricity, it can be expected that some locations will actually require a more involved solution such as a sub-station or other larger scale grid project to support the multiplied customer demand. Accommodations to the implementation plan need to be made to allow for these activities which may require CEQA or other time-consuming approvals. Most recently, a transformer shortage is contributing to upgrade timeline delays and cancellations as existing transformers are held in inventory for replacement of existing transformers that fail in service or otherwise become unserviceable.

 

Factoring Total Cost of Ownership over the life of an EV into acquisition funding discussions fails to acknowledge the distinct differences between capital acquisition funding sources and use restrictions and Operations and Maintenance (O&M) funding sources and use restrictions. This methodology may be appropriate for light duty sedans and high mileage/use transit applications, but the practical implications for medium and heavy duty fleets do not hold true in current market conditions. Even in the more mature light duty vehicle market, the existing TCO models for EV’s don’t show cost parity or potential costs savings until the last 10% of vehicle life or later. It is unrealistic to anticipate fleets to fund significantly increased capital acquisition costs, through anticipated savings in O&M that are projected 10 or 15 years in the future. It is also unclear if the higher rates for electricity in California were included in the TCO analyses relied upon by ARB to identify these potential ZEV TCO savings.

 

Facility electrification goals and mandates must also be factored into these regulations. While electrification to accommodate light and medium/heavy duty fleets, many jurisdictions like Oakland are also endeavoring to eliminate natural gas service to facilities in favor of electricity. These additional demands may be expected to increase costs of electrical upgrades and place further demands and stress on the existing grid. These facility electrification projects are also taking place at numerous locations in addition to the fleet depot facilities which needs to be identified and planned for in power increase/grid improvement plans.

 

The City of Oakland supports aggressive action on expanding zero emission vehicles and infrastructure, but needs regulations and incentives that work with the competing and challenging efforts to electrify buildings and transportation systems simultaneously.  With supply chain shortages and first cost capital concerns dominating procurement decisions, we recommend modifications to the draft regulations to ensure full compliance and progress towards the State’s clean energy and air quality goals. 


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Date and Time Comment Was Submitted 2022-10-17 09:48:41

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