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Comment 227 for Advanced Clean Fleets Regulation (acf2022) - 45 Day.

First NameGary
Last NameArant
Email Addressgarant@vcmwd.org
AffiliationGeneral Manager, Valley Center MWD
SubjectAdvanced Clean Fleets Regulation
Comment

October 17, 2022

To:              California Air Resources Board

From:       Gary Arant, General Manager, Valley Center Municipal Water District

Subject:   All Clean Fleets Rule – Providing Support for ACWA’s Letter of Comment of                                                       October               17, 2022 As Well As Additional Comments

Dear CARB Commissioners and Staff,

 As a retail water agency and public fleet operator, Valley Center Municipal Water District  strongly supports the Association of Water Agencies letter of comments, dated October 17, 2022.  We would also like to add the following additional comments:

Commercial Availability

As you are aware, among retail water agencies, there have been ongoing discussions regarding critical aspects of a successful implementation of this important regulation. In addition to concerns about a very short time frame for implementation, including the timely installation of required on-site charging infrastructure issue, as well as overall grid reliability,  much attention has been focused on the topic of “Commercial Availability” of suitable Vocational EVs (vehicles water and wastewater utilities will use) and how that will be defined in the final regulation.

In our view, there are many important aspects to the term “Commercial Availability” which are addressed in the latest ACWA comment letter, including;

Available, but in What Quantities?

1.     Vocational EVs may be commercially available but are they available in sufficient quantities to create a competitive bidding environment for public agencies?

Not only should CARB monitor what EVs meeting utility performance standards are commercially available, but also in what quantities are the EVs available to meet the needs of literally over a thousand water, wastewater, county and municipal and public electric utilities to provide a competitive bidding market.

 

Available but at What Price?

2. In light of regulatory pressure placed on water, wastewater utilities, public power agencies and municipalities to maintain affordable water, wastewater and utility services, especially to disadvantaged and underserved communities, how much more should a public water/wastewater/ county, municipality or public electric utility be required to pay for an EV compared to comparable ICV….30%, 50%, 75%, 100%?

CARB ACF regulations need to establish a cost premium cap of 33% beyond which the utility has the option to purchase an ICV.

Available,  but in what kind of Market?

3.     Without items 1 and 2 above, the ACF Regulation is creating a market that requires utilities to purchase Vocational EVs without determining if sufficient quantities exist to create a competitive market and at what cost premium cap.  As such,  a distorted market may emerge where conditions are ripe for unfair pricing of EV’s.

Without mechanisms in place to determine when sufficient numbers of a particular EV are available to create a competitive bid market, absent a cost premium cap CARB will need to monitor and regulate the marketing and sales practices of EV manufacturers and retailers.

Available, but When?

4.     Another important component of Commercial Availability is, when can the EV be delivered?  3 to 6 months is reasonable and customary,  but not 1 to 2-year estimates of which we are aware.  The ability of a utility to function and respond in normal and emergency periods is necessarily tied to the possession of specialized equipment meeting the utility’s specialized needs.

CARB needs to set a parameter for EV availability with a delivery timeline not to exceed 6 months and if the quoted delivery time exceeds 6 months, the utility should have the option to reject the bid and purchase a comparable ICV.

Delay Implementation At Least Until January 1, 2025 and January 1, 2028 Respectively

With the:

•Current vagaries about “Commercial Availability” of EV’s meeting water and wastewater utility critical vocational standards and needs,

•Questions about the lead time needed to securing affordable installation of on-sight charging infrastructure, questions about the ability of the IOU’s to supply the local power needs,

•Concerns about the overall capability of the electrical grid to handle the new demands, and

•Potential delay of the final regulation until early 2023…

 it would seem prudent to delay implementation of the ACF for at least one-year, until January, 2025 for 50% of vehicle purchases and January. 2028 for 100% of purchases.       

“Policymakers and regulators trying to force aspirational

policies on reality-based, physically constrained systems must be honest

with their constituents about the limits of their ambitions, the timeline to

achieve their policy goals and the likely cost to consumers to achieve

these policy ambitions. It may be an uncomfortable truth, but there

is a cost to the transformation, there are resource limits

that impact the ability to meet arbitrary timelines…” 

“FERC, State Utility Regulators, and the Arsonists Dilemma”

Utility Dive, October 4, 2022

 

In Conclusion 

Again, with our added commentary above, Valley Center Municipal Water District strongly supports the October 17, 2022 ACWA letter of comment.

Thank you for your thoughful consideration.

Gary T. Arant

General Manager



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Date and Time Comment Was Submitted 2022-10-17 10:46:36

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


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