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