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Comment 23 for Advanced Clean Fleets Regulation (acf2022) - 45 Day.

First NameCory
Last NamePeters
Email Addresscpeters@bestdrayage.com
AffiliationBest Drayage
SubjectProposed ACF - Drayage Truck 1/1/2024 Requirement
Comment

I am writing you today to urge you to remove the 1/1/2024 requirement that any drayage truck entering a port facility for the first time be Zero Emission.  As a trucking company based in the Central Valley, there is no Zero Emission equipment available today that would allow us to make it from our customers to the Port of Oakland and back without re-charging en route.  That is not practical, as the quickest charge available today is at least 6 hours.  It is hard enough for drivers to make it between the Central Valley and the Port of Oakland and back within legal driving hours, adding the charging time will make it impossible.  Until the technology is available, we should not be forced to purchase something that does not exist.

 

The 1/1/2024 registration requirement is the most glaring issue we have seen in your proposal, especially for those fleets who regularly purchase new trucks.  Other issues include not having enough public charging infrastructure and the weights of zero emission trucks.  We have attended a few calls with CARB staff who seemed shocked to learn that most trucks rely on public fueling now.  Asking fleets to install their own charging infrastructure is not practical, as the majority of our industry doesn’t have their own fueling stations now, trucks fuel on the road because that is where they need it most.  The weight of zero-emission trucks is also a concern.  With the lightest zero-emission Class 8 trucks averaging more than 12,000 lbs. heavier than their diesel counterparts, shippers will be forced to slash loads by up to 30%.  This will have a dramatic impact on the costs for shippers, especially those in the Central Valley.

 

While we agree there is a need for cleaner emission vehicles, until that technology is there for all Class 8 vehicles, it is harmful to put in regulations like this one.  There are many more practical applications that can go to zero-emission vehicles with current technology.  Perhaps a review of what an actual drayage truck is would be beneficial for your staff?  During presentations, it seems as if they believe all drayage trucks just work within the port complexes.  In reality, there is no difference between a day-cab drayage truck that goes between the ports and the Central Valley (or further) and thousands of other Class 8 trucks that your proposal gives much more time to transition to zero emission.

 

Thank you for your time.

 

Cory Peters

Chief Financial Officer

Best Drayage


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Date and Time Comment Was Submitted 2022-10-06 13:42:28

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