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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