The
City of Los Alamitos appreciates the
opportunity to provide comments on the Advanced Clean Fleets (ACF)
draft regulatory language (September 2 iteration) for public fleets
as presented at the California Air Resources Board’s (CARB)
July 26 public workshop.
Given that zero-emission vehicle
(ZEV) availability is critical to the successful implementation of
the ACF rule, we have focused on these provisions in our comments.
Our core recommendations are for CARB to include a robust,
transparent framework to assess ZEV commercial availability, as
well as a separate exemption process when ZEVs are not accessible
to public agencies in practice or are unsuitable for the
fleet’s operational needs.
The proposed regulations ignore
existing market realities and the time needed to develop and ramp
up an infrastructural system that can support an electrified fleet
of waste, water, and sewer utility vehicles.
For example, existing
zero-emission technology limits a garbage truck’s range to
100 miles or less, with a payload loss of 6,000 to 7,000 pounds.
This reduction in payload capacity, combined with the time needed
to charge a truck, means that agencies would need two garbage
trucks for each one in service, significantly increasing costs for
both vehicle infrastructure and labor.
Many of these vehicles are not
commercially available. If a city has planned for supporting
infrastructure and budgeted for such purchases, it should be
recognized by CARB and receive an extension for compliance instead
of being penalized for vehicles not yet available. The proposed
regulations should also be modified to ensure that established and
reliable manufacturers can adequately produce and service these
vehicles for years to come.
If required to follow the
proposed regulation as drafted, the projected infrastructure and
fleet costs will add substantial rate increases across multiple
public works and utility service departments. Cities across the
state are pursuing environmentally sound and robust strategies to
decarbonize their communities. However, this proposed regulatory
language does not account for rising utility costs, and substantial
mandates from multiple regulatory bodies, so we urge CARB to
consider these impacts to ensure success for communities without
further exacerbating the affordability issues facing many of our
cities and residents.
Again, thank you for allowing us
the opportunity to provide written responses to the proposed
Advance Clean Fleets Regulations.