Comment Log Display

Here is the comment you selected to display.

Comment 21 for Advanced Clean Fleets Regulation (acf2022) - 45 Day.

First NameJennifer
Last NameGoodsell
Email Addressjmgoodsell@iid.com
AffiliationImperial Irrigation District
SubjectIID remarks on Proposed ACF Regulation
Comment

Good afternoon, my name is Jennifer Goodsell and I am the General Services Manager at the Imperial Irrigation District. IID is an irrigation district and a public power provider representing some of the most economically disadvantaged and underserved communities in the State. Our predominantly rural service territory encompasses all of Imperial County, parts of Riverside and San Diego Counties, and spans over 6,000 square miles.

IID recognizes that transportation is the single largest source of the State’s greenhouse gas emissions, and achieving a zero emission medium and heavy duty fleet is critical to meeting California’s environmental goals. While we support the state’s goals to promote clean transportation options, and we endorse the direction that fleet electrification is headed, I am urging this board to seriously consider the unintended consequences this regulation would impose on public utilities, and our ability to deliver essential public services, especially during emergency events.

On September 28th, IID in conjunction with the member agencies of the Southern California Public Power Authority hosted a demonstration and round table discussion at our La Quinta facility. That event was attended by CARB Board member Riordan, CARB staffer Paul Arneja, Assemblyman Eduardo Garcia and his Chief of Staff, as well as representatives from the Assembly Utilities and Energy Committee, the Assembly Transportation Committee, the California Municipal Utilities Association and the Northern California Power Agency. We appreciate CARB’s presence, and want to thank everyone who attended and made an effort to understand the unique needs of public utilities.  

Our goal for this event was education, and to give the attendees an intimate look at the equipment we use, let them witness a live demonstration of real life working conditions, and experience what we mean when we talk about duty cycle and the performance requirements of a PTO, or Power Take Off System. Most of the attendees didn’t know what a PTO was, or what purpose it served.

Mother Nature is a force that we cannot predict or control, and this equipment is the heart and soul of our fleets, and it is what our customers rely on in times of emergency. Whether it is a lack of commercially available technology, exemptions an agency can’t qualify for until a certain percentage of the fleet is already electrified, or the reality that the infrastructure of the California grid isn’t ready for this regulation, it is respectfully requested that you fully consider the implications of your decision on public utilities and the services we provide to the residents of this state.

Thank you


Attachment
Original File Name
Date and Time Comment Was Submitted 2022-10-27 14:49:19

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


Board Comments Home