Thank you for the opportunity to provide
comments on behalf of the National Star Route Mail Contractors
Association. As the national voice for surface transportation
companies that contract with the US Postal Service, the Advanced
Clean Fleets rule will significantly impact HCR suppliers operating
in California, will impact the transportation of mail and packages
into and out of California, and could indirectly burden the entire
postal surface transportation network. Compliance will require
suppliers to make significant and potentially impractical changes
to their operations that would have serious consequences for the
interstate commerce facilitated by the United States Postal
Service.
NSRMCA doesn’t disagree with
CARB’s goal of significantly reducing greenhouse gas
emissions, but is concerned with the challenges that would come
with the AFC as currently written. Transitioning a fleet to include
zero-emission vehicles is not feasible at this time, due to the
lack of commercially available vehicles, technological capability,
and charging infrastructure.
Compliance is inconsistent with the duty
cycle of vehicles used in transporting mail for the United States
Postal Service and its network design. NSRMCA is concerned about the viability of
full fleet electrification for many in-state operators. Because
short-haul and regional delivery vehicles which can travel up to
300 miles in a single trip, are in near-constant use, contractors
would have to significantly increase their fleet size to ensure
they always have a fully charged vehicle ready to make deliveries
if they could even complete a contract route on a single
charge.
Additionally,
most carriers that deliver mail to or from California would be
subject to the ACF’s high-priority fleet obligations –
regardless of where they are located. The ACF rule unnecessarily imposes significant
burdens on the interstate transportation of mail and commerce by
treating all vehicles within the High Priority Fleet category
equally even if they spend a de minimis amount of time within the
state.
Lastly, NSRMCA notes
that the ACF rule would unduly burden and may be impossible to
complied with by freight brokers or logistics companies that
contract with the United States Postal Service to move the mail, a
growing component of the Postal Service’s transportation
network. The ACF rule, both its high-priority fleet and
green-contracting requirements, are inconsistent with brokerage
operations generally and how they support the Postal Service
specifically.
NSRMCA recommends CARB establishes clear and
viable exceptions to its Advanced Clean Fleet rule that will allow
transportation companies to continue to use available
reduced-emission fuel solutions and technologies until
battery-electric power is truly viable. In the alternative, CARB
should consider an amended, extended compliance timeline so that
low-emission alternative fuel solutions available today can be used
until battery-electric or other future solutions become viable.
NSRMCA also urges the California Air Resource Board to adopt an
exemption for vehicles that spend a de minimis amount of time
operating in California.
Lastly, as part of our review of submitted
comments, we took note of the comments submitted by the United
States Postal Service. If they are granted an exemption for
vehicles necessary for the maintenance of postal operations, NSRMCA
asks that HCR suppliers are included, because of their essential
role in transporting the mail.
For further information on NSRMCA’s
approach, please reference NSRMCA’s complete written comments
submitted on October 17, 2022. Thank you for your
time.