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Comment 25 for Advanced Clean Fleets Regulation (acf2022) - 45 Day.

First NameMargaret
Last NameEdwards
Email Addressmedwards@nsrmca.org
AffiliationNSRMCA
SubjectOral Comments - National Star Route Mail Contractors Association
Comment

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.


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Date and Time Comment Was Submitted 2022-10-27 14:55:15

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