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Comment 32 for Advanced Clean Fleets Regulation (acf2022) - 45 Day.

First NameMarcus
Last NameVierra
Email Addressmvierra@bestdrayage.com
Affiliation
SubjectAdvanced Clean Fleet - Comments
Comment

The Advanced Clean Fleet rule is too ambitious for the reality of the technology and infrastructure of 2024 for Port Drayage.  Below I will highlight the most urgent issues with this bill facing the companies I work with directly every day, which are drayage trucking companies that run from the Port of Oakland to the Central Valley:

1.       There is no public charging infrastructure currently in place to charge these vehicles.  Many drayage trucking companies own 1-5 trucks, and often do not own the yards they park the trucks in.  They have no option for private charging, either due to cost or simply because they do not own land to do so.  There is no way there will be adequate public charging available for all of the drayage trucks in 14 months.

2.       Not allowing diesel replacement trucks beyond 2024 puts too much uncertainty in this industry.  Right now many drayage drivers are being forced out of perfectly viable trucks because they have 2010 or older engines.  Used truck prices are at an all time high.  However, with this rule, if a company buys a 2019 truck (which should be able to be used until 2032), and it gets totaled on January 2, 2024 even if no fault of the driver, they cannot replace this truck except with an electric truck that is triple the price and not viable for this industry?

3.       Current electric trucks do not provide the range needed to go from the central valley to Oakland and back home.  This will mean drivers that currently do these runs in 10-14 hours will not be able to do the same jobs they do now and still adhere to legal hours of service requirements.  It should not be a 2-day trip from Fresno to Oakland and back, but it will be in an electric truck that does not have the range to make it.  This will cause an influx of drivers to no longer want to be in this industry which currently allows them to be home with family each night.

4.       Cargo weight issues due to these much heavier trucks will severely harm agricultural product exporters in the central valley, and require more trucks on the road to haul the same amount of product.  Right now, electric trucks are 12,000lbs heavier than the average truck we work with.  That means almond shippers will only be able to put 33,000lbs of product into a container instead of 45,000lbs due to the maximum gross weight still remaining 80,000lbs.  There will be a need for 25% more trucks on the road each day, not to mention the explosion of costs due to this and adding to the total number of containers needing to be exported on container ships.

Are electric trucks the future of the drayage industry?  Maybe.  But this rule is way too early based on the reality of the technology and infrastructure that currently exists.  What this will do is cause a true crisis at the ports for trucking companies, for ag exporters in the central valley, and for a huge number of hard working families that rely on these jobs for their survival.  2035 might be a more realistic start date for these rules and regulations, once the technology has caught up with the ambitions of CARB.  Drayage should not be among the first industries targeted by these rules, or else you risk catastrophic supply chain issues that directly impact California businesses, and ultimately all California residents. 


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Date and Time Comment Was Submitted 2022-10-07 08:20:38

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