thanks for recieving my comments in regards with the zev trucks rule and law
one of the things that concern us are, the differences that a zev truck has in regards with autonomy and cost of operation
our core busines is serving the assembly line busines in Tijuana, B.C., and delivering and picking up loads in Los Angeles Area
currenly, we can do that within the federal HOS od pur drivers, but because the Zev truck Class 8 only gives us 150 miles per charge, and because our load from San Diego, Ca., to Los Angeles afrea destination, and pick up location on the return load, and because o regular round trip from san diego, is about 325 miles, we need to recharge batteries twice on the trip
people form kenwoerth dealers tells us that we need a recharge location on route, and install a high capacity battery charger, that chage will require 3 hours
with that said, a regular round trip that migth require as mucho as 10.5 total hours, with the time required to recharge the truck, we will need 17.5 hours, and theres where we have the problem, because thats over the federal hours of service we have to comply with, meaning that the dirver will have to stop on route to sleep, and re-start the following day (and theres no zev sleeper truck, what they offerits a day cab, so we dont have a way to make this work.
also the production lines we service with loads, are acustomed for us to arribe at a certain hour, of the same day
so until zev trucks can do the same things a diesel truck does, we will need morte trucks and drivers that we currently use to move our current work load.
on the weigth capacity we currenly move, we can move up to 45,000 pounds od (payload weigth), having the zev truck +7,000-10,000 pounds heavier, it will mean that load weigth has to be reduced, and that more trucks are to be requiered to move the same ampunt of loads we currently move
our firm controls 100 class 8 tractors, and in total we have +150 employees
those positions are at risk, if our company looses efficency, and having more expensive trucks, that cost more to operate, and can work less miles per day, and move less weith per load, will make us close our doors
we proppose that no changes are imposes on zev trucks, until those trucks can have similar autonomy on one charge of bateries, and can carry similar total weigth that the trucks we cureently operate can move
possibly we can move to cng engine trucks because those ones produce 3% of contaminants, that de disel engine priduce, and allow more development on the technologies on teh zev trucks, and the instalation of the infraestracture that will allow us to charge trucks, when they are at our terminals, with drivrs resting at home
thanks and best regards
i will leave you with some charts, so you can better understand federal hours of serice and weigth limitations per load when using current trucks, and moving heavy loads under current ,limits
