Thank you for giving the public the
opportunity to portray their thoughts on the recent ACF
proposal. There are a few issues in the proposal, first and
foremost, I strongly urge you to remove the 1/1/24 requirement on
drayage trucks entering a California port facility for the first
time to be Zero Emission. Best Drayage is a trucking company
based in the Central Valley of California focusing on container
drayage to the Port of Oakland. To date, there is no Zero
Emission equipment available that would allow us the opportunity to
service our customers’ needs without re-charging in
route. Our average daily haul ranges from 200-400 miles
round-trip. This just isn't feasible with the quickest charge
currently available taking 5-6 hours. Currently, drivers are
able to complete their workday within their legal driving hours,
adding a 5-6 hour charge to their day would make servicing the
Central Valley impossible for any drayage provider to do
legally.
Getting the cart before the
horse isn't going to help matters by forcing the purchase of a
vehicle that doesn't exist today. This is both impractical
and again, impossible to comply with. Rationally, this should be
tabled until the technology is available. I'm going to focus on the
1/1/24 registration requirement, this is what sticks out to me
most. It's common practice for fleets to upgrade and purchase
new vehicles in our market, one simply cannot upgrade their fleet
if their isn't anything to replace your old fleet
with.
Another big concern is the
public charging infrastructure, where is it, and will there be
enough? Logically, it's very unrealistic to think we can fast
forward that as well to meet a 1/1/24 deadline to service the
entire state. The vast majority of the trucking community
fuels at public fuel stations, not at their own sites.
Therefore, public charging stations would be a necessity to have in
route, off the major highways/corridors, just like we see now. The
weight of zero-emission trucks is also a concern, with the lightest
zero emission truck averaging 12,000-12,500 lbs. heavier than a
current diesel truck. This will tie the hands of all shippers
and consignees that are shipping and receiving freight in
California to drastically reduce cargo weights which will result in
dramatic cost shifts. Especially, those providing dried fruit
and nuts that are based here in the Central Valley feeding our
entire world, not just our state.
In closing, I don't deny the
need for cleaner emission vehicles but until that technology is
accessible for all Class 8 vehicles I urge you to postpone this
until the infrastructure is there to make it achievable. I
hope you take strong consideration into the impact and harm this
regulation will pose on the drayage industry if passed
prematurely. We've been on a few calls with the CARB staff
and I believe the perception is drayage trucks only operate within
the port complexes and are far different than other Class 8
vehicles. That's not the case, as I previously mentioned, our
average length of haul ranges from 200-400 miles round-trip.
There's really no difference between a "drayage" truck servicing
the Central Valley and the many thousands of Class 8 trucks that
have much more time to make the transition to Zero
Emission.
Again, thank you for allowing
us the opportunity to speak freely and trust you will allow the
time for due diligence and consider moving your marker back to a
much more reasonable time frame.
Jeff
Cox-President
Best Drayage
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