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Comment 34 for Advanced Clean Fleets Regulation (acf2022) - 45 Day.

First NameJeff
Last NameCox
Email Addressjcox@bestdrayage.com
AffiliationBest Drayage
SubjectProposed ACF-Drayage Truck 1/1/24 Requirement
Comment

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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Date and Time Comment Was Submitted 2022-10-07 09:08:08

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