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Comment 53 for Advanced Clean Fleets Regulation (acf2022) - 45 Day.

First NameRajiv
Last NameJain
Email Addressrjain@btw1.com
AffiliationBridgeport transportation & Warehousing
SubjectAdvance Clean Fleets Regulation
Comment

the new rule of 800,000 miles and life of truck 18 years are both unrealistic 

normally drivers drive 500 miles a day, 2500 miles a week, 10,000 miles a month

and about 100,000 a years so in 8 years they drive 800,000 miles  

the new rules are not realistic.

I called freightliner of Oakland to buy new truck so they can last 8 years based on my calculation

they said the earliest they can deliver the trucks is june 2024-book now for $500 down, cost $224000 and there are no grants for it .

and they can deliver on max 100 trucks on advance booking 

other used truck inventory is very low 

cost with less than 400,000 miles are cost 120,000a nd they are not many of those to buy

second part of the rule is even more unrealistic

register these trucks before 12/31/2023 in the drayage registry 

and 1/1/2024 only zero emission trucks can registred 

there are very few zero emission trucks which can last for more than 200 miles on a single charge 

Tesla is now getting ready to deliver some trucks -which cost upward of $400,000, grants is only $120,000

again tesla says it will begin producing these trucks soon

we truckers have less than 14 months to buy or replace trucks 

both these rules are not realistic

if goal is to be zero emission truck by 2040

then we should start the rule on 2032-8 years , 800,000 truck will last till 2040

by 2035-2038, there will be enough truck produced

if truckers buy used trucks of 400,000 miles it can be used only for 4 more years and then they need to buy zero emission trucks again ..nut there or cheap to buy 

if we can be real then instead of 800,000 mile rule make 1,000,000 miles 

plus take away registration in drayage 1/1/24-for zero mission ...

zero emission should come in to play after 1/1/2032..not earlier...

if we cannot register normal diesel truck after 1/1/24 and the goal is replace all diesel trucks by 2040...that is 16 years away 

This makes no sense ..one cannot replace 5000 trucks in 14 months ...

so if the plan to kill small truckers/business owners then it is a good plan -

already we are having issues not enought truck driver and now we will not have enough trucks to do we cannot do with what trucks we have 

the rule was 2010 engine will be good for a long time-fully compliant 

and now with 800,000 mile truck even 2010 engine truck is not usable 

just be real !!!

dont destroy port trucking 

 

 

 


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Date and Time Comment Was Submitted 2022-10-10 12:14:22

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