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Comment 56 for Advanced Clean Fleets Regulation (acf2022) - 45 Day.

First NameDavid
Last NameAtwater
Email Addressdbatwater@vandepol.us
Affiliation
SubjectAdvanced Clean Fleets Regulation
Comment

I have one important thought and comment that needs to be made in light of recent news of major disasters that befall us in California and across the country; that is, having all of our emergency response “eggs in one basket” namely electric light, medium, and heavy duty electric vehicles needed for emergency response.

As a Company that has always been there through earthquakes, major snow events, huge deadly fires, and floods AND PANDEMICES, we have been participating in emergency response preparedness for decades.  

I know that electrification of emergency and other response vehicles will make any disaster recovery and response much worse in life and death situations.  In most, if not all of the disasters experienced in our State, one of the first effects experienced is that the electrical grid goes down.  Hence the requirement for back-up power for hospitals, police facilities, California’s Office of Emergency Services, and media outlets to name but a few, that also includes OUR solar powered offices with a standby 250KW generator that is regularly utilized often in area outages to keep our systems and equipment coordination running.

Just consider last month when the Governor was telling those with electric vehicles to not charge them due to overwhelming grid stresses.  This was not even coupled with another disaster, like a fire or earthquake…. or any other disaster where major response is required.

  With electric vehicles you cannot “get there from here!”  EVEN in that grid demand problem we experienced, our companies were involved working to keep power plants up with what they needed to generate power at record levels.  We CAN deliver fuels and products needed without electricity as all our vehicles are independently powered and carry fuel that is turned into power without electricity or using standby power.  We cannot use electric vehicle to fill those roles.

THE ASK:  Please exempt ALL vehicles that work to keep our State operating during crises.  That would include:  Fire Trucks, Ambulances, Police vehicles, utility vehicles, the many State, County, and local agencies vehicles that respond when disaster strikes. 

Exempt all the vehicles that deliver food prepared and grocery and fuel as these vehicles provide fuel for evacuations, and response and food to keep people alive right now.  The list would be large but the need during these events would be immediate and demand all resources available to preserve human life and health.

I appreciate your thoughts to make commute and local errand cars less polluting but using a broad brush to shut down emergency response vehicles, food and fuel deliveries  and support vehicles for example, lacks adequate consideration of the redundancy needs required for large crises. 

Remember, in all large emergencies, it is ALLWAYS, “All Hands on Deck.”


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Date and Time Comment Was Submitted 2022-10-10 13:15:35

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