Comment Log Display

The Santa Clarita Valley Water Agency (SCV Water) appreciates the
opportunity to provide public comments to the California Air
Resources Board (CARB) in response to the Proposed 15-day Changes
to the Proposed Regulation Order Advanced Clean Fleets Regulation
State and Local Government Agency Fleet Requirements (Proposed
ACF).

SCV Water was created on January 1, 2018, and serves a population
of 278,000 through 75,000 retail water connections. Our agency
supports the comments and concerns submitted by other public
agencies and organizations such as the Association of California
Water Agencies (ACWA) and California Municipal Utilities
Association (CMUA).
 
SCV Water believes that the proposed requirements and timelines of
the Proposed ACF do not provide public electric, water, and
wastewater agencies with a realistic pathway to compliance  and
jeopardize our ability to respond during emergencies.
 
SCV Water relies on highly specialized medium- and heavy-duty
vehicles to respond to emergencies, restore water service, and
prevent disruptions. Our experience in most major disasters
(wildfire, earthquakes, etc.) has been that one of the first
services to be impacted is the electrical grid and without a
functional electric grid a fleet of zero-emission medium- and
heavy-duty vehicles would be rendered inoperable. Other emergency
services such as firefighting rely upon water agencies to provide
extensive support during these critical emergencies. Therefore, the
exemptions and requirements of this regulations need to be revised
with emergency preparedness in mind.

We offer the following comments and suggestions:

Emergency Response Vehicles
While the regulation has some exemptions, the details and
complexity of each exemption make them almost impossible to
utilize. The proposed regulation also fails to recognize that
certain crews and vehicles do not have set routes and need to be
able to operate during extended emergencies. Therefore, public
agencies should be allowed to designate some vehicles as emergency
support vehicles and receive the same exception as police and fire
emergency vehicles.

Vehicle Purchase Requirements
The ZEV Purchase Requirement should not require public agencies to
purchase higher weight class vehicles that make it unsafe or more
difficult to operate larger vehicles in work sites or small
neighborhoods.
Vehicle downtime and interruption to essential services is one of
our biggest concerns; therefore, we have concerns about being
required to purchase vehicles from unproven manufacturers that do
not have service centers in our area or have the ability to
complete recalls and honor battery warranties. Therefore, public
agencies should be allowed to request an exemption if they believe
the available ZEVs are unsafe or unreliable for the job
application.

Vehicle Availability:
•	Keeping track of every ZEV manufacturer and model places a
significant administrative burden on public agencies, therefore; we
believe CARB should be responsible for maintaining a list of
available market-ready vehicles and configurations.
•	We are also in agreement with the Joint Public Agencies' comment
letter that manufacturers should be required to provide a
specification sheet for their offered vehicles, including evidence
of battery capacity range, fully loaded weight and dimensions,
compatibility with and run time of auxiliary equipment where
applicable, and payload; a delivery date for the vehicle within 18
months; and a list of service centers.

Infrastructure Exemptions:
SCV Water believes that there are too many variables outside of our
control and that it would be very easy for any agency to fall out
of compliance and not be eligible to apply for exemptions.
Furthermore, most fleets will need to make substantial upgrades to
their yards/facilities in order to support zero emissions vehicles.
Therefore, we encourage infrastructure extensions to be considered
beyond their proposed targets.

We appreciate CARB staff's effort to try to incorporate commentary
from various stakeholders in the latest draft and we encourage
continued engagement with all stakeholders to ensure that
implementation of the proposed ACF considers ongoing challenges and
technology limitations.