Comment Log Display

The City of Bakersfield appreciates the opportunity to comment on
the California Air Resources Board's (CARB) Advanced Clean Fleets
(ACF) draft regulatory language (March 23 iteration). The city
seeks clarity on several items. We also have serious concerns about
aggressive timelines, which due to local budget cycles, are simply
unattainable.

We are grateful for the collaborative workshops held by CARB to
discuss our concerns and for providing feedback on some of our
suggestions. While the latest iteration reflects some of the
exemptions and extensions that we requested, we remain concerned
with the following: 

Lack of Price Caps. We recommend that CARB consider imposing price
caps to ensure the market responds positively with vehicles at
competitive rates. Local governments strive to be good stewards of
the taxpayer's dollars, but without price caps, the proposed
regulations may result in zero-emission vehicles that are put to
market at an artificially inflated rate. A percentage price cap
would potentially prevent manufacturers from manipulating the
market and help local governments protect taxpayer resources. 

Inventories. We believe that CARB should provide a list of
available manufacturers that have market-ready vehicles in the
medium- to heavy-duty class sizes, 2B-8. Availability of model/body
types of multiple weight classes (and functions) are not confirmed
by fleets, but rather by manufacturers informing CARB which models
will be available.  

Timelines and Public Funding. The proposed regulations continue to
impose aggressive timelines for compliance. They do not consider
public budgets and funding methods for capital projects. Many local
governments follow a two-year budget cycle, and many cities have a
five-year capital budget cycle that cannot be easily repurposed at
the scale this proposed regulation would require. Requiring
compliance to start on Jan. 1, 2024, would require significant and
immediate investment from local budgets for the preconstruction
that is simply unattainable. Electrifying service yards to support
an electrified fleet is a much greater undertaking than a simple
electricity panel upgrade or some quick trenching in the parking
lot. The time and costs for planning, engineering, and expansion of
both the electrical capacity of a facility's system and the
distribution system that feeds it are well beyond the available
budget of cities. While savings will eventually manifest from
retiring or repurposing internal combustible engine assets, they
will have no effect on the upfront expenses. For these reasons, we
believe that local governments need an extension of at least four
years from regulation adoption. 

The proposed regulations ignore existing market realities, as well
as the time needed to develop and ramp up an infrastructural system
that can support an electrified fleet of waste, water, and sewer
utility vehicles. If required to comply with the proposed
regulation as drafted, the projected infrastructure and fleet costs
will add substantial rate increases across multiple public works
and utility service departments.  

In Bakersfield there are approximately 384 vehicles that could be
affected by this regulation. To transition from our current
infrastructure (LNG and CNG) to electric or hydrogen would take
considerable planning and funding. The City has spoken with vendors
who have indicated that the phase 3 version of refuse trucks will
not be out to market until later this year and is estimated to be
limited to a restrictive 1,100 stops and 100 miles. Until we can
test these vehicles ourselves, we cannot be certain they will meet
our current needs without major changes to programs or staffing.

This proposed regulatory language fails to account for rising
utility costs, substantial mandates from multiple regulatory
bodies, market realities, budget deficits, and affordability issues
facing our residents. 
 
Again, thank you for allowing us the opportunity to provide written
responses to the proposed Advance Clean Fleets Regulations.