Comment Log Display

The Rio Linda Elverta Recreation and Park District appreciates the
opportunity to provide comments on the ACF draft regulatory
language (March 23 iteration) for public fleets as proposed by
California Air Resources Board (CARB) staff.  While the latest
iteration of the ACF regulation reflects some of the exemptions and
extensions that have been requested, we remain seriously concerned
with the following and must request further amendments accordingly:
 

Timelines and Public Funding. The proposed regulations continue to
impose aggressive timelines for public fleets to comply and do not
consider existing local agency budget constraints and funding
methods for capital projects.  

Many local governments budget every two years, and many have a
five-year capital budget cycle that cannot be easily repurposed at
the scale this proposed regulation would require. Mandating
compliance to start January 1, 2024, for a proposed regulation that
would require significant and immediate investment and allocation
from local agency budgets for the preconstruction, site
preparation, and coordination with energy providers 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. Upgrading infrastructure,
purchasing vehicles, training workforce, and complying with
mandated reports is not something local agencies can easily comply
with. Inflation and other cost increases have already stretched
budgets to their limits.  

The proposed regulation also ignores existing market realities and
the time needed to develop and ramp up an infrastructural system
that can support an electrified fleet of essential 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. There is no current funding for these increased costs.
It will take at least a year to put together a funding plan and
then could take another year or more to place new taxes on the
ballot or hold Proposition 218 protest proceedings. If voters
reject such tax and fee increases, local agencies will be left with
no resources to afford the immediate up-front costs necessary to
comply with the regulation.

While savings may eventually manifest from retiring or repurposing
assets oriented to internal combustion engines (ICE), they will
have no effect on the upfront capital expenses. For these reasons,
we believe that local governments need an extension of at least
four years from regulation adoption and we encourage the State of
California to develop a substantial grant program to support local
governments in complying without imposing an undue burden upon
their ratepayers and taxpayers already struggling to make ends meet
at this time of high inflation.

Exemptions.  Local agency vehicles essential to the health and
safety of residents should be fully exempt from the regulation.
While some of these vehicles are captured under the current
emergency vehicle exemption, it should be expanded.

In addition to emergency vehicles currently defined in the
California Vehicle Code, the following local agency vehicles must
be operable 24 hours per day, 365 days per week. Any interruption
in their regular use could jeopardize the health and safety of the
communities they serve. Given the most likely current or future ZEV
options will depend upon a consistently accessible source of
electricity, the risk of disruption whether due to an earthquake,
public safety power shutoff, rolling brownout, wildfire, flood, or
other natural disaster is too great to risk the operability of
these vehicles and health and safety of Californians:

•	Valve trucks, welding trucks, and other vehicles essential to the
repair and maintenance of water, wastewater, and other utilities.
These are particularly critical during and following the very
events that could interrupt the ability of ZEVs to operate.
•	Vehicles used by open space, regional park, and other agencies to
spot wildfires, mitigate wildfires, rescue lost or injured hikers,
and prevent poaching of animals.
•	Vehicles used by mosquito abatement and vector control agencies
to prevent and disrupt the proliferation and uncontrolled spread of
dangerous known and unknown vectors.

In addition, we are requesting a Small Agency/Department automatic
exemption based on fiscal hardship.  We also request you expand the
existing delayed implementation for small vehicle fleets in
non-designated (non-low population) counties to include agencies
that purchase less than two vehicles in a calendar year. Otherwise,
the current "rounding up" rule would apply the regulation to 100%
of vehicles purchased by agencies purchasing just one vehicle in
the initial three-year implementation period even though that
period is intended to only require 50% of vehicles comply. Agencies
purchasing just one vehicle in a calendar year are the smallest
agencies in the state that are leased capable to comply with the
reporting mandates and costs associated with the regulation.
Moreover, in purchasing just one vehicle an agency has no means to
mitigate the added cost of ZEV additions as an agency purchasing
multiple vehicles can by strategically purchasing 50% ICE vehicles
for the vehicle models that may be least affordable as ZEVs.

Price Caps. We request that CARB impose price caps to ensure the
market positively responds with vehicles at competitive rates.
Local governments strive to be good stewards of the taxpayer's
dollars, but without price caps, complying with the proposed
regulations may force a purchase of ZEVs that are put to market at
an artificially inflated rate. With the inclusion of a percentage
price cap, manufacturers will be unable to potentially manipulate
the market with unwarranted unit costs.

Inventories. We request CARB 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 that models will
be available.   
 
Again, thank you for allowing us the opportunity to provide written
responses to the proposed ACF Regulations.  
 
Sincerely, 



Mike Heller
General Manager
Rio Linda Elverta Recreation and Park District