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Comment 144 for Advanced Clean Fleets Regulation (acf2022) - 15-1.

First NamePacal
Last NameCornejo-Reynoso
Email Addresscornejop@emwd.org
AffiliationEastern Municipal Water District
SubjectEMWD Comments on 15-Day Proposed Advanced Clean Fleets Language
Comment
April 7, 2023

Mr. Tony Brasil
California Air Resources Board
1001 I Street
Sacramento, CA 95814

Mr. Craig Duehring
California Air Resources Board
1001 I Street
Sacramento, CA 95814

Mr. Paul Arneja
California Air Resources Board
1001 I Street
Sacramento, CA 95814

Subject: EMWD Comments on 15-Day Proposed Advanced Clean Fleets
Language

Mr. Tony Brazil, Mr. Craig Duehring, and Mr. Paul Arneja:
On behalf of Eastern Municipal Water District (EMWD), a water,
wastewater, and recycled water provider serving nearly one million
residents in western Riverside County, I am writing to make you
aware of significant concerns that EMWD has identified in the
15-day proposed language of the California Air Resources Board
(CARB) Advanced Clean Fleets (ACF) rule. EMWD is generally
supportive of the State's climate goals and it is the intent of
these comments herein to provide CARB staff with feedback, which if
considered, would make the rule more implementable for public
agencies. EMWD must ensure that we can continue to provide a high
quality of service in all circumstances. As the ACF rule is
currently written, certain provisions would limit the use of EMWD's
fleet in both routine and emergency situations.

EMWD has identified three primary concerns with the ACF rule.
First, the rule could result in publicly owned electric utilities
and public water and wastewater agencies needing to use vehicles
beyond their useful life or replace them with a ZEV that does not
have adequate capabilities to restore service, maintain
reliability, and respond in emergencies. The proposed regulation
provides three exemptions that attempt to provide flexibility: a
Daily Usage Exemption, Zero-Emission Vehicle (ZEV) Purchase
Exemption, and ZEV Fueling Infrastructure Exemption. These
exemptions, however, are severely limited because they can only be
used for vehicles that are 13 years or older. Data submitted to
CARB shows a typical utility vehicle lifespan is 7-10 years, given
the heavy usage.

Additionally, the daily usage exemption is underpinned by a skewed
energy usage formula. The rule includes a daily usage exemption
(which, as noted above, is currently restricted for use to replace
vehicles that are 13 years or older) that could allow a publicly
owned utility to purchase a traditional utility vehicle if the ZEV
configuration does not meet the daily needs of the utility. To
determine daily needs, there is a 60-month look-back assessment
that requires fleets to discard the highest three energy usage days
for a vehicle, which could prove to be problematic in fully
assessing the capabilities needed for a particular vehicle. As an
example, if a utility vehicle is deployed to restore service after
a wildfire or earthquake for three days, those three days should be
factored into the formula as an accurate representation of the
vehicle's usage.

Lastly, the issue of vehicle availability remains a priority issue
for EMWD. The lack of medium-heavy duty ZEV vehicles in the market
will impact an agency's ability to reliably maintain service. There
are a limited number of manufacturers actively producing equipment
in this range. While manufacturers may claim production or near
production readiness of certain vehicle types, actual production
capability to meet even limited demand is far from mature and in
some cases does not exist at any reasonable scale at all. This is
further exacerbated by the cancelation of ZEV purchase contracts by
manufacturers. Fleets are provided one-year to enter into a new ZEV
contract if a vendor cancels an existing order. EMWD has observed
these cancellations even with the purchase of Internal Combustion
Engine (ICE) vehicles where dealers are failing to meet extended
delivery schedules and manufacturers are cancelling orders.
Additionally, an exemption cannot then be acquired to purchase an
available ICE powered vehicle if a vendor claims availability of a
new unit model within 18 months. This further delays the delivery
of a needed vehicle for maintaining critical public
infrastructure.

EMWD appreciates the opportunity to comment on this proposed rule
and would like to reiterate that we are supportive of a reasonable
ACF ruling. As climate change worsens and weather events become
more extreme, EMWD acknowledges the need to limit greenhouse gas
emissions. However, this initiative should not impact a public
utility's ability to provide essential services to their customers
and the communities that they support. We encourage CARB staff to
continue analyzing the potential impacts to public fleets across
the state. If you have any questions or if EMWD could be of
service, please feel free to contact me at (951) 928-6130, or by
email at mouwadj@emwd.org.
Sincerely,
Joe Mouawad, P.E.
General Manager

Attachment www.arb.ca.gov/lists/com-attach/909-acf2022-VjMGbVAmADdRCFIx.pdf
Original File NameEMWD Comments on CARB ACF Rule (EDITED).pdf
Date and Time Comment Was Submitted 2023-04-07 15:27:28

If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.


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