Dear CARB,
We’ve had
a number of constituents contact me about the proposed regulation
the Air Resources Board staff is planning on bringing before the
Governing Board in October that will require the replacement of all
diesel, gasoline and natural gas vehicles > 8,500 pound GVWR
with electric vehicles for all state and federal fleets, all public
fleets, and for high priority private fleets with 50 vehicles or
more or annual revenues of $50 million or more in annual revenues.
We understand the phase out will start with mandates as early as
2025.
Of concern is
the selection of high priority fleets simply on the basis of the
number of vehicles or the amount in annual revenues without any
distinction on the types of businesses that can feasibly accomplish
this endeavor, let alone economically manage the requirement,
especially in a time of economic downturn and high inflation.
Constituents from the construction, agriculture, and emergency
power systems industries have also contacted my office stating
companies that meet the high priority criteria will be forced to
replace with electric vehicles leaving those companies at a
competitive disadvantage to those fleets that are not private high
priority fleets and which are not mandated to replace their
vehicles.
Also at issue are the heavy duty rental vehicles
serving these industries like water trucks and dump trucks. These
vehicles have no ability to be charged in remote locations such as
highway and construction projects. Additionally, heavy construction
and agricultural equipment service vehicles operated by such fleets
also have no ability to charge their vehicles remotely. These
vehicles will require high voltage DC chargers that are unavailable
at remote sites and along the highways in convenient
locations.
Also of concern are the costs this will impose on
private companies for the charging systems required for these heavy
duty vehicles, and the infrastructure to support such systems.
Large companies in these businesses with hundreds of vehicles will
not have the financial resources to replace so many vehicles while
at the same time manage their day to day business. We are also
perplexed with the aggressive phase-out this regulation represents
when the proper utility infrastructure and DC charger access for
heavy duty vehicles in the state is barely existent.
Before the Governing Board approves this regulation
that places inequities and financial burden on large private fleets
and other fleets in the state, we ask the following of your
Board:
1.
Letters have been provided to your staff
identifying business types such as heavy construction equipment
rentals, and heavy construction equipment and critical services
maintenance and repair that cannot feasibly replace with electric
due to the specialty vehicle type and variability of the day to day
vehicle operations. We understand these issues have not been
adequately addressed. Wee ask the Governing Board to postpone the
adoption of this regulation until staff can properly distinguish
what private fleets (and public, state and federal fleets) can and
cannot feasibly manage the transition being proposed.
2.
We need
real answers to how the tremendous increase in state electrical
power will be met to accommodate this proposal. Currently,
California is already importing nearly 30 percent of its power
needs. This regulation will only increase that demand for daily
charging. The utility infrastructure for the needed increases needs
to be in place to feasibly manage what is being required of these
fleets. We know the Board has been wrestling with the
infrastructure issue for automobiles and light duty vehicles and we
are greatly concerned when you add the vehicles from these major
industries to the list.
3.
We need to know the plans for addressing public
DC charging stations along the highways and for remote locations.
Many EV stations for cars have been installed at convenient
locations, but these are not compatible or practical for use with
the heavy duty vehicles used in the construction, agricultural,
heavy duty rental, and critical services industries. Very little is
in place for the required DC charging stations for these heavy duty
vehicles, and costs for the chargers and installation is over
$100,000 each, not including the costs for necessary electric
utility upgrades. Without the necessary DC charging stations for
these vehicles, these industries will be unable to manage necessary
construction activities and repair services, and many vehicles and
drivers will be unsafely stranded.
4.
As all batteries have a limited life, we need to
know if plans are identified for the coordination with DTSC and EPA
to manage the hazardous waste disposal. A single Class 8 day cab
can have up to 15,000 pounds in batteries that will ultimately
become hazardous waste.
I look forward to the answers to these questions
before the Governing Board moves forward with this regulation.
Assemblywoman Blanca E. Rubio