Hello.
I am Tom Greene from Rancho California Water District. We serve over 150,000
people in Southwest Riverside County. We have over 1,000 miles of pipes, 100 wells
and pump stations and one hundred trucks. We currently have 7 and a half Megawatts of
solar power, and are working on another 5 Megawatts of
hydro-electric and battery storage projects. We have 6 vehicle charge
points installed so far and many of our employees are early
adopters with good results.
Because of those good results, We have been
looking to purchase heavy duty electric trucks and we are working
on a vehicle electrification master plan. We’ve checked the
specifications from over 30 manufacturers, on over 50 trucks, many
of which don’t even have a prototype yet. But we yet
haven’t yet found any chassis cabs or even heavy-duty pickups
that can meet the gross vehicle weight ratings and trailer towing
ratings, along with the distances needed to replace our trucks.
Some bus chassis looked promising, but a few manufacturers have
told us that the drive-trains are not rated for towing. Thus, we
are settling on purchasing some all-electric half-ton pickups for
inspectors in the short term. Specifications show that these trucks can tow
heavy loads, but testing has shown that they lose range by up to
two thirds when towing.
Thus, we are expecting that those trucks won’t be able
to carry the loads needed to do the work we need done every
day. We need to fix
pipes in the roads, this is work we do every day. Our work is often
performed in the streets, where the vehicles also use power take
off equipment and where there aren’t any charge points.
We expect that the vehicle manufacturers
will eventually engineer the trucks needed to perform our work in
the future. But to have every single public agency, searching
every single vehicle manufacturer to find specifications of all the
vehicles, every single budgeting time of the fiscal year is
wasteful and detrimental to getting the vehicles purchased.
Thus, we join with the Association of California Water Agencies and
the California Municipal Utilities Association in calling for CARB
to keep an ongoing Commercial Availability list, showing all of the
specifications of vehicles, instead of a vehicle unavailability
list. This includes the range results when fully loaded and
the pricing. We need to know about trucks that are actually
being built on assembly lines instead of just on the drawing
boards.
We also join the Metropolitan Water District
in requesting that the rule have some flexibility to extend the 50%
buying limits till the year 2030 for those classes of vehicles that
are not commercially available. Thank you.
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