Comment Log Display

July 20, 2022

To: California Air Resources Board

From: Gary Arant, General Manager, Valley Center Municipal Water
District

Subject: All Clean Fleets Rule - Commercial Availability of EVs 


Dear CARB Commissioners and Staff,

Among retail water agencies, there have been ongoing discussions
regarding a critical aspect of a successful implementation of this
important regulation. In addition to concerns about a very short
time frame for implementation, including the timely installation of
required on-site charging infrastructure issue, much attention has
been focused on the topic of "Commercial Availability" of suitable
Vocational EVs (vehicles water and wastewater utilities will use)
and how that will be defined in the final regulation.

In our view, there are many important aspects to the term
"Commercial Availability".

Available, but in What Quantities?

1.	Vocational EVs may be commercially available but are they
available in sufficient quantities to create a competitive bidding
environment for public agencies?
Not only should CARB monitor what EVs are commercially available,
but also in what quantities are the EVs available to meet the needs
of literally hundreds of water, wastewater, and electric utilities
to provide a competitive bidding market.

Available but at What Price?

2.	In light of regulatory pressure placed on water and wastewater
utilities to maintain water and wastewater service affordability,
especially to disadvantaged and underserved communities, how much
more should a public water/wastewater/ electric utility be required
to pay for an EV compared to comparable ICV....30%, 50%, 75%, 100?

CARB ACF regulations need to establish a cost premium cap of 30%
beyond which the utility has the option to purchase an ICV.

Available,  but what kind of Market?

3.	Without items 1 and 2 above, the ACF Regulation is creating a
market that requires utilities to purchase Vocational EVs without
determining if sufficient quantities exist to create a competitive
market and at what cost premium cap.  As such,  a distorted market
emerges where conditions are ripe for unfair pricing (gouging) by
EV manufacturers and retailers.

Without mechanisms in place to determine when sufficient numbers of
a particular EV are available to create a bid competitive market
and has not set a cost premium cap, then it will need to monitor
and regulate the marketing and sales practices of EV manufacturers
and retailers.

Available, but When?

4.	An important component of Commercial Availability is when can
the EV be delivered.  3 to 6 months is reasonable and customary, 
but not 1 to 2-year estimates of which we are aware.  The ability
of a utility to function and respond is necessarily tied to the
possession of critical and specialized equipment. 

CARB needs to set a parameter for EV availability with a delivery
timeline not to exceed 6 months and if the quoted delivery time
exceeds 6 months, the utility should have the option to reject the
bid and purchase a comparable ICV. 

In Conclusion

These provisions will incentivize EV manufacturers and retailers to
produce Vocational EVs in sufficient quantities to facilitate a
competitive bidding environment for vehicles priced reasonably
comparable to ICV prices and with acceptable delivery periods. 
While this may delay the effective implementation of ACF at the
agency level, it will help to guarantee the long-term success of
the regulation.

Thank you for your consideration.

Gary T. Arant
General Manager