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Comment 35 for Informal Public Comments on the Proposed Advanced Clean Fleets Rulemaking (acf-comments-ws) - 1st Workshop.


First Name: DIANE
Last Name: ENGLER
Email Address: dianeengler@lacsd.org
Affiliation: SANITATION DISTRICTS OF LOS ANGELES CNTY

Subject: Comments on ACF Rules
Comment:
Hello,

It is in all of our best interests to make implementation of these
new regulations successful.  If we fail, it will open the door to
another generation of diesels on our roads - and in our lungs.

Please consider the following.

I think we need to re-define NZEV.  As it stands, NZEVs with
electric only miles do not exist, and development of the concept
trucks will not be profitable or even likely if sales will be
limited to public fleets and then ended in 2035.  Also, just
because a vehicle can be plugged in, doesn't mean it will be.  RNG
powered trucks eliminate PM emissions now, have negative GHG
profiles, and in the case of 0.02 g/b-hp, can reduce NOx
significantly, now.

In the case of fleets providing a public service critical to the
public's health and safety, I think we need a class of exemption
for "utility critical response vehicles."  The use of "emergency
vehicle" is already taken, and could be confusing.

Please do not hesitate to reach out to me if I can provide any
details on the LACSD RNG fleet or critical response vehicles.

Thanks!
-Diane

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Date and Time Comment Was Submitted: 2021-09-09 16:05:06



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