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Comment 73 for Informal Public Comments on the Proposed Advanced Clean Fleets Rulemaking (acf-comments-ws) - 1st Workshop.


First Name: Jeff
Last Name: Wood
Email Address: jewood@parelectric.com
Affiliation: Utility Line Contractor

Subject: Advanced Clean Truck Rule
Comment:
Greetings, I am commenting to make sure that staff understands the
challenges utility line contractors will have with the ACT Rule. 
Please know that our company is in support of clean air goals and
environmental stewardship.  I recommend for crane trucks and other
HD vehicles that will be working in mountainous terrain and other
challenging backcountry areas, should be exempted from the ACT
Rule.  The reason is that at this point and time there are no ZEV's
available that can operate in these areas.  These vehicles simply
perform too many heavy duty functions and will surely be unable to
recharge or operate from remote mountainous areas. There will be no
battery charging infrastructure close by and the EV's would not be
able to run the equipment that is currently powered by the existing
low emissions diesel engines - 2010 and newer. Should a ZEV lose
charge voltage in one of these areas the cost and time delay would
be unmanageable. It is probable that ZEV's just driving to these
job sites would be difficult.  We must find a way to exempt
operations that will be building, repairing and engineering our
renewable transmission infrastructure for our State.  I do believe
it makes good sense for some applications throughout California to
move toward the ZEV goals but the application of building and
maintaining our energy transmission infrastructure needs to be
exempted from this rule at this time. Respectfully, Jeff Wood 

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Date and Time Comment Was Submitted: 2021-10-06 08:17:11



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