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Comment 86 for Informal Public Comments on the Proposed Advanced Clean Fleets Rulemaking (acf-comments-ws) - 1st Workshop.


First Name: Ron
Last Name: Nuss
Email Address: ron@nwexc.com
Affiliation: Northwest Excavating, Inc.

Subject: Advanced Clean Fleets Regulation
Comment:
Dear Chairman Liane M. Randolph and Members of the Staff:

Thank you for giving me the opportunity to write to you today.  I
am the head mechanic for Northwest Excavating, Inc. a family owned
construction business in Southern California employing families and
supporting local businesses for more than 50 years.  It's difficult
conducting a construction business in California due to the
regulations in our industry.  As you know we have spent millions to
comply with the Off-Road Diesel Regulation, On-Road Diesel
Regulation and PERP not to mention other State and local agencies. 


I would like you to please consider removing the 3/4 ton work truck
from the Advanced Clean Fleet Regulation.  The construction
industry is different from the standard trucking industry.  Our
problem is we would not be able to charge these vehicles at our
terminal / home base because the foreman and operators drive these
vehicles to the jobsite then home every night.  We would be asking
our employees to install charging stations at their personal
residents, If that were even possible.  Also they would have to be
compensated for the added cost to their electrical bill.  Some
jobsites are more than 100 miles from their home.  The other
problem is construction jobsites only have temporary power.  To
charge ZEV trucks the contractor would have to install a diesel
generator and a charging station.  If nothing else please consider
pushing back the implementation of the 3/4 ton work truck to a
later date until more infrastructure will be available to support
these vehicles.  The construction industry will be the ones
building this infrastructure.  It would be nice if we could use our
existing low emission trucks to do that for our community.

Please consider what I have proposed and thank you for your time.

Sincerely,

Ron Nuss


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Date and Time Comment Was Submitted: 2021-10-28 15:30:48



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