Comment Log Display

Monterey-Salinas Transit (MST) concurs with the points made in a
letter from the California Transit Association dated April 30, 2018
regarding the proposed Clean Transit rules as they would affect
public transit agencies.  

MST is the public transit operator for Monterey County and has
regional connections into Santa Cruz County, Santa Clara County,
and San Luis Obispo County.  MST's 60 bus routes cover a nearly 300
square mile service area of coastal California.  In fact, MST's
service area covers fully 1/5 of the coast of California, and has
one of the longest public transit routes in the nation - the
equivalent distance of Washington, DC to Philadelphia.

It is because of this large service area that MST has serious
concerns about the proposed rules that would require a percentage
of any bus order to include electric buses.  As of this date, the
majority of MST's routes are too long to utilize electric buses
given the current range of the battery powered vehicles.

Despite that, MST has moved forward with testing and evaluating
various electric vehicle technologies.  In fact, MST had the first
in-ground wireless enroute charging system (WAVE) in North America.
 We retrofitted an old diesel themed trolley bus with an electric
propulsion drivetrain.  The wireless charging system has performed
very well, although at the time of installation, only 50 KWh
charging was available.  Now the industry standard is 250 KWh.  As
such, we are awaiting delivery of 2 BYD plug-in electric buses, and
are about to submit a grant application to the federal government
for two Gillig electric buses.  In addition, MST conducted an
electric bus implementation study to help us assess which of our
bus lines would be conducive to electric buses, and which weren't
given the range of today's vehicles.  And, MST has spent hundreds
of thousands of dollars to upgrade our two bus garages to have
enough power to charge 19 electric buses.  MST took the initiative
on its own regarding electric buses without being forced by CARB
regulations.  As a smaller transit agency, it is important for us
to carefully evaluate the performance of the various electric bus
manufacturers and charging systems before we make any major
electric bus purchases.

Another barrier to electrification is PG&E and its understaffed
engineering department here in Salinas and the inordinate amount of
months it takes to get on PG&E's construction schedule.  It has
been nearly impossible to have any electrical design or
implementation work done by PG&E.  In addition, where MST is going
to be building a third bus garage, PG&E does not have sufficient
power to accommodate all proposed projects in the Business Park
where we will be constructing that facility.  And, PG&E still does
not have any favorable rates for electric bus charging.  And, it is
my understanding that they are about to shift their "peak period"
rates later into the afternoon/evening, which is precisely the time
our mechanics would be doing repairs and charging the electric
buses.

A final concern that should be raised relates to the role of public
transit operators in natural and/or man-made disasters.  We are
called upon for evacuations and emergency transportation during
such events.  It is common in natural disasters for the power to go
out.  In fact, the power lines themselves can start wildfires
during windy conditions.  If we are eventually 100% electric and
the power goes out, how are we going to recharge our buses as they
are needed to make multiple trips sometimes to remote areas of the
county to rescue evacuees.

Thank you for the opportunity to comment on this important matter. 
We hope that you will consider a less aggressive implementation
schedule for smaller agencies in air basins with good air quality,
such as the Monterey Bay Area.