Comment Log Display

On behalf of the Otay Mesa
Chamber of Commerce, we would like to comment on the Advanced Clean
Fleets regulations being proposed by CARB.
 
Otay Mesa is home to
California’s largest commercial land port of entry with an
estimated 7,000-9,000 truck crossings per day (3,500-4,500
northbound and 3,500-4,500 southbound). Otay Mesa has a unique
trucking community, which travels to the maritime ports in the Los
Angeles area and works with large manufacturers in Baja California.
This phenomenon makes some of our truckers -even small size fleet
operators-, fall under the high priority fleet category and/or
drayage categories which requires very aggressive transition
timelines. We request CARB consider the following changes to the
Advanced Clean Fleets regulations:
 

The January 1, 2024 deadline
after which only zero-emission (ZE) drayage trucks may be added to
CARB’s drayage reporting system should be moved to a future
data, when it is actually viable to purchase a ZE truck. Preventing
diesel trucks from entering maritime ports will be extremely
detrimental to California business and trade. 
The CARB exemption should
also consider pricing and not just availability. If there are very
few ZE trucks available, pricing could soar and it would be
financially impossible to purchase a ZE truck. Studies show new
battery electric trucks cost approximately three times more than
the cost of a traditional diesel truck. In addition, the life cycle
of a battery electric truck could be much shorter than a regular
truck.

 
It is important for CARB to
truly understand the cross-border manufacturing phenomena that
moves billions of dollars in both Otay Mesa and Calexico. The
amount of truck trips these industries require is certainly not
viable to acquire with the new dedicated services being offered and
many of them -if not all of them- are restricted from acquiring
100% of trucks trips in California because of Mexican
regulations.
 
Infrastructure to
Fuel/charge Zero Emission Vehicle (ZEV) trucks 
 
The proposed regulation does
not ensure the required infrastructure will be in place to handle
re-fueling/charging ZE trucks along important freight corridors. In
addition, investments are being focused on maritime ports and
highways even though California’s land ports are the gateway
to commerce in California. There is a complete disconnect between
the timeline CARB is 
 
 
proposing and the development
of charging/re-fueling stations which. CARB should not assume this
will be coordinated by the private sector and other California
agencies. 
 
Currently, there are no plans
to develop a ZE re-fueling/charging station in Otay Mesa, other
than a small station that could handle 2 trucks and one private
fleet operator that is not a cross-border trucker. 
 
Operators that fall under the
priority ruling have trucks in Baja California in addition to Otay
Mesa and ZE charging/re-fueling stations are not being developed or
even planned in Baja California.
 
 

We ask that CARB ensure a
public charging/re-fueling station(s) that can handle cross-border
trucking needs be funded and built in the vicinity of
California’s most important commercial land port of entry and
the proposed new East Otay Port, so that critical essential goods
can keep being transported before the mandate takes place. In FY
2021, more than $56 billion of imports and exports were processed
through the Otay Mesa commercial port of entry.

 
Timeframes for
Hydrogen Technology
Related to timeframes, it is
important to note that there are many advantages to hydrogen fuel
cell technology, especially for long-haul truck use cases, because
hydrogen is lighter, it takes less time to re-fuel, and the range
is similar to diesel fuel. Hydrogen technology is several years
behind battery electric technology. The Otay Mesa community needs
time to wait for hydrogen fuel cell technology to be ready to use,
investing in a large number of electric charging stations that may
become obsolete in a few years when companies have more hydrogen
options would result in significant financial loss. Time should be
given to industry to plan for the use of hydrogen in the next five
years (2028).
 
Funding
Opportunities
Regarding California’s
incentive funding programs to comply with this regulation:
 

We ask that you consider
funding equity by region, vulnerable populations and size of
company, so small and medium size Hispanic operators are not left
out.

 
Before moving forward with
this mandate, the California Energy Commission should have an
accurate estimate of energy projections for the increased usage
these regulations will generate and ensure the PUC has worked out
the viability of this additional energy supply with the California
utilities. Specifically, the energy demand estimates being
developed in response to Assembly Bill 2127 (2018) and Senate Bill
643 (2021) should be incorporated into the demand estimate used by
the PUC. It seems quite logical to state but the fact is
that these energy estimates have not been quantified or
incorporated into any supply plan.  
 
If approved as is, this new
regulation will have a dramatic and catastrophic impact on supply
chains and inflation. While we completely agree with the climate
action challenges our world is encountering, we respectfully
request the following:
 

We ask that the State of
California provide an in-depth economic expert analysis of this
proposed regulation before implementing, to avoid any potential
catastrophic disruptions to our supply chains and
California’s economy. 

Finally, while we appreciate
CARB’s goal to protect vulnerable communities, 
 

We ask that CARB be forceful
in mandating their land use guideline document to Cities and
Counties, which would ensure residential communities are not placed
adjacent to industrial areas: a simple solution that would protect
families from being placed in heavy truck traffic areas. 

Original File Name: Advance Clean Fleets Regulation Comment Letter.pdf

Date and Time Comment Was Submitted: 2022-05-17 09:31:25