Comment Log Display

The Harbor Association of Industry & Commerce (HAIC) is a
non-profit industrial and commercial trade association that serves
as a united voice on transportation, energy, environmental, and
land use issues affecting the harbor business communities. In
response to the California Air Resources Board (CARB) September 9,
2021, workshop on the Advanced Clean Fleet (ACF) rule, we refer to
earlier comments submitted on March 17, 2021:

1.	We would like to see a clear distinction between short-haul and
long-haul heavy-duty (HD) trucks.
2.	Allow for the accommodation of H2 fuel cell (H2) Zero-Emission
Vehicle (ZEV) technology as one of the options for long haul trucks
in upcoming drayage truck rulemaking and incentive programs.

Additionally, we are submitting comments on the CARB ACF draft
rules and Total Cost of Ownership (TCO) document published on
August 25, 2021. This comment letter evaluates both the CARB rule
language and the cost calculations used to justify the timing of
rule requirements. We have concerns about the acceleration of the
rule schedule resulting in high costs in the early years and a
disproportionate cost burden on the fleets that are part of the
early compliance (drayage trucks and others).

In the battery-electric (BE) truck calculations, we have identified
several factors increasing operational cost to short and long-haul
operators, including the need for multiple charging stations and
extra labor hours. To the extent that H2 trucks are considered as
an alternative because of their higher suitability for long haul
truck applications, it will be necessary for both H2 truck and H2
fuel production technology to be competitive with BE and diesel
technology. Otherwise, the ZEV burden for long-haul trucks will
become infeasible.
 
BE and H2 Vehicle Purchase Price:
The current (2022 delivery) BE truck purchase price is three times
the purchase price of an equivalent diesel truck, based on HVIP
references and other published sources (including SCAQMD). The
assumption that the new BE truck purchase price will drop
significantly by 2025 due to manufacturing efficiencies; such a
price drop is unlikely.  

For H2 trucks, the assumed purchase price decline is even more
significant. The H2 truck price is currently approximately 4.0
times the purchase price of an equivalent diesel truck, based on
extrapolation of vendor information found on the HVIP website. This
translates to a price drop by a factor of 2.5 in three years (from
2022 to 2025), which again seems unrealistic.

H2 Fuel Purchase Price:
In the ACF TCO document, a chart showing H2 fuel price reaching
$5/kg in 2030 and remaining at that level afterward indicates that
this is based on a quoted price projection. The $5/kg is a price
target for H2 trucks to be competitive with BE technology, not a
price projection for 2030. The current H2 price is well over $10/kg
based on ARB's TCO document and other published sources (available
upon request). Such a price drop (from $10/kg to $5/kg) is unlikely
by 2030. We would recommend that CARB remove the assumption and
change the rule timing for long-haul trucks.

As we further hone our environmental standards, we would like to
see minimum performance standards for BE and H2 trucks, just as
fuel efficiency standards have been set for other vehicles in the
past. California has lofty climate goals, and the State has been
the leader in green technology. We appreciate CARB's efforts in the
rulemaking process and ask the Board to consider these comments on
the need to consider H2 fuel cell technology for long-haul drayage
trucks. I appreciate your attention on this matter, and we look
forward to working with you to achieve a greener California.

Sincerely,



Henry Rogers
Executive Director
Harbor Association of Industry & Commerce

Original File Name: HAIC ACF Comments.pdf

Date and Time Comment Was Submitted: 2021-09-27 21:18:26