Recent media coverage by the Sacramento Bee and CalMatters quotes CSDA and our serious concerns with the ACF as proposed.
The biggest concern with the draft rule is its timeline. With some exceptions, it requires cities, counties and special districts to ensure 50 percent of specified vehicle purchases are zero-emission by 2024, and 100 percent by 2027. No one is arguing the environmental benefits of the proposal, but the timeline is simply impossible. The vehicles and the infrastructure simply don’t exist.
Cities, counties, and special districts throughout California use fleets of medium and light duty vehicles to provide essential public services to millions of Californians daily. These are vehicles for services like delivering water, clearing snow, medical response, wilderness rescue and public safety. They need to be available at a moment’s notice, and they need to be in service even during a power outage – which is often the case in an emergency.
ZEVs that perform these essential operations do not exist today. Numerous class 2b and 3 vehicles are “available”, but can’t deliver the necessary specifications to meet agency needs. If CARB cannot amend its timeline, then wherever ZEVs are unable to meet public fleets’ unique needs, including operating extended hours, in all weather, elevation, off-roading, and natural disaster conditions, vehicles should be automatically exempt from the regulation.
Another concern is infrastructure. CARB must think through how, and where, agencies are going to charge these vehicles. We’re talking about substantial investments in infrastructure that will all be impacted by permitting, environmental review (CEQA) and global supply chain challenges. Even the most optimistic estimates from utilities suggest this infrastructure will take 2-3 years, far beyond the proposed 2024 deadline.
Then there are the real-world grid reliability concerns. Insufficient electrical service is already a real challenge. Public safety power shutoffs and rolling blackouts would render essential vehicles unchargeable at best, and inoperable at worst. The potential that public agencies may be unable to charge fleet vehicles is unacceptable as it jeopardizes the ability to fulfill essential public health and safety responsibilities.
Finally, the draft regulation gives scant attention to cost, or where the money will come from to meet these requirements. These are public agencies – their only source of revenue is the public’s dollars. Costs for compliance include more than just the costs of vehicles. They include costs for the needed infrastructure – including space and electricity access for charging stations, associated costs for planning and construction as well as training a workforce to maintain the vehicles.
Individual agencies that have investigated compliance costs report millions of dollars in anticipated expenses, for which there is currently no funding source. Multiply that by thousands of agencies throughout California and the scope and scale of this investment far outpaces existing revenue sources.
The ACF must be subjected to further scrutiny and discussion with affected stakeholders so it can be implemented effectively and help the state achieve its zero-emission goals.
Rather than an unrealistic deadline, CARB should continue to work directly with affected stakeholders to better understand real-world challenges before approving a final rule.
Otherwise, putting lives and property at risk for an unattainable timeline will only hamper the cause of adapting communities to our climate while ensuring the well-being of those we serve.
CSDA, together with our partners in local government, is in attendance at today’s CARB meeting and will deliver public comments on behalf of the more than 1,000 independent special districts we represent.
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