Submission Number: 433
Submission ID: 6891
Submission UUID: 077d1040-5fcd-454e-9683-8567a59fb115

Created: Mon, 11/20/2023 - 13:01
Completed: Mon, 11/20/2023 - 13:01
Changed: Mon, 11/20/2023 - 13:03

Remote IP address: 73.90.201.177
Submitted by: Anonymous
Language: English

Is draft: No

Flagged: Yes


Submitted Comment
Richard Teebay
N/A
Today's Workshop

Mike and Anna,

Thanks for today's workshop. And thanks for all your efforts on this proposal.

I do think that Idling and PTO usage can be significant sources of emissions - think aerial (bucket) trucks, tow trucks, security patrol vehicles, etc. (And especially police patrol cars which are exempt VC 165).

For light duty, perhaps provide some credit if manufacturers electrify AC as opposed to belt driven AC as they have power steering. I would require that the manufacturers provide data to support or suspend the credit going forward.

As I read the regulation, it applies to Medium Duty trucks up to 14,000 lbs. GVWR. For those vocations with significant PTO operations, such as aerial trucks, consider credit for solutions like the Odyne PTO option. Stationary operations can use a lot of fuel. Minimizing fuel consumption reduces emissions including GHGs. Again, DATA will be key to extending credit. I believe that 20% to 25% of an investor-owned utility's fleet would currently be excluded from the Fleet Regulation (ACT) for "emergency response" such as wildfires, etc. This should include a significant number of the utility's aerial trucks. Please consider using these exempted vehicles to pilot and gather data.

Thanks again for your significant efforts for California and beyond.

Rick Teebay

N/A