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I know it is supposed to be mundane, but I think the zero emission heavy vehicle question is fascinating because it is so impactful, so relatable for most people (unlike utility scale batteries and reconductoring), and it has been considered one of the "hard to abate" sectors that might make sense for hydrogen. I feel hydrogen is over-hyped by governments that are listening too carefully to fossil fuel lobbies, and so it was refreshing to have at least 2 experts in the field nixing hydrogen in favor of batteries. One model they did not discuss, maybe because it's lame, is the idea of swapping batteries rather than charging in real time. I would like to hear more about electric busing and trucking success stories, maybe from more advanced countries like China and Chile.

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Question: this episode on electrifying big trucks says at about 54:30 that “Which means you can charge these long haul trucks with 300 miles of range in 30 minutes.” I’m confused as to whether this is referring to “long haul” trucks or drayage trucks. A quick search of the Google machine says that long haul diesel trucks can get between 1300 and 1800 miles on a tank of diesel. It is amazing to charge a class 8 truck in 30 minutes but I’m left wondering if 300 miles of range can truly be called “long haul.” Any thoughts or data to help me here?

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I think a long haul driver is going to have *real* range anxiety with the current situation. This ideal trip, where you start with 500 miles of range, and add an additional 300 miles with a 30 minute charge is just very far from reality, and is not coming soon. Drivers make a lot of adjustments on the fly, and adding stops at specialized chargers, with no wait time just seems like a fantasy to me.

On the other hand, I'm skeptical that 1200, 1300, 1800 mile ranges are necessary. I know of a team that drives back-to-back shifts, and they average 625 miles per shift. Both shifts have mandatory 30 minute breaks. In the grand scheme of things, the weight of all that diesel isn't significant, but it doesn't seem like a big ask to get them to refuel/recharge during a trip. So, this idea that 1300 miles of range is a "must-have"? C'mon man.

Unfortunately, I think we're going to have diesel for a long time, for long-haul. Maybe there's a period of hybrids to comply with urban pollution regulations, or some way to charge on-the-fly that emerges, in the meantime.

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Thank you - those are some interesting points. Especially the idea that having full range of 1200+ miles is not realistic taking into account required breaks. I mean when was the last time I ever drove over 300 miles wo a break. Never. Hats off to long haul drivers. I can’t imagine driving that far all at once.

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I didn't mean to direct the "C'mon man" at you, personally. 😄

I'm sure there are drivers that can never have enough range!

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Fully electric drayage trucking makes so much sense. What if the government (federal, state) paid for the fleet of electric trucks for the ports and leased them to operators. Just like an investment in cargo cranes at the port, the government could support the ports in buying a fleet of electric drayage trucks that operators could lease. Maybe that is politically naive? Just seems like a pretty high bang for relatively low bucks from a federal budget perspective. Compare to the $2 trillion dollar F-35 fighter jet budget for example. Seattle drayage trucks could be fully electrified for 1/1000 of that.

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Thanks for your valuable service. I incorporated some of what I learned here in the comments I sent to my Washington State Senator.

Thank you for supporting SB 5811 in the 2020 legislative session. SB 5811 was passed, and it adopted The California zero-emissions-vehicle mandate for cars and trucks.

I’ve been attending the regular meetings of Commerce’s Alternative Fueled Vehicles Technical Advisory Group for 3 years regarding electric trucks and buses.

In those meetings, I soon came to realize that the most important provision of 5811 was the California Advanced Clean Trucks rule. (The cars are electrifying ahead of schedule and the ZEV Mandate hasn’t even taken effect yet. )

It has come to my attention that the fossil fuel industry has used mis-information to alarm the trucking industry, and the Trucking Industry in turn is looking for legislation to delay and weaken the Advanced Clean Trucks rule.

I urge you to do everything possible to keep the Advanced Clean Trucks Rule full strength and on schedule.

Of course there will be challenges that need to be solved, but the best way to solve them is to start out small, one step at a time. That’s what the Advanced Clean Trucks Rule does.

I’ve recently heard reports that the people living near the Port of Seattle die 13 years earlier than folk living in Northgate, because of air pollution. Anecdotally, Don Orange and I were driving though the neighborhood surrounding the Port of Portland in the St. Johns’ neighborhood, when he casually said, “people don’t live very long in this neighborhood”.

Protecting the Advanced Clean Trucks rule is a top priority of the Sierra Club.

Another top Club priority was to prevent diversion of Climate Commitment Act funds for other budget needs.

If the trucking industry approaches you seeking delay, please reach out to me for the rest of the story.

Don Steinke

Page 2, Supplemental context:

I attended an informal rule making hearing yesterday sponsored by the Department of Ecology.

I began my comment by saying, I support full adoption, without delay, of the California emissions standards such as the standards that apply to heavy duty trucks. I also support the use of public funds and policies to help the industry reach economies of scale and reach price parity.

So does China. They sold 65,000 medium and heavy-duty electric trucks in all of 2022, and sold the same amount in just the first half of 2024. Why are they subsidizing electric trucks? Because the pollution from trucks harms both health and climate.

During the hearing I heard concerns brought up, concerns based on mis-information.

I’ve addressed those concerns below.

Regarding the high upfront cost:

Conventional banks can’t support leasing programs for electric drayage trucks because they don’t know what the residual value of the truck will be. For that reason, Congress has established a Green Bank to purchase 500 electric drayage trucks and offer them for 4-year leases. That will give the banks enough data to continue the program.

Regarding Charging Infrastructure

Truckers need a place to park and charge their truck batteries. The company called Forum Mobility is busy acquiring land near surplus grid capacity and near drayage truck routes for truck charging stations. They have their eye on the Seattle Tacoma Market, as well as the Portland Vancouver Market.

Four years ago, Southern California Edison announced plans to invest $350 million in truck charging stations. The world’s largest warehouse company Prologis as well as the South Coast Air Resources board have each built facilities capable to charging more than 95 trucks at a time.

It's not necessary to build everything everywhere all at once. And it’s not necessary to have a full build-out on day one. Go after the low hanging fruit first, one step at a time. Some of the first ZEV trucks maybe be able to charge at the loading dock.

Delivery trucks are low hanging fruit. Amazon already has 15,000 electric delivery vans on the road with 300 in Seattle. Next step up might be drayage -- big rigs hauling shipping containers from Ports to Warehouses within 100 miles. I support full adoption, without delay, of the California emissions standards such as the standards that apply to heavy duty trucks.

Regarding availability of suitable vehicles:

As I understand, the phase in period for this program is 20 years. There is no need to worry now about snowplows and forest fire-fighting equipment. The Advanced Clean Trucks rule will allow the sale of conventional equipment for many years to come. Such equipment if bought in 2039 could last for 20 years more. The price of batteries will continue to fall as the market develops and adding two auxiliary batteries to a snow-plow may make sense. Plug-in hybrids do earn partial credit and may be a good alternative.

If it turns out that there is no solution for the application, seek a waiver to allow biofuels.

Regarding pass-through costs:

The voters of Washington have spoken by a 24% margin in support of spending programs to accelerate the transition to a clean energy economy.

Regarding protecting our competitive advantage:

Ford’s CEO Farley says that China’s EV manufacturing industry is an existential threat. China copied California ZEV mandate and set more ambitious targets. Now China has about 200,000 zero-emissions heavy duty trucks on the road. That’s because they supported that industry. We need to support the competitiveness of our truck manufacturers by incubating the market here.

Regarding impacts to State agency budgets:

I believe that most of the State Funding for agency acquisition of clean trucks will come from the Climate Commitment Act which was supported by our voters 5 weeks ago by a 24% margin. Our CCA provides about $1 billion per year for clean energy projects. In addition, the Federal Inflation Reduction Act has authorized about $1 trillion over the next ten years for clean energy projects. The Trump administration may try to reverse those authorizations but Congress controls the purse.

Re—the lack of infrastructure

Consider working with your local electric utility to seek grants. Our CCA provides about $1 billion per year for clean energy projects. The Federal Inflation Reduction Act has authorized about $1 trillion over the next ten years for clean energy project. The Trump administration may try to reverse those authorizations but Congress controls the purse.

Regarding Total Cost of Ownership

In order to achieve parity in total cost of ownership, we need to support the growth of the industry. That’s what the Advanced Clean Trucks rule is doing. The Federal Green Bank Program called Climate United will help. It is purchasing 500 electric semis, and will be offering them for four-year leases. At the end of four years, those truck will be available on the secondary market and the banking community will have enough data to establish a residual value and their own leasing program for new ZEV trucks.

Regarding the potential of forcing small business owners to go out of business.

There will always be demand for plumbing, roofing, and painting contractors. By adopting the Advanced Clean Trucks Program, we will help achieve total cost of ownership price parity between conventional and zero emissions vehicles.

There is no requirement that anyone purchase an electric vehicle. Contractors will (depending on weight class) be able to buy a new truck in 2039 and drive it for the rest of their life and then sell it in the used truck market.

The most cost-effective way to extend the life of people living near transportation corridors is to reduce emissions, particularly diesel emissions.

According to the EPA in 2019, each dollar spent reducing tailpipe emissions yielded at least $10 saving in health care costs.

I agree with the organization Coltura which advocates that EV incentives should go first to super users, those that drive a lot such as contractors and farmers.

Regarding long-haul trucks, power supply

18-wheelers that carry containers from Ports to warehouses less than 100 miles away, are low hanging fruit.

The Organization called Forum Mobility is acquiring land on drayage truck-routes for charging stations.

Forum Mobility also plans to offer lease programs for 18 wheelers.

We don’t need to have a full build-out on day one.

The Tesla Semi is intended for long haul trucking.

Conclusion

I support full adoption, without delay, of the California emissions standards such as the standards that apply to heavy duty trucks.

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I am very hopeful, but I have to say I think they may be overly optimistic. As far as I can tell the total cost of ownership is usually referring to purchase price and fuel, but repair costs are also a huge part of commercial trucking. I suppose that's another area where data points are needed. Plus there is the weight issue; a few thousand pounds of batteries can make the difference between profit and loss for some applications. There's a reason Tesla is testing its trucks with Frito-Lay. I wonder if any state allows increased weights for electric trucks to accomodate the batteries- there is a small weight allowance for trucks with APUs and that's justified by the environmental benefits.

As far as I can tell, there isn't a long haul (OTR) truck with a sleeper available for sale in the US, because it just doesn't make financial sense (yet). I'd be interested to hear somebody discuss the referenced willingness of truck makers to sell electric trucks, or whether it's just a marketing exercise. Looking at Truck Paper, there are currently ~20K day cab trucks for sale with ICE engines, and 35 electric.

On the plus side, and in the longer term, hopefully the very fast charging will be a major benefit once widely deployed- most long haul drivers can drive a maximum of 11 hours per day but have to take a 30 minute break. That means most drive in the 600-ish mile range per day, and if you could get a 300-350 mile charge in 30 minutes, that would fit within the current hours of regulation- one daytime charge and one at night.

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Washington State has adopted the Advanced California Clean Trucks Rule, but not yet the Clean Fleets Rule.

In my public comment to them, I suggested they consider doing so.

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