CleanFleets.net Proposal
November 4, 2024
RESPONSE TO REQUEST FOR PROPOSAL TO
PROVIDE PROFESSIONAL VEHICLE/EMISSIONS
CONSULTING SERVICES
November 4, 2024
Prepared for:
City of Anaheim
Department of Public Works
Fleet Section
Prepared by:
1822 21st Street
Sacramento, CA 95811
(916) 520-6040 Ext 104
CleanFleets.net Proposal
November 4, 2024
November 4, 2024
City of Anaheim Department of Public Works-Fleet Section Attn: Cindy Suh, P/T Staff Analyst
955 S Melrose Street
Anaheim CA 92805.
Re: PROFESSIONAL VEHICLE/EMISSION CONSULTING SERVICES
Dear Ms. Suh:
CleanFleets.net LLC (referred to herein as “CleanFleets”) transmits this response to the City’s request for proposal for professional services. The qualifications shown in this document provide the City with the highest degree of confidence that we will competently and successfully implement the Scope of Work if we are selected. As you review the attached information, please consider that CleanFleets is the only service provider that can offer the City:
Twenty-five years of continuous experience in diesel fleet rules regulatory development and implementation for over 300 diesel private and public agency truck and equipment fleet owners; and,
Service to the City’s OMFSD for the services contemplated since 2017; and, An adviser on annual basis to other cities, to the City’s primary communications provider (AT&T) and the City’s primary waste hauler (Republic Services); and, An adviser to more than 50 fleet operators impacted by South Coast AQMD’s clean vehicle fleet rules; and,
Selected three times by the California Air Resources Board (CARB) as their technical expert to manage grant funding and as an instructor to train fleets concerning diesel and greenhouse gas regulations; and,
Developer of our proprietary Fleet Management System (FMS) software that enables us to manage CARB-required records and accomplish regulatory reporting across all CARB vehicle regulations for over 15,000 mobile assets; and, Field services including compliance inspections and testing for the new Clean Truck Check (CTC) requirements.
I may be reached at 916-718-7050 with any questions.
Sincerely,
Sean R. Edgar
Director & Account Manager
CleanFleets.net Proposal
November 4, 2024
A. Firm Overview
CleanFleets proposes to provide all services requested in this Request for Proposals (RFP). It was formed in 2007 as a partnership between EnvironStrategy Consultants of Irvine and Clean Fleets & Fuels Group of Sacramento. Director Sean Edgar purchased all shares in 2010.
Size of the firm: 4
Summary of its corporate organization: Limited liability company (LLC) with “SCorp” designation
Location and size of corporate headquarters: The company has leased 1,000 square feet at 1822 21st Street, Sacramento CA 95811 since 2007. This office is located within two miles of the CARB Headquarters (Cal-EPA Building) and the State Capitol and will have the primary responsibility for the execution of services. Travel expenses for meetings with CARB, South Coast Air Quality Management District (AQMD) or the City are included in the hourly rates proposed and there will be no additional transportation, lodging or similar expenses charged without the express written consent of the City.
The Account Manager is Sean Edgar. His contact information is:
Office Phone: (916) 520-6040 Ext 104.
Cell Phone: (916) 718-7050
Email address: [email protected]
Office address: 1822 21st Street, Sacramento CA 95811
B. Understanding of the Scope of Work
The following narrative is our understanding of the services required by the City. It is presented using the same numbering system as the RFP document. The accompanying Cost Estimate provides details for each element of the Scope. We bring extensive expertise, knowledge, and know-how to each of the tasks listed in the worktable. The RFP text appears in italics and our replies in normal typeface.
1. Meet with City Representative(s) at beginning of task to review list of vehicles/equipment.
We reviewed the Exhibit B spreadsheet of all mobile assets owned by the City and we find no surprises, however we will come to our first meeting with a list of upcoming CARB deadlines for all diesel and propane vehicles as well as procurement tips for the City to consider before the ACF ban on internal combustion vehicle purchases goes into effect on 1/1/2027.
The initial meeting should be in person at the City’s offices as that would lend itself to being more productive than a virtual meeting. For the term of the proposed contract, we propose quarterly meetings with the City in a hybrid format where two are in person and two are virtual meetings. This arrangement worked well in 2023.
Our account manager returns calls from the City within 24 hours. From prior work we have a solid grasp of over 1,000 mobile assets owned by the City. The Clean Truck Check (CTC) Regulation requires the City to attest to its CleanFleets.net Proposal
November 4, 2024
compliance in January 2025. The In-use Offroad Diesel Vehicle Regulation requires annual certification by March 1, 2025 and the Advanced Clean Fleets (ACF) Regulation will require City to certify compliance by April 1, 2025. Through our ongoing work for over 200 fleets we are up to speed on the current zero emission vehicle (ZEV) capabilities and will rank ZEV options for the City. Our firm has obtained specialized training from the California Council on Diesel Education and Technology (CCDET) and other sources to identify applicable regulations affecting internal combustion engines
2. Conduct a comprehensive evaluation of current state of emissions compliance for the listed vehicles and equipment, documenting any deficiencies or non- compliance issues and notifying City Representative(s).
Director Sean Edgar was appointed by CARB to its Truck Regulations Implementation Group (TRIG) and has 25 years of experience with CARB and South Coast AQMD fleet rules and was selected three times by CARB as their expert to train public agencies and privately owned onroad, offroad and portable diesel engine owners and also to administer CARB grant funds.
CleanFleets will perform physical inspection of vehicles at the Technician rate quoted should the City-supplied data not contain the required parameters to complete an evaluation.
CleanFleets has responded on behalf of our clients to more than 50 audit requests from the California Air Resources Board (CARB) and are familiar with their expectations.
We will review: CARB CTC data exports supplied by the City, prior year ACF and Public Agency & Utility Fleet Regulation required records, Offroad/DOORS system access and analysis, prior year portable engine/PERP filing, South Coast AQMD permits and any supplemental data supplied by the City. CleanFleets has performed these tasks for the public agencies listed as references and more than 200 private fleet operators
CleanFleets has field personnel and analytical staff to obtain or validate data and has done so for over 15,000 diesel, gasoline and natural gas vehicles.
3. Present an action plan to bring any vehicles/equipment that are not currently in compliance into compliance.
CleanFleets will produce a matrix and narrative of findings from the prior work items CleanFleets is extremely familiar with state and local air quality regulations and also can obtain clarification in writing from the regulatory agencies when required Director Sean Edgar is a regular presenter and attendee of CARB and Air District workshops and has participated in every major onroad and offroad regulation development for more than 25 years
4. Monitor, on an on-going basis, the City’s fleet and advise City Representative(s) of emissions compliance status when fleet mix and size changes (vehicle/equipment additions, deletions, etc.)
CleanFleets will ask the City to supply a monthly report on fleet additions and deletions and perform the data entry as required to CARB’s databases and prepare CleanFleets.net Proposal
November 4, 2024
the required disclosures that the City is obligated to make when selling specific diesel assets.
5. Monitor all applicable rules, regulations, and laws regarding emissions compliance related to the City’s fleet and advise City Representative(s) of any changes in current rules, regulations, and laws, as well as any new or proposed/adopted new rules, regulations, and laws that would impact the City’s fleet.
From our principal office in Sacramento, CleanFleets will review all monthly agendas of CARB and the South Coast AQMD and monitor and report on impacts to the City assets which are the scope of this proposal.
Director Sean Edgar has testified at CARB on regulatory proposals or adoption hearings on more than 50 occasions over the past 20 years. CleanFleets performs this service for the public agencies listed in References. CleanFleets is affiliated with the following vehicle owner associations and routinely writes articles to keep members abreast of CARB and AQMD rule changes. Among the associations are: Associated General Contractors, San Diego Chapter; California Beer & Beverage Distributors; California Moving & Storage Association; California Construction and Industrial Materials Association; California Fuels and Convenience Alliance; Construction Industry Air Quality Coalition; and Western States Trucking Association. See a recent article relating to ACF and emergency service providers in the Attachments.
6. Provide assistance with data gathering and compilation for reporting purposes, both internally and for submission to regulatory agencies.
This is performed on as needed basis at the hourly rates supplied We have inspected more than 15,000 vehicles over the past decade and audited fleet record supplied by over 200 clients.
We have a proven track record of timely regulatory filings in the CARB DOORS, DOORS-LSI, TRUCRS and CTC systems over the past seven years with no late fees or emissions penalties paid by the City.
Our Fleet Management System (FMS) houses all relevant fleet data including vehicle and reporting documentation.
7. Prepare annual and on-demand reports of City fleet vehicle/equipment compliance.
This is performed on as needed basis at the hourly rates supplied. We have a proven track record of timely regulatory filings in the CARB DOORS and DOORS-LSI systems over the past seven years.
CleanFleets comes to each quarterly meeting with the City with the current reporting system data and compliance calculations.
Requests for data between quarterly meetings are supplied promptly.
CleanFleets.net Proposal
November 4, 2024
8. Prepare annual and on-demand reports of City Fleet vehicle/equipment compliance.
Please see our reply to this same question in #6 above.
9. Submit all CARB program reports to all applicable agencies.
This is performed on as needed basis at the hourly rates supplied The annual reports in #7 above are readily available and can promptly be submitted to other agencies when directed by the City.
10. Our response is divided into a. and b. to recognize duplication of numeral 10 in RFP text
a. Complete and submit all necessary ZEV purchase
exemptions/applications. This includes as needed resubmission(s). i. This is performed on as needed basis at the hourly rates supplied ii. CARB has made the criteria for exemptions or extensions very rigorous and we do not see that this will have much of a role in the City’s ACF compliance strategy.
b. Assist with the Portable ATCM compliance, permitting and renewal process. This is for the PERP Registration for initial application and renewals (CARB or the local Air District/SCAQMD).
i. This is performed on as needed basis at the hourly rates supplied ii. We have assisted the City on a limited basis in the past and are familiar with both the CARB and AQMD staff managing this. iii. Recommendation: Because PERP permits have different expiration dates and may not have a common designated person at the City to receive renewal or data notices sent via US Mail, we recommend that the City designate a single individual or position name to which CleanFleets can ask CARB to send all correspondence. Clean Fleets requests a current inventory of PERP registered units from the City so we can add to a master calendar of upcoming renewals or upgrade deadlines during the future contract term.
11. Labeling of Vehicles (to meet CARB and/or SCAQMD Requirements)
Labeling is produced to specifications required by CARB regulations for $20 each label when requested by the City.
12. Inspections (to meet CARB and/or SCAQMD Requirements)
Inspections are conducted at the $150 per hour Technician rate when authorized by the City.
We have inspected more than 15,000 vehicles over the past decade
CleanFleets.net Proposal
November 4, 2024
13. Conduct Periodic Smoke Inspection Program Emission testing and field inspections.
CTC vehicle testing by CARB-credentialed technicians is $180 per test when when authorized by the City. Note: We will ensure that where our Testers complete testing that the data is reflected in the CARB CTC-VIS reporting system at no additional cost to the City.
14.Conduct diesel particulate filter cleaning services.
Until 2020 our firm conducted this service in our Los Angeles County office however we discontinued that service. We maintain a list of vendors in Los Angeles and Orange counties that we can provide to the City upon request.
15.Coordinate with the City Representative and its contractors to research, assess, and complete grant applications and other funding for low-emission vehicles, ZEV, equipment, and infrastructure (including charging) when requested by the City.
We monitor all monthly CARB and AQMD meetings to learn of new regulations and grant opportunities
We are currently providing grant support for Anaheim Disposal/Republic Services across several CARB and South Coast AQMD grant programs; We currently are managing two Volkswagen Mitigation Fund grants. Both were submitted within the last three months and we are working positively with AQMD staff to resolve remaining concerns and get to the contract phase very shortly. The AQMD staff person on these grants is:
o Jessie J. Conaway, Staff Specialist, Technology Advancement Office, South Coast AQMD, Email: [email protected], Telephone (909) 396 3143
16.Procedure for CARB Advanced Clean Trucks Regulatory Process – to include technology limitations.
We have participated in nearly all CARB workshops and public hearings since the zero emission vehicle program was formalize in 2016 under the name Last Mile Delivery;
We have watched from the front lines the expansion to all truck types and all public agencies;
We are very familiar with the CARB implementation process for AB 1594 (Garcia); Through the TRIG meetings we regularly review and debate the number of extensions and exemptions under ACF. We are closely watching the AB 1594 (Garcia) implementation by CARB that is likely to provide some relief to the City’s electricity and water service trucks. Draft language is currently being circulated by CARB staff and we are anxious to begin advising the City again on finding the least net-cost way to continue to provide reliable public services under the ACF ZEV purchase mandate. You will see in the next section the references for whom we are providing this same service.
CleanFleets.net Proposal
November 4, 2024
C. Project Team
Below is the organizational chart for the term of the contract. All members have been employed by us and have worked on prior tasks for the City for more than five years.
The City will be promptly notified of any changes in key personnel prior to award.
Resumes of key personnel and certifications are located in the Attachments.
Figure 1
Organization Chart
The table below presents position title and job descriptions for each key person.
Table 1 Key Personnel & Project Assignments
Key
Personnel Title Project Roles (all staff based in Sacramento Office) Sean
Edgar
Director &
Account
Manager
Sean provides overall project management and
communication with the City. Sean has directed the past work for the City since 2017. Additionally he has compiled responses to CARB for more than 30 fleet audits and is
considered an expert by CARB and multiple vocational
associations of truck owners and contractors. His CARB
Clean Truck Check Credential and CCDET training
certifications appear in the attachments.
Jared
Yamasaki
Project
Manager
Jared provides data analysis, interpretation and
compliance reporting. He has performed this function for past work for the City since 2017 and has more than 20
major fleet audits over the past five years under his belt.
Gabriela
Lopez
Admin
Support
Gabby provides office tasks from reproduction of reports to the City to billing support.
City of Anaheim Representative
Sean EdgarDirector &Account Manager
Jared YamasakiProject Manager
Gabriela LopezAdmin Support
CleanFleets.net Proposal
November 4, 2024
C1. Capabilities
Our firm plans to use the same staff used for at least the past five years to provide the service(s)/tasks authorized during the initial two-year contract duration. Based on past performance we believe that this will be adequate for the proposed work. Should we need additional personnel we will hire them and inform the City.
D. Relevant Experience of the Team:
This section describes our experience providing services in the discipline/subdisciplines required. The numbering corresponds to Section D on Page 6 of the RFP. The RFP language is in italics and our responses in normal typeface.
D1. Demonstrate its understanding of the range of projects and objectives for specific tasks. D2. Demonstrate technical expertise to provide services as defined in the Scope of Services.
Section B provides greater detail on our approach and ability to manage the proposed work. The fact that we have served the City in this capacity since 2017 with no regulatory fines or negative findings speaks volumes about our ability to serve the City under a new Agreement.
We will interface with City staff through meeting requests for times that suit the City. We proposed at least two quarterly meetings in person and two done virtually. We will interface with regulatory agencies by reviewing their published agenda and regular contact to understand what new proposals may emerge.
We regularly prepare necessary applications, reports and grant applications by: 1) determining the basis for the report or eligibility for the grant; 2) summarize data or documentation that is needed and set reasonable deadlines for our City partners or regulatory agencies to supply; 3) provide prompt follow up and follow through to ensure that the work product is of the highest quality for the intended use.
We present recommendations after our thorough understanding of the facts and in a collaborative manner. Should vehicles or equipment be determined to be out of compliance we will provide the City in writing with the range of options to bring that equipment back into compliance. We have successfully negotiated compliance settlements with CARB and AQMD for over 15 years and can provide advice on how best to approach them if required or advisable.
Our extensive experience dates to the late 1990’s when the South Coast AQMD began to approve its natural gas fleet rules. CARB subsequently passed its Diesel Risk Reduction Plan in 2000 and Director Sean Edgar has advised dozens of public agencies and hundreds of private fleet owners on compliance strategies. CARB’s determination of our technical expertise is found in their 2012 and 2015 letters about our firm’s selection (see Attachments).
We have experience in managing client data in every vehicle online reporting system that CARB has established over the past 15 years. CARB unveiled its Diesel Offroad CleanFleets.net Proposal
November 4, 2024
Online Reporting System (DOORS) around 2008. That was followed by the Truck Regulations Upload Compliance and Reporting System (TRUCRS) in 2011. Other reporting systems like DOORS-Large Spark Ignition, ARBER, DTR and now CTC have evolved over time. We file hundreds of annual reports each year on behalf of our clients, including the City’s Clean Truck Check and Advanced Clean Fleets initial reports. In terms of ZEV applications, we routinely file grant applications under the AQMD’s VW Mitigation Funding program, including two major projects in the past 90 days.
Our method of data gathering involves detailed analysis of documents, spreadsheets or photos supplied by others. When those are not conclusive, we recommend that our field staff conduct physical audits, as we did at the Anaheim Convention Center on the propane forklifts there in advance of a reporting deadline.
We have know-how in researching grants and as mentioned we routinely apply on behalf of our clients, including the City. The first example is the CARB Hybrid Voucher Incentive Program (HVIP). These grants are truck dealer-based so in the past we have encouraged the City’s procurement team to ensure that the quoted vendor price reflects the available CARB rebates. Second, the current VW Mitigation Funding is open to fleets that scrap heavy duty trucks and replace them with ZEVs. Since 2023 we have assisted Anaheim Disposal (Republic Services) with grant support to inspect and provide detailed photographic and maintenance records that qualify the vehicle for grants. This has resulted in dozens of the ZEVs that the waste hauler is deploying in the City to have reduced costs on the City’s ratepayers. In terms of infrastructure “including charging” it is regrettable that Sacramento has not provided the necessary funds for the City’s Utilities Department to pay for the City’s or customer’s charging infrastructure. For example, SoCal Edison and other investor-owned utilities access Senate Bill 350 funds to build electric infrastructure to the meter of the fleet end user. We are monitoring the federal Inflation Reduction Act funding coming to California and Caltrans will have a major role in distribution. Our concern is that it will not be dedicate to community-based charging as needed in Anaheim. CARB’s ACF is among the biggest unfunded mandates ever from Sacramento on the City. We will redouble our efforts in this area should we be selected again by the City.
Our forms of communication have been regular emails, calls, Zoom meetings and in- person meetings at the City offices. Those may occur as CARB or AQMD make announcements of workshops or hearings and are summarized on a quarterly basis along with review the status of the various CARB reporting systems. As a sample of a quarterly report, see the Attachments for ” CARB & SCAQMD Issues” dated May 4, 2023.
As complementary or additional services, CleanFleets is capable of performing any tasks using our skill set at the hourly rates quoted. Mike Hogan in Fleet Maintenance indicated that he has trained staff to complete the Clean Truck Check testing. Our staff is also available to conduct that if requested by the City.
CleanFleets.net Proposal
November 4, 2024
D3. List at least three (3) relevant projects or similar contract pursuits. Include owner/agency information, contact information, consultant fee, type of services/tasks provided, and identify any personnel proposed in Section C of this RFP.
Below are four references (three public and one private) for whom comparable services were provided in the last five (5) years. Each will verify and confirm our responsiveness, relevant experience and professionalism.
City of Camarillo
John Thomas, Assistant Director of Administrative Services 601 Carmen Drive
Camarillo, CA 93010
(805) 383-5667
Email: [email protected]
CleanFleets Services (2009- present): In 2009, CleanFleets completed an audit of City’s diesel assets. Based on that initial audit we prepared required CARB records, performed regulatory reporting, assisted in diesel particulate filter procurement, prepared Ventura APCD portable engine applications, We provide ongoing CARB- related support to the City and in 2023-2024 assisted the City with its long-term compliance planning for the CARB Advanced Clean Fleets (ACF) requirements.
CleanFleets Team: Sean Edgar, Jared Yamasaki
Consultant Fee in 2024: $12,000 (est)
City of Mountain View
Antoinette Wilson, Fleet and Facilities Support
231 N. Whisman Avenue
Mountain View, CA 94043
(650) 903-6892
Email: [email protected]
CleanFleets Services (2008- present): In 2008, CleanFleets completed an audit of City diesel assets. Based on that initial audit we prepared required CARB records, performed regulatory reporting, assisted in diesel particulate filter procurement, prepared Bay Area AQMD portable engine applications and presently we provide ongoing CARB-related support to the City. We provide ongoing CARB-related support to the City and in 2021-2024 assisted the City with its Advanced CleanTruck (ACT) initial report and ongoing ACF procurement strategy.
CleanFleets Team: Sean Edgar, Jared Yamasaki
Consultant Fee in 2024: $6,000 (est)
Central Contra Costa Sanitary District
Robert Hess, P.E., Associate Engineer
5019 Imhoff Place
Martinez, CA 94553
(925) 229-7242
Email: [email protected]
CleanFleets.net Proposal
November 4, 2024
CleanFleets Services (2008- present): In 2008, CleanFleets completed an audit of District’s diesel assets. Based on that initial audit we prepared required CARB records, performed regulatory reporting, assisted in diesel particulate filter procurement and presently we provide annual CARB-related support to the District including emissions testing, regulatory records management and long-term compliance planning for the CARB Advanced Clean Fleets (ACF) requirements.
CleanFleets Team: Sean Edgar, Jared Yamasaki, Gabriela Lopez Consultant Fee in 2024: $15,000 (est)
Marie Kimball
AT&T Services Inc
Marie Kimball, Global Fleet Operations-Regulatory Compliance 2300 E Eight Mile Road
Stockton, CA 95210
(650)704-2266
Email: [email protected]
CleanFleets Services (2010- present): Since 2010, CleanFleets has performed field services supporting the Anaheim-based fleet as part or our three-year agreements for statewide CARB reporting and regulatory compliance assistance for the California fleet of more than 7,500 vehicles. Our most recent efforts have focused on ACF planning and implementation of the CARB Clean Truck Check emissions reporting and testing requirements.
CleanFleets Team: Sean Edgar, Jared Yamasaki, Gabriela Lopez Consultant Fee in 2024: exceeds $200,000
CleanFleets.net Proposal
November 4, 2024
Attachments
CleanFleets.net Proposal
November 4, 2024
Attachment
Fee Schedule
&
Consultant Personnel Information
CleanFleets.net E-Fee Schedule 11/5/2024
RFP TASKS Frequency Director
Hours
Director
Rate Subtotal
Project Manager
& Technician
Hours
Project
Manager &
Technician
Rate
Subtotal Total Optional Tasks
1. Meet with City Representative(s) at beginning of task to review list of vehicles/equipment. One-Time 4 $200.00 $800.00 4 $150.00 $600.00 $1,400.00
2. Conduct a comprehensive evaluation of the current
state of emissions compliance for the listed vehicles
and equipment, documenting any deficiencies or non-
compliance issues and notify the City Representative.
This includes the current and future California
Advanced Clean Fleets (ACF) program.
As Needed 10 $200.00 $2,000.00 10 $150.00 $1,500.00 $3,500.00
3. Present an action plan to bring any
vehicles/equipment that are not currently in compliance into compliance.
One-Time 1 $200.00 $200.00 1 $150.00 $150.00 $350.00
4. Monitor, on an on-going basis, the City’s fleet and
advise City Representative(s) of emissions compliance
status when fleet mix and size changes
(vehicle/equipment additions, deletions, etc.)
Monthly 4 $200.00 $800.00 2 $150.00 $300.00 $1,100.00
5. Monitor all applicable rules, regulations, and laws
regarding emissions compliance related to the City’s
fleet and advise City Representative(s) of any changes
in current rules, regulations, and laws, as well as any new or proposed/adopted new rules, regulations, and
laws that would impact the City’s fleet.
Monthly 6 $200.00 $1,200.00 2 $150.00 $300.00 $1,500.00
6. Provide assistance with data gathering and
compilation for reporting purposes, both internally and for submission to regulatory agencies.
As Needed 5 $200.00 $1,000.00 5 $150.00 $750.00 $1,750.00
7. Prepare annual and on-demand reports of City fleet
vehicle/equipment compliance. Annually 6 $200.00 $1,200.00 20 $150.00 $3,000.00 $4,200.00
8. Prepare annual and on-demand reports of City fleet
vehicle/equipment compliance. As Needed 6 $200.00 $1,200.00 10 $150.00 $1,500.00 $2,700.00 At hourly rates notes
9. Labeling As Needed $20.00/
each
10. Inspections As Needed $100.00/
each
11. Conduct periodic Smoke Inspection Program
Emission testing and field inspections As Needed $180.00/ each
12. Conduct diesel particulate filter cleaning services if requested As Needed $500.00/
each
Est by local
vendors
13. Coordinate with City Representative and its
contractors to assess and complete grant applications
for low emission vehicles, equipment and infrastructure when requested by the City.
As Needed
At rates in
section
14,15, 16 &
17 below
14. Director Hourly Cost N/A $200.00
15. Project Manager Hourly Cost N/A $150.00
16. Technician Hourly Cost N/A $150.00
17. Quarterly updates on any air quality regulations (in-person/zoom) Quarterly 4 $200.00 $800.00
OPTIONAL SERVICE-INFRASTRUCTURE As Needed $200.00 $150.00 As needed at
hourly rates
notes
RESUMES OF KEY PERSONNEL
Sean C. Robledo Edgar
Sean Edgar has more than twenty-five years of public policy development and field experience in transportation and air quality issues for clients in both the public and private sectors. Mr. Edgar gained experience in the public policy arena while serving in the Office of Governor Pete Wilson in the early 1990’s. There he participated in the formation of the California Environmental Protection Agency and performed research and policy formulation on topics such as military base closure, inland bay dredging, and toxics regulation.
Mr. Edgar’s work since 1995, on behalf of public and private sector clients, has focused on regulatory compliance and advocacy on waste transportation and air quality issues.
Mr. Edgar has had an established presence at the California Air Resources Control Board (CARB) since the September 2000 adoption of the Diesel Risk Reduction Plan (DRRP) and has participated in every major on-road and off-road rulemaking for more than ten years. Among his other accomplishments, Mr. Edgar represented the private solid waste collectors in the development and implementation of the CARB Solid Waste Collection Vehicle Rule, the first private carrier rule enacted under the CARB’s Year 2000 plan. He is a recognized expert and regular contributor to statewide panels regarding on-road fleet rule implementation and technology options.
In 2009 Mr. Edgar was appointed by CARB to their Truck Regulations Advisory Committee. In 2011 he was authorized by CARB through a competitive bid process to train business owners about CARB rules. In the past two years he has educated more than 5,000 fleet owners in six western states through over 150 personal appearances.
He is a recognized expert regarding on-road fleet rule implementation and technology options. In 2014, Mr. Edgar became an instructor at the University of California, Davis Extension. Since 2016 Mr. Edgar has been intimately involved in the CARB zero emission vehicle regulations and was selected by CARB to serve on their Truck Regulations Implementation Group in 2023.
Mr. Edgar is a member of (and trainer for) multiple vocational truck associations and holds a Bachelor of Arts degree in Political Science from the University of California at Berkeley. In 2006 he earned an Air Quality Management Certificate from California State University Fresno Extension and has completed substantial technical training and continuing education in the fields of environmental law and regulation, hazardous materials management, and occupational safety.
RESUMES OF KEY PERSONNEL
Jared Yamasaki
Jared Yamasaki has twenty years of experience in managing complex data in support of California’s air quality regulatory programs. As Project Manager, Mr. Yamasaki will perform the regulatory reporting and analyses required by the City.
CleanFleets.net 2011 - Present
Project Manager
Jared maintains fleet records and compliance options for the owners of more than 15,000 diesel vehicles. He researches, clarifies and helps fleet owners implement the various diesel regulations enforced by the California Air Resources Board, including but not limited to, the Statewide Truck and Bus Regulation, the In-Use Off-Road Regulation, and the Tractor-Trailer Greenhouse Gas Regulation. Additionally, he has helped clients analyze their fleets and plan out a comprehensive compliance schedule specific to each applicable regulation.
California Air Resources Board 2005 - 2011
Student Assistant
Jared managed the division’s budget of over $3,000,000; including tracking expenditures, forecasting, and creating monthly reports for management. One major highlight in this position was being able to save the division money by evaluating and amending contracts. Additionally, he has attended various training classes and workshops and have helped coordinate the Annual Cross-Media Enforcement Symposium.
Education
California State University, Sacramento (2010)
Bachelors of Science - Finance and International Business GPA: 3.58 and 3.48 respectively
Related Coursework
Fundamentals of Enforcement (FOE) and Visible Emissions Evaluation (VEE) – A basic overview of air pollution with an emphasis on visible emissions evaluation. Topics also include air pollution and its effects, meteorology, water vapor plumes, air pollution law, and air compliance inspection procedures and documentation.
CleanFleets.net Proposal
November 4, 2024
Attachment
Sample Reports
&
Articles
CARB & SCAQMD Issues
May 4, 2023
Issue Analysis
Diesel, CNG
and Propane
Mobile Asset
Reporting
• Propane Forklifts: Report to be filed before
6/30/23. Compliance System reads, “Your forklift
fleet, as currently reported, has met the Large
Spark-Ignition Regulation Fleet Average
Emission Level requirements.”
• Diesel Off-road annual document “ROAR” was
filed on time: “Your fleet, as currently reported,
has met the off-road regulation performance
requirements through the January 1, 2027
compliance date.” Any additions or deletions?
• Portable: Alert Clean Fleets of any renewals
received by the City.
ZEV/ACF
Process
• CARB passed the Regulation on 4/28/23, press
release is attached
• From 1/1/2024 onward, 50% of vehicles added
must be battery electric (BEV) or hydrogen
(>8,500 lbs GVWR "F250" pickup size and up)
• Increases to 100% from 1/1/2027 onward
• League of Cities “carve out” article is misleading
(attached)
• SCPPA/CMUA testimony was great and filed a
46 pages analysis of the problems
1 • "Near-zero" does not include RNG fueled
• Inadequate state funding and exemptions
• Need input from Utilities on infrastructure
challenges and review of AB 1594 by CMUA
that pursues a legislative fix
• Discussion of how to plan for implementation
1 https://www.arb.ca.gov/lists/com-attach/824-acf2022-UTsBaFM7VWhXJVAP.pdf
SB 210
Implementati
on/Heavy
Duty I/M
(now called
“Clean Truck
Check” by
CARB
• CleanFleets has staffed all recent committee
meetings relating to new smog check and has
credentialed testers and equipment
• Reporting by the City expected July to
December 2023 emissions reporting process.
CleanFleets will identify the data points
immediately upon release of the reporting
system.
• Twice per year testing on all diesel and natural
gas vehicles >14,000 lbs GVWR in 2024
• This is an existing line item in CleanFleets
contract with the City but pricing will need to be
updated.
lnilTTONNEIYS
Legislative Update
p.4
Time to Retire
p.7
California Energy
Commission "Dreamland"
p.16
"Ghosting" Your US DOT Number
p.2o
CTA Drops AB5 Ap
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CARB Consultant
(916) 520-6040 - Ext '102
Disaster Planning is
Needed Now
I am not sule
whether natural or
manmade disas-
ters are more costly.
It is now a week
since Hurricane
Helene caused over
200 deaths and is
continuing to inflict suffering on residents that arc cut off lrom lood, potable water and emergency communications
to facilitate rescue of stranded residents. To minimize the additional loss of life it will require many Opes of trucks to move people out, goods in, clear debris and reestablish surface transportation. While this disaster is unfolding in the Southeast, we know that Califomians will invariably con- flont disasters and should be prepared. Neither Govemor Newsom nor CARB are helping in this regard.
During the several years of CARB Advanced Clean
Fleets (ACF) development there was light shed on the need to respond to disasters with appropriate vehicles to protect public health and safety. The adopted ACF requires that regulated state and local govemments and "high priority" pdvately-owned fleet that provide "mutual aid" assistance in disasters are required to phase-in zero emission vehicles starling at 25% by 2032, 50% by 2035 and 7 5'Yo thereaf- ter. CARB does not appear to be concemed about saddling emergency ollicials during future emergencies.
Just last month the Califomia legislature passed
Assembly Bill 3179 which would provide 911 and emer-
gency communications providers with reliefuntil the end of this decade to replace their utility bucket trucks and mobile cell towers with zero emissions trucks. Due to the uncer- tain terrain and potential for 2417 operation in remote areas the fleet owners sought relief. On September 29 Govemor Newsom vetoed the bill, declaring that CARB was follow- ing his Executive Order to reduce emissions by "providing safe, feasible and flexible compliance options" and the bill "undermines" those efforts. The following day the lack of emergency communications was identified as a key barrier to hurricane recovery. My belief is that CARB's failure to see this will result in unnecessary misery for Californians in the future.
In the meantime, the WSTAJed litigation against CARB
continues in state and federal courts. In Western States Ttucking Association vs. Steven Cliff (CARB Executive
OfTicer) was filed on July 21, 2023 in Fresno County
Superior Court. The suit requests a temporary and perma- nent injunction that would halt the implementation of the ACF. There have been extensive negotiations to resolve the issues outside of Court however this has not been success- ful io protect WSTA members interests. An initial hearing is scheduled for November 14,2024.
In a second case (Westem States Trucking Association,
Inc., et alv. EPA, el al) WSTAis seeking to invalidate the fed- eral approval of CARB's "ACT" Regulation to force electric truck manufacturing mandates. We believe the Court will take up this matter in the next several months. Athird WSTA action against EPA challenges the new federal tailpipe emis- sion standards for medium and hear.y-duty trucks will limit the production of intemal combustion hucks in future years.
The Westem Propane Gas Association has filed a law-
suit seeking to oveltum the recent Zero Emission Forklift Measure that CARB will use to phase out propane forklifts starting in 2026. There is also litigation by the Califomia Trucking Association that does not yet appear to have a court date.
We will continue to monitor this and I can best be
reached by email [email protected] with any questions.
CleanFleets.net Proposal
November 4, 2024
Attachment
Required Exhibits
2. 1.
7. 4.
5. 6.
DEBARMENT/SUSPENSION CERTIFICATE
INSTRUCTIONS ON CERTIFICATION REGARDING DEBARMENT AND SUSPENSION By signing and submitting this proposal, the prospective primary participant is providing the certification set out below.
The inability of a person to provide the certification required below will not necessarily result in denial of participation in this covered transaction. The prospective participant shall submit an explanation of why it cannot provide the certification set out below. The certification or explanation will be considered in connection with the department or agency's determination whether to enter into this transaction. However, failure of the prospective primary participant to furnish a certification or an explanation shall disqualify such person from particlpation in thls transaction.
The certification in this clause is any material representation of fact upon which reliance was placed when the department or agency determined to enter into this transaction. lf it is later determined that the prospective primary participant knowingly rendered an erroneous certification, in addition to other remedies available to the Federal Government. the department or agency may terminate this transaction for cause or default.
The prospective primary participant shall provide immediate written notice to the department or agency to whom this proposal is submitted if at any time the prospective primary participant learns that its certification was erroneous when submitted or has become erroneous by reason of changed circumstances.
The terms covered transaction, debarred, suspended, ineligible, lower tier covered transaction, participant, person, primary covered transaction, principal, proposal, and voluntarily excluded, as used in this clause, have the meanings sel out in the Definitions and Coverage sections of the rules implementing Executive Order 12549. You may contact the department or agency to which this proposal is being submitted for assistance in obtaining a copy of those regulations.
The prospective primary participant agrees by submitting this proposal that, should the proposed covered transaction be entered into, it shall not knowingly enter into any lower tier covered transaction with a person who is debarred, suspended, declared ineligible, or voluntarily excluded from participation in this covered transaction, unless authorized by the departmeni or agency entering lnto this transaction.
The prospective primary participant further agrees by submitting this proposal that it will include the clause titled "Certification Regarding Debarment, Suspension, lneligibility and Voluntary Exclusion - Lower Tier Covered Transaction," provided by the department or agency entering into this covered transaction, without modification, in all lower tier covered transactions.
A participant in a covered transaction may rely upon a certification of a prospective participant in a lower tier covered iransaction that it is not debarred, suspended, ineligible, or voluntarily excluded from the covered transaction, unless it knows thai the
9. .10.
certification is erroneous. A participant may decide the method and frequency by which it determines the eligibility of its principals. Each participant may, but is not required to, check the Nonprocurement List.
Nothing contarned in the foregoing shall be construed to require establishment of a system of records in order to render in good faith the certification required by this clause.
The knowledge and information of a participant is not required to exceed that which is normally possessed by a prudent person in the ordinary course of business dealings.
Except for transactions authorized under paragraph 6 of these instructions, if a participant in a covered transaction knowingly enters into a lower tier covered transaction with a person who is suspended, debarred, ineligible, or voluntarily excluded from participatlon in this transaction, in addition to other remedies available to the Federal Government. the department or agency may terminate this transaction for cause or default.
OEBARMENT/SUSPENSION CERTIFICATE
CERTIFICATION
1. The prospective primary participant certifies to the best of its knowledge and belief, that it and its principals: (a) Are not presently debarred, suspended, proposed for debarment, declared ineligible, or voluntarily excluded from a covered transaction by any Federal department or agency; (b) Have not wiihin a three-year period preceding this proposal been convlcted of or had a civil judgment rendered against them for commission of fraud or a criminal offense in connection with obtaining, attemptlng to obtain, or performing a public (Federal, State or local) transaction or contract under a public transaction; violation of Federal or State antitrust statutes or commission of embezzlement, theft, forgery, bribery, falsification or destruction of records, making false statements, or receiving stolen property; (c) Are not presently indicted for or otherulse criminally or civrlly charged by a governmental entity (Federal, State or local) with commission of any of the offenses enumerated in paragraph (1)(b) of this certification: and (d) Have not within a three-year period preceding this application/proposal had one or more public transactions (Federal, State or local) terminated for cause or default.
2. Where the prospective primary participant is unable to certify to any of the statemenls in this certification, such prospective participant shall include an explanation with this Signature of RESPONDENT's Authorized Official
ame and Title of RESPONDENT's Authorized Official
DEBARMENTiSUSPENSION CERTIFICATE
Date
#