California Fuels and Convenience Alliance
2520 Venture Oaks Way, Suite 100
Sacramento, CA 95833
916.646.5999
Cotati City Council
201 West Sierra Ave
Cotati, CA 94931
Re: Agenda Item #8.B- Prohibition on New Gas Stations
To: Mayor Mark Landman
Vice Mayor Susan Harvey
Councilmember Ben Ford
Councilmember John C. Moore
Councilmember Laura Sparks
The California Fuels and Convenience Alliance (CFCA) represents about 300 members, including nearly 90% of all the independent petroleum marketers in the state and more than one half of the state’s 12,000 convenience retailers. Our members are small, family- and minority-owned businesses that provide services to nearly every family in California.
Additionally, CFCA members fuel local governments, law enforcement, city and county fire departments, ambulances/emergency vehicles, school district bus fleets, construction firms, marinas, public and private transit companies, hospital emergency generators, trucking fleets, independent fuel retailers (small chains and mom-and-pop gas stations) and California agriculture, among many others. CFCA appreciates the opportunity to provide comment on this proposed ordinance.
The California Fuels and Convenience Alliance strongly opposes the proposed ordinances prohibiting the establishment of new gas stations. This ordinance will stifle electric vehicle (EV) charging infrastructure growth in Cotati and defies California’s efforts to fight climate change.
EV Charging and Alternative Fuels Infrastructure
Despite the growth of EVs both in California and nationally, EV charging infrastructure remains very expensive and will require funding from traditional fueling infrastructure until a vast majority of vehicles are not Internal Combustion Engine (ICE) vehicles. This scenario remains decades away as EVs only account for 2.799% of California’s total light-duty vehicle population as of December 2021 according to the California Energy Commission. 1 The state and federal
governments have recognized this reality and plan to expand alternative fueling networks by utilizing existing and potential new gas station sites, including hydrogen and CNG. Banning access to low carbon liquid fuels like renewable diesel, biodiesel, ethanol, and cleaner burning formulations of gasoline under development hamper California’s efforts to combat climate change in the near future.
Fairness and Equity
Some might claim that consumers could charge their EVs at home rather than allowing chargers at gas stations; however, this does not constitute a legitimate path to closing the EV charging gap. More than half of Californians live in multifamily dwellings, which have not been required to be built with EV chargers until recently and will need to be served by EV charging at other sources such as gas stations. As noted above, traditional fueling infrastructure pays for investments in EV infrastructure. Due to nearly nonexistent return-on-investment at this time, stations cannot install EV infrastructure without traditional fuel at this time.
1 https://www.energy.ca.gov/data-reports/energy-almanac/zero-emission-vehicle-and-infrastructure-statistics/light-duty-vehicle Additionally, the prohibition on new gas stations would hurt Cotati’s future infrastructure needs as mandated by the state through SB8 and SB9. These bills, passed to combat California’s housing crisis, would require Cotati to build more housing or face millions of dollars in fines. The estimated housing unit growth mandated by these bills will increase the need for traditional fueling sites beyond 2035 and more points of access for alternative fueling infrastructure.
Conclusion
CFCA urges the Cotati City Council to cooperate with state and federal programs to allow gas stations within the jurisdiction. Closing the EV charger gap and transitioning to a low or no carbon future is an “all hands-on deck” task that will require both public and private sector participation. Cotati and other local governments should not be making decisions that impede state and federal initiatives to grow EV charging and alternative fuel networks at gas stations.
Please contact Ari Berlfein, CFCA’s Policy Analyst, by email or phone with any questions or comments, [email protected] and (916) 646-5999